1. Purpose
COSMOSWORLD MANAGEMENT SOLUTION SDN. BHD. (“CWMS”, “the Company”, “we”, “our” or “us”) is committed to conducting its business with integrity, transparency, accountability and professionalism. CWMS adopts a zero-tolerance approach towards bribery, corruption, kickbacks, secret commissions, improper payments and other forms of unethical conduct.
The purpose of this Anti-Bribery & Anti-Corruption Policy (“Policy”) is to establish clear standards of conduct for directors, management, employees, workers, representatives, agents, consultants, contractors, suppliers, service providers, business partners and other persons acting for or on behalf of CWMS.
This Policy is intended to support responsible business decisions, protect the reputation and interests of CWMS, promote ethical business practices and ensure that all business activities are conducted in accordance with applicable Malaysian laws, regulatory requirements, contractual obligations and accepted standards of corporate governance.
2. Scope
This Policy applies to all CWMS operations, departments, offices, projects, business units and activities, including business conducted directly by CWMS or through third parties.
It applies to all directors, officers, managers, employees, temporary personnel, workers, consultants, representatives, agents and any other person performing duties for or on behalf of CWMS.
CWMS also expects suppliers, subcontractors, vendors, recruitment partners, labour providers, accommodation providers, transportation providers, consultants, professional advisers and other business partners to conduct themselves in a manner consistent with the principles set out in this Policy.
3. Our Commitment
CWMS will not tolerate bribery or corruption in any form, whether direct or indirect, whether involving the public sector or private sector, and whether involving money, gifts, services, benefits, opportunities or anything else of value.
No employee or representative of CWMS may offer, promise, give, request, agree to receive or accept any improper advantage for the purpose of influencing a decision, obtaining or retaining business, securing a commercial advantage, avoiding an obligation, accelerating an official process or improperly rewarding another person.
CWMS expects all persons covered by this Policy to exercise good judgment, act honestly, maintain appropriate records and immediately raise concerns where any activity may create an actual, potential or perceived bribery or corruption risk.
4. Prohibited Conduct
The following conduct is strictly prohibited:
- Offering, promising or giving a bribe to any person.
- Requesting, receiving or accepting a bribe or improper benefit.
- Paying or receiving kickbacks, secret commissions or undisclosed rebates.
- Offering money, gifts, entertainment, employment, travel, accommodation or other benefits to improperly influence a decision.
- Making unofficial payments to obtain approvals, licences, permits, contracts, visas, quotas, inspections, certifications or other advantages.
- Using an agent, consultant, supplier, subcontractor, intermediary or other third party to make an improper payment on behalf of CWMS.
- Creating false invoices, fake expenses, inflated quotations or misleading accounting records.
- Disguising improper payments as consultancy fees, commissions, reimbursements, marketing costs, donations, sponsorships or other legitimate expenses.
- Providing benefits to relatives, friends or associates of a decision-maker in order to influence that decision-maker.
- Retaliating against any person who refuses to participate in bribery or who raises a genuine concern.
5. Bribery
Bribery generally involves offering, giving, requesting, receiving or agreeing to receive something of value in order to improperly influence an action, decision or outcome.
A bribe does not have to involve cash. It may include gifts, entertainment, travel, meals, employment opportunities, discounts, commissions, preferential treatment, confidential information, contracts, services, accommodation, transportation or any other personal or commercial advantage.
The value of the benefit is not the only consideration. A relatively small benefit may still constitute an improper inducement depending on the purpose, timing, recipient and circumstances.
6. Facilitation Payments
CWMS prohibits facilitation payments or unofficial payments made to secure, accelerate or influence routine governmental, administrative, regulatory or commercial processes.
Employees must not make payments to accelerate the processing of applications, permits, approvals, immigration matters, licences, registrations, inspections, certifications or other official procedures unless the payment is an official and legally prescribed fee supported by proper documentation or receipt.
Where a person requests an unofficial payment, the employee or representative should refuse the request where safe and practical to do so and report the matter to Management.
7. Gifts, Hospitality and Entertainment
Reasonable business gifts, meals, hospitality and entertainment may sometimes be appropriate where they are lawful, modest, infrequent, transparent and connected to a genuine business purpose.
However, gifts or hospitality must never be offered or accepted where they may reasonably be perceived as influencing a business decision, procurement process, contract award, regulatory decision, payment approval, recruitment decision or other official action.
Employees must exercise particular caution during tender processes, contract negotiations, licence applications, audits, inspections, disputes, payment approvals and other situations where important decisions are pending.
Cash gifts, cash equivalents, personal loans, secret commissions and excessive or luxurious hospitality are prohibited unless specifically permitted under an approved Company process and applicable law.
8. Government and Public Officials
Interactions with government agencies, regulators, immigration authorities, local authorities, licensing bodies and other public institutions require a high standard of integrity and transparency.
No person acting for CWMS may offer or provide any payment, gift, benefit, favour, employment opportunity or other advantage to a public official for the purpose of influencing an official act or decision.
Official payments must be made only through recognised channels and must be supported by appropriate receipts, invoices, official payment references or other documentation.
9. Political Contributions
CWMS does not permit Company funds, assets or resources to be used for political contributions intended to improperly influence business decisions, regulatory outcomes, government approvals or commercial advantages.
Employees may participate in lawful political activities in their personal capacity, but such participation must not be represented as an activity or position of CWMS unless formally authorised by the Company.
10. Charitable Donations and Sponsorships
CWMS may support legitimate charitable, community, educational or social initiatives where such support is lawful, transparent and consistent with the Company's values.
Donations and sponsorships must never be used as a method to disguise bribery, secure contracts, obtain approvals, influence officials or create improper commercial advantages.
Where appropriate, due diligence should be conducted on the recipient and the purpose of the contribution should be properly documented.
11. Third Parties and Business Partners
CWMS recognises that bribery and corruption risks may arise through third parties acting for or in connection with the Company.
Appropriate care should therefore be taken when selecting and engaging agents, consultants, subcontractors, suppliers, recruitment partners, labour providers, accommodation providers, transportation providers and other business partners.
Where appropriate, CWMS may consider the reputation, ownership, business background, qualifications, experience, pricing structure, relationships and compliance standards of a proposed business partner before entering into an arrangement.
Payments to third parties must be commercially reasonable, properly documented and made for legitimate goods or services actually provided.
Unusual requests for cash payments, payments to unrelated bank accounts, excessive commissions, unexplained fees, payments to personal accounts or payments to third parties located in unrelated jurisdictions should be treated as potential warning signs.
12. Procurement and Contracting
Procurement and contracting decisions should be based on legitimate business considerations such as capability, quality, service, commercial terms, compliance, experience, reliability and value.
Employees must not accept personal benefits in exchange for awarding contracts, approving quotations, selecting vendors, approving invoices, increasing prices or providing preferential treatment.
Where conflicts of interest exist, they should be disclosed before the relevant procurement or contracting decision is made.
13. Recruitment and Employment
Recruitment, promotion, deployment, salary, benefits and other employment-related decisions must not be used as improper inducements.
No person should be recruited, promoted, deployed or given preferential treatment for the purpose of improperly influencing a client, supplier, public official, business partner or other decision-maker.
Where a candidate is closely connected to a client, supplier, public official or person involved in an important commercial decision, the relationship should be disclosed where relevant and appropriate safeguards should be considered.
14. Conflicts of Interest
A conflict of interest may arise where a person's personal, financial, family or business interests interfere, or appear to interfere, with the interests of CWMS.
Employees and representatives should disclose actual or potential conflicts of interest that may affect their professional judgment or decision-making.
Examples may include ownership interests in suppliers, personal relationships with vendors or clients, undisclosed commissions, outside employment, private business interests or financial arrangements involving parties that conduct business with CWMS.
15. Books, Records and Financial Controls
CWMS requires business transactions to be accurately and appropriately recorded.
No false, incomplete, misleading or artificial accounting entry may be created for the purpose of concealing a payment, benefit or transaction.
Invoices, receipts, quotations, contracts, expense claims, payroll records, commissions and other financial documents should accurately reflect the nature of the underlying transaction.
Employees must not create secret accounts, undisclosed funds or unrecorded transactions.
The Company may implement financial controls, approval limits, separation of duties, supporting-document requirements and periodic reviews to reduce bribery and corruption risks.
16. Cash Payments
Cash transactions may present increased compliance and fraud risks. Where possible, business payments should be made through traceable banking or approved payment channels.
Any cash payment should have a legitimate business purpose, appropriate approval and proper supporting documentation.
Requests for unusual cash payments, payments without receipts, split payments designed to avoid approval thresholds or payments to individuals instead of contracted business entities should be treated with caution.
17. Commissions, Referral Fees and Incentives
Commissions, referral fees, incentives and similar payments must relate to legitimate services, be commercially reasonable and be properly documented.
CWMS does not permit commissions or incentives to be used as a mechanism to disguise improper payments.
Employees should raise concerns where commissions appear unusually high, where the recipient has no clear role in the transaction or where payment instructions are inconsistent with the contractual arrangement.
18. Red Flags
Circumstances that may indicate an increased bribery or corruption risk include unusually high commissions, unexplained consultancy fees, requests for payment to unrelated third parties, cash payment requests, refusal to provide invoices, secrecy regarding ownership, close relationships with decision-makers, unrealistic service descriptions, pressure to make urgent payments without documentation or requests to avoid normal approval processes.
The presence of a red flag does not necessarily mean that wrongdoing has occurred, but it requires appropriate consideration and, where necessary, further review.
19. Reporting Concerns
CWMS encourages employees, workers, clients, suppliers and business partners to raise concerns where they reasonably believe bribery, corruption, fraud, improper payments or unethical conduct may have occurred.
Concerns may be reported to Management or through any designated CWMS Speak-Up, whistleblowing or confidential reporting channel.
Reports should include, where available, relevant facts, dates, persons involved, documents, communications or other information that may assist the Company in understanding the concern.
A person making a report is not expected to prove the allegation before raising the concern. Reports should, however, be made honestly and in good faith.
20. Protection Against Retaliation
CWMS does not tolerate retaliation against a person who, in good faith, raises a concern, refuses to participate in bribery or assists in an internal review or investigation.
Retaliation may include dismissal, threats, harassment, unfair treatment, reduction of duties, intimidation or other adverse action taken because a person raised a genuine compliance concern.
Knowingly making false or malicious allegations may, however, result in appropriate disciplinary action.
21. Investigation and Response
CWMS may review or investigate suspected breaches of this Policy where appropriate.
Employees and representatives are expected to cooperate with legitimate Company investigations and provide accurate information.
Where a breach is identified, CWMS may take appropriate corrective action, including improvements to controls, disciplinary action, termination of employment or contractual relationships, recovery of losses and referral to relevant authorities where required or appropriate.
22. Disciplinary Action
Breach of this Policy may be considered serious misconduct.
Depending on the circumstances, consequences may include counselling, formal warning, suspension, termination of employment, termination of contract, removal from a project, recovery of losses or other action permitted by law and contract.
23. Responsibilities of Management
Management is responsible for promoting an ethical culture and supporting reasonable anti-bribery and anti-corruption controls within the Company.
Managers should demonstrate appropriate behaviour, avoid encouraging employees to achieve business results through improper means and respond appropriately when compliance concerns are raised.
24. Responsibilities of Employees
Every employee and representative of CWMS has a responsibility to understand and comply with this Policy.
Employees must avoid participating in prohibited conduct, maintain accurate records, follow applicable approval procedures, disclose relevant conflicts of interest and raise concerns where improper conduct is suspected.
No employee will be criticised for losing business, delaying a transaction or refusing an opportunity where doing so is necessary to comply with this Policy or applicable law.
25. Training and Awareness
CWMS may provide anti-bribery and anti-corruption guidance, awareness communications or training to employees and relevant business partners where appropriate.
Training may be tailored according to job responsibilities, risk exposure, interaction with government authorities, procurement responsibilities, financial authority or other relevant factors.
26. Monitoring and Review
CWMS may periodically review its anti-bribery and anti-corruption controls to assess whether they remain appropriate for the Company's business activities and risk profile.
This may include review of policies, approval procedures, contractual arrangements, business partner relationships, financial records, complaints, reported concerns and relevant changes in law or business operations.
27. Compliance with Malaysian Law
CWMS conducts its business in Malaysia and expects all persons acting for or on behalf of the Company to comply with applicable Malaysian anti-corruption, corporate, employment, financial and regulatory requirements.
Nothing in this Policy is intended to limit or replace any legal obligation imposed on CWMS or any individual under applicable law.
Where applicable law imposes a higher standard than this Policy, the applicable legal requirement should be followed.
28. Cooperation with Authorities
CWMS will cooperate with lawful requests from competent regulatory, enforcement or governmental authorities in accordance with applicable law.
Employees must not destroy, alter, conceal or falsify records relating to an investigation, regulatory inquiry or suspected compliance matter.
29. Confidentiality
Information relating to reported concerns, investigations and disciplinary matters will be handled with appropriate sensitivity and confidentiality, subject to legal, regulatory, contractual and operational requirements.
Information may be shared with persons who reasonably require access for investigation, legal advice, decision-making, regulatory reporting or corrective action.
30. Questions and Guidance
Employees who are uncertain whether a payment, gift, business arrangement, commission, benefit or proposed action complies with this Policy should seek guidance from Management before proceeding.
Where there is uncertainty, the preferred approach is to pause the proposed transaction, obtain clarification and ensure that the decision and supporting reasons are appropriately documented.
31. Policy Ownership
This Policy is owned by the Management of COSMOSWORLD MANAGEMENT SOLUTION SDN. BHD.
Management is responsible for maintaining this Policy, overseeing appropriate implementation and approving material amendments.
32. Review and Updates
This Policy will be reviewed periodically and may be amended where necessary to reflect changes in law, regulation, business activities, contractual requirements, risk assessments, operational experience or recognised corporate governance practices.
The current published version of this Policy will supersede previous versions unless otherwise stated.
33. Policy Statement
CWMS believes that sustainable business relationships are built on trust, integrity and accountability. The Company expects all persons representing CWMS to conduct business honestly and to reject bribery, corruption and improper influence in all forms.
No commercial opportunity, contract, payment, approval or business advantage is considered more important than maintaining the integrity of CWMS and complying with applicable legal and ethical standards.
By working with CWMS, employees, representatives and relevant business partners are expected to support these principles and contribute to a professional, transparent and responsible business environment.
Policy Number: CWMS-POL-002
Policy Title: Anti-Bribery & Anti-Corruption
Policy Owner: Management
Version: 1.0
Effective Date: 5 September 2026
Review Date: 5 September 2027
This policy is subject to applicable Malaysian law, contractual obligations and periodic review. It may be updated and does not itself guarantee legal compliance.