1. Purpose and Scope
WGA Marketing Sdn Bhd (hereinafter referred to as “the Company”) is committed to conducting business with the highest standards of integrity and ethics. This policy establishes the Company’s zero-tolerance position toward bribery and corruption in all forms. It applies to all employees, directors, and third-party associates (including contractors, consultants, and agents) acting on behalf of the Company.

2. Core Principles
The Company strictly prohibits the offering, promising, giving, requesting, or accepting of any bribe, whether in the form of cash, gifts, hospitality, or other advantages, to influence a business outcome or gain an improper advantage.

3. Key Areas of Risk
Gifts and Hospitality: While modest gifts or hospitality for branding and relationship-building purposes are common, they must never be used to influence a decision. All gifts must be reasonable, proportionate, and transparently recorded.

Facilitation Payments: The Company does not permit “grease payments” to government officials or private entities to expedite routine administrative tasks.

Charitable and Political Contributions: Any donations made on behalf of the Company must be legal, ethical, and approved by management to ensure they are not used as a cover for bribery.

Third-Party Due Diligence: The Company expects its business partners to adhere to similar ethical standards. Before engaging third parties, a basic assessment of their reputation and integrity should be conducted.

4. Compliance with Malaysian Law
This policy is designed to align with the Malaysian Anti-Corruption Commission (MACC) Act 2009 and the MACC (Amendment) Act 2018, specifically Section 17A regarding corporate liability. The Company recognizes that it can be held liable if a person associated with the organization commits bribery for the Company’s benefit.

5. Reporting (Whistleblowing)

The Company encourages employees and associates to report any suspected instances of bribery or corruption. Reports should be made promptly to ensure the integrity of our operations.

• Primary Contact: All reports or inquiries regarding this policy should be directed to management@swot.com.my.

• Protection: Reports can be made in good faith without fear of retaliation or victimization. All reports will be investigated thoroughly and treated with the strictest confidentiality.

6. Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or contract. Furthermore, individuals involved in bribery may be subject to criminal prosecution under Malaysian law.

7. Monitoring and Review
The management of WGA Marketing Sdn Bhd will periodically review this policy to ensure its effectiveness and relevance to the company’s evolving business operations in the IT and marketing sectors.