Anti-Bribery Policy

Last updated: 01 June 2021

Qube Apps Solutions Sdn Bhd – Anti-Bribery & Whistleblowing Policy

Qube Apps Solutions Sdn Bhd (QAS) is committed to high standards of ethical, moral, and legal business conduct.

The purpose of this policy is to set out:

• Our minimum expectations for complying with anti-bribery laws; and

• The obligation of every QAS business unit to adopt and implement an effective anti-bribery compliance program.

Scope & Compliances

QAS believes that corruption prevents fair market competition and threatens our socio-economic development, economy, and enterprises. We uphold the principles of business ethics, integrity, and comply with all applicable laws and regulations in all our business operations. QAS does not tolerate any form of corruption.

Our systems are designed to deter and prevent any acts of corruption. It is our policy that any employee or other person/entity acting on behalf of QAS must not, directly or indirectly, offer bribes to any official or individual/entity to gain business advantages.

If any supplier, agent, consultant, or business partner (“Partners”) of QAS offers bribes to any QAS employee, the employee must reject the bribe and report the case to the Company.

Through contractual covenants and procedures, QAS requires all of its Partners to comply with our anti-corruption statement and conduct themselves ethically in business dealings.

Anti-Money Laundering

Bank Negara Malaysia (BNM) is the competent authority under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA). BNM leads national efforts, formulates policies, and receives and analyses suspicious transaction reports (STR).

Scope under AMLA includes:

• Lawyers

• Accountants

• Trust companies

• Company secretaries

• Dealers in precious metals or stones (e.g., goldsmiths, jewelers)

• Registered estate agents

• Licensed casinos

• Licensed gaming outlets

• Moneylenders

• Pawnbrokers

• Leasing and factoring businesses

Whistleblowing

Background
This policy ensures that suspected wrongdoing is reported and managed in a timely and appropriate manner. All suspected fraud should be immediately reported to the Head of Department (HOD).

Policy Statement
Wherever and with whomever we operate, QAS is committed to doing so lawfully, ethically, and with integrity. Each of us shares the responsibility to uphold this commitment.

At times, the right course of action may be unclear, or wrongdoing may be suspected or known. We have a legal and moral duty to take proper action to identify and remedy such issues.

To support this, QAS has implemented a Whistleblowing Policy so that employees can report concerns confidentially and securely.

Objectives:

• Ensure all employees feel supported to speak up in confidence

• Encourage identification and challenging of improper behavior at all levels

• Provide clear reporting procedures

• Manage all disclosures consistently and professionally

• Assure confidentiality and protection against retaliation

Improper, unethical, or inappropriate behavior is unacceptable. This is endorsed and supported at the highest level.

Examples include (non-exhaustive):

• A criminal offense

• Fraud

• Failure to comply with legal obligations

• Miscarriage of justice

• Threat to health and safety

• Environmental damage

• Deliberate concealment of any of the above

Reporting Requirements

Please include the following where possible:

• Outline of known or suspected wrongdoing

• When, where, and how it occurred

• Names of those suspected (internal and/or external)

• Names of others with relevant information

• How you became aware of the issue

• Estimated value of any loss to QAS or others

• Breaches of internal controls, policies, or procedures

After Reporting

The HOD will acknowledge receipt within 3 working days and discuss the next steps.
You may be accompanied by a work colleague or Qualified Legal Professional in any meetings.
Other departments may be involved depending on the case (e.g., Internal Audit for suspected fraud).
All information will be kept confidential and, where possible, anonymous.

Investigation

An appropriate response will be determined based on the situation. The investigation aims to:

• Minimize risk of further wrongdoing

• Prevent further loss or reputational damage

• Preserve all evidence

• Establish the extent of any wrongdoing

Investigations are typically handled internally, though external investigators may be appointed when necessary.

Disciplinary Action

If an investigation reveals a report was made in bad faith, it may result in disciplinary action under QAS procedures.

Contact Us

For questions about this Anti-Bribery & Whistleblowing Policy, please contact:
📧 info@qubepos.com