Tropicana and its subsidiaries are committed to conducting business ethically in compliance with all applicable anti-bribery and anti-corruption laws of the country in which the Group operates. The Group does not condone any form of bribery and corruption. Our Anti-Bribery and Anti-Corruption Policy (“ABAC Policy”) provides guidance on how to prevent, deal with and combat bribery and corrupt activities and issues that may arise in the course of business. The Policy applies to all employees, directors (executive and non-executive) and any person who performs services for or on behalf of the Group, which includes contractors, sub-contractors, consultants, suppliers, agents, intermediaries and representatives of the Group. All new recruits as well as employees promoted, transferred and in exposed positions are trained on the ABAC Policy by the Group Human Resources. Meanwhile, the Group Internal Audit, an independent authority, has oversight of the implementation of compliance controls related to this policy. The Head of Group Internal Audit reports directly to the Audit Committee, the Group Management Committee and the Board of Directors. The Risk Management Team conducts regular risk assessments to identify bribery and corruption risks potentially affecting the Group. A whistleblower will be accorded the protection of confidentiality of identity, to the extent reasonably practicable. In addition, an employee who whistleblows internally will also be protected against any adverse and detrimental actions for disclosing any improper conduct committed or about to be committed within the Group, to the extent reasonably practicable, provided that the disclosure is made in good faith. Such protection is accorded even if the investigation later reveals that the whistleblower is mistaken as to the facts and the rules and procedures involved. Upon the completion of the whistleblowing process and procedures, the whistleblower will be accorded the privilege to be notified of the outcome of the disclosure. Heads of Departments and the Group Human Resources are responsible to deal with enquiries related to whistleblowing. Alternatively, whistleblowers may email whistleblower@tropicanacorp.com.my PROCUREMENT PRACTICES Procurement in Tropicana comes under the oversight of Group Procurement. Tropicana’s approach to procurement is guided by the Group’s procurement policy. To maintain product quality, we emphasise effective procurement measures that facilitate effective engagement with suppliers who align with the Group’s commitment to product quality and service excellence. Fair Selection and Continuous Assessment We strive to procure our resources and building materials from suppliers who share the same commitment to product quality and adherence to regulatory standards. Taking into consideration their job history, cost of service and ability to meet deadlines, we enforce stringent selection and evaluation methods to ensure that our suppliers are contracted based on merit. Selection • Product sourcing via the Approved Suppliers List (“ASL”) Survey • If products are unavailable on the ASL, the Group will conduct open market research for alternatives • Upon the identification of suitable replacement vendors, the new vendors will be required to complete the Vendor Survey Form (“VSF”) Selection • Shortlisted vendors are surveyed and selected based on financial security, labour costs, compliance, product pricing and quality Continuous Assessment • Suppliers are periodically assessed for their performance and compliance based on the criteria outlined in the Group’s SOP The Group remains uncompromising in our stance on product quality and service excellence which extends to the suppliers we engage with. In the event that contracted suppliers fail to meet the performance benchmark set by the Group, the following consequence is applied: • Probation Supplier – Suspended from tender participation for a specified period • Not Acceptable Supplier – Removal from Approved Suppliers List (“ASL”) list ANTI-CORRUPTION & WHISTLEBLOWING POLICY 103 TROPICANA SUSTAINABILITY STATEMENT
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