Integrated Annual Report 2023 2 3 4 5 6 7 8 9 1 249 CORPORATE INTEGRITY AND ETHICAL BUSINESS CONDUCT • Conflict of Interest (“COI”) Declaration Procedure This procedure serves as a guide for declaring actual, potential, or perceived conflicts of interest identified and disclosed in accordance with the Conflict of Interest (“COI”) policy and outlines the subsequent actions to be taken in managing conflicts of interest among employees. • Anti-Bribery & Anti-Corruption (“ABAC”) Policy Statement At UEM Edgenta, we strive to uphold our core values and to present ourselves with integrity, ethics, and accountability which our employees must harness at both professional and personal levels. All UEM Edgenta stakeholders including directors, officers, controllers, and employees shall conduct our business dealings, relationships, and operations with a zero-tolerance approach towards bribery and corruption in compliance with statutory laws and regulatory requirements within jurisdictions in which UEM Edgenta operates. • Anti-Bribery & Anti-Corruption (“ABAC”) Guide UEM Edgenta takes a zero-tolerance approach to bribery and corruption and is committed to adhering to the highest standards of ethical behavior in the conduct of all our business dealings and relationships. This document provides an essential guide to curb bribery and corruption and describes standards of ethical behavior in the conduct of all our business dealings and relationships, we and/or any third party acting on our behalf, must not act corruptly in our business dealings. • No Gift Policy We at UEM Edgenta uphold the ‘No Gift Policy’ as an integral component of our commitment to maintaining the highest standards of integrity and ethical conduct. This policy is designed to prevent both actual and perceived conflicts of interest, aligning seamlessly with UEM Edgenta’s comprehensive Code of Conduct. By strictly prohibiting the acceptance of gifts, we ensure that our employees, stakeholders, and partners adhere to principles that promote fairness, transparency, and unbiased decision-making. This policy serves as a safeguard against undue influence and reinforces our dedication to fostering a corporate culture rooted in trust, accountability, and ethical business practices. • ABMS Manual This Manual sets out requirements in relation to MS ISO 37001:2016 Anti-Bribery Management System and guides a management system designed to help UEM Edgenta prevent, detect, respond to, and address bribery and corruption. • Whistleblowing Policy The policy encourages the reporting of wrongdoings in good faith, with the assurance that personnel or any parties making such reports shall be treated fairly, their identity remains confidential, and are protected from retaliation. • Whistleblowing Procedure UEM Edgenta’s Whistleblowing Procedure provides an avenue for our employees, stakeholders, and members of the public to report any actual or suspected malpractice, misconduct, or violation of the Group’s policies and procedures through dedicated and confidential channels which is the “Speak-up Channel”. • Investigation Procedure The investigation procedure is established to ensure a consistent process in assessing and investigating any allegation or violations of the UEM Edgenta Code of Conduct, policies and procedures, and applicable rules and regulations. This procedure ensures that investigation outcomes are recorded uniformly and in a timely manner and that any necessary corrective action and/or external reporting is executed appropriately. • Authorities’ Raid/Visit Procedures This procedure delineates the critical and practical aspects to be considered to provide an effective response when confronted with an authority raid. It encompasses detailed guidelines and actions necessary for handling the situation, ensuring a comprehensive and well-coordinated approach to address the demands and challenges posed during such encounters. The objective is to facilitate a swift, organised, and compliant response that aligns with legal requirements and safeguards the interests of UEM Edgenta.
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