Kossan Rubber Industries Bhd

Anti-Bribery and Corruption ("ABC") Policy

Introduction

Kossan Rubber Industries Bhd and its Group of Companies ("Kossan Group") uphold integrity, respect, and professionalism in all business operations. We are committed to conducting business with the highest ethical standards and ensuring compliance with all applicable anti-bribery and corruption laws, including but not limited to the Malaysian Anti-Corruption Commission Act 2009, the Malaysian Anti-Corruption Commission (Amendment) Act 2018, the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001, the U.K. Bribery Act 2010, and the U.S. Foreign Corrupt Practices Act 1977 (amended 1998) and any of its amendments or re-enactments that may be made by any relevant authority from time to time.

This ABC Policy applies to all employees, directors, subsidiaries, third-party vendors, suppliers, contractors, and any individual acting on behalf of Kossan Group. We expect our business associates to uphold the same standards and comply with this ABC Policy when engaging with us.

Zero Tolerance Commitment

Kossan Group maintains a zero-tolerance stance against all forms of bribery and corruption. We are committed to upholding integrity, transparency, and accountability in all our business dealings.

Strict Prohibition

All employees and business associates are strictly prohibited from, directly or indirectly:

  • Offering, giving, or promising bribes, kickbacks, or improper benefits;
  • Soliciting, requesting, or accepting bribes or undue advantages;
  • Providing or receiving gifts, incentives, commissions, or hospitality intended to improperly influence business decisions.

No Gift Practice

To prevent conflicts of interest, Kossan Group enforces a No Gift Practice in all business dealings. Employees must not accept or give gifts, entertainment, or hospitality that could be perceived as an attempt to gain an unfair advantage.

Exceptions require prior approval from the Board of Management of Kossan Group and must align with ABC Policies (defined below) and all applicable anti-bribery and corruption laws.

Ethical Business Partnerships

Kossan Group expects all business associates, including third-party vendors, suppliers, and contractors, to uphold ethical business practices and comply with standards consistent with this ABC Policy.

To ensure compliance, Kossan Group may conduct due diligence on third parties before and during business engagements. We reserve the right to terminate any relationship with parties involved in bribery, corruption, or unethical conduct.

Political Contributions and Charitable Donations

Kossan Group does not make political donations. All charitable contributions must undergo proper vetting to prevent misuse as a disguise for bribery or undue influence. Contributions must be transparent, properly documented, and comply with ABC Policies and all applicable anti-bribery and corruption laws.

Reporting and Whistleblowing

Employees and business associates are encouraged to report any suspected bribery or corruption through the following official reporting channels:

All reports will be treated with strict confidentiality, and whistleblowers will be protected under the Whistleblower Protection Act 2010. No retaliation, discrimination, or negative consequences will be imposed on individuals who report in good faith.

Violations and Consequences

Any employee found violating this ABC Policy will face stern disciplinary action, including termination. Business associates who breach this ABC Policy risk immediate contract termination and cessation of business dealings.

Violations may also result in legal prosecution, fines, or other penalties under applicable laws. Further legal action may be pursued if Kossan Group’s interests are harmed due to non-compliance.

Training and Compliance Monitoring

Kossan Group will provide regular training to employees and relevant stakeholders to enhance awareness and understanding of this ABC Policy. Compliance monitoring, audits, and risk assessments will be conducted periodically to ensure adherence to anti-bribery and corruption laws.

Continuous Improvement and Policy Revisions

Kossan Group is committed to continuously improving its anti-bribery and corruption practices. This ABC Policy will be reviewed and updated periodically to remain effective, relevant, and in line with the latest legal and regulatory requirements. Employees and business associates will be notified of significant updates, and we encourage feedback to strengthen our commitment to integrity and ethical business conduct.

In addition to this ABC Policy, employees can refer to Kossan’s internal Anti-Bribery and Corruption Framework, Anti-Bribery and Corruption Guidelines, and Gifts, Hospitality, and Entertainment Guidelines (collectively referred to as “ABC Policies”) for further details on implementation and compliance.

Business associates or external parties requiring further information may reach out to us at legal@kossan.com.my.

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