Anti Bribery Policy

1.0 POLICY STATEMENT

1.1 All WRH MARINE SDN BHD (the “Company” collectively “we” or “ours”, or “us”)  Employee, AT ANY TIME, DO NOT ACCEPT ANY KIND OF GIFTS OR HOSPITALITY from any contractors, vendors or service providers. It is the policy of The  WRH MARINE SDN BHD to conduct all of our business in an honest and ethical manner. We take a ZERO-TOLERANCE approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the areas in which we operate.

1.2 The purpose of this policy is to:

  • set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and
  • provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

1.3 Bribery and corruption can be punishable for individuals by custodial sentences and if we are found to have taken part in corruption, the Company could face an unlimited fine, be excluded from tendering for public contracts and face damage to its reputation. We therefore take our legal responsibilities very seriously.

1.4 In this policy, third party means any individual or organisation that an affected person, as defined below, comes into contact with during the course of his/her work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

 

2.0 WHO IS COVERED BY THE POLICY?

2.1 This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as affected persons in this policy).

 

3.0 WHAT IS BRIBERY?

 

3.1 A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. All affected persons are prohibited from offering or receiving a bribe. In addition, the UK Bribery Act 2010 includes further offences of bribing a foreign official and, for the Company, failing to prevent bribery.

 

4.0 WHAT IS CORRUPTION?

4.1 Corruption is the act of giving or receiving of any gratification or reward in the form of cash or in-kind of high value for performing a task in relation to his/her job description.

4.2 Based on the Laws of Brunei – Prevention of Corruption Act (Chap. 131), there are four main corruption act namely:

  1. Requests / Receives bribe
    [Section 5 & 6 (a) of  Laws Of Brunei – Prevention of Corruption Act (Chap. 131)]
  2. Offer / Giving bribes
    [Section 5 & 6 (b) of Laws Of Brunei – Prevention of Corruption Act (Chap. 131)]
  3. To put forward a false claim
    [Section 6 (c) of Laws Of Brunei – Prevention of Corruption Act (Chap. 131)]
  4. Possession of unexplained property
    [Section 12 of Laws Of Brunei – Prevention of Corruption Act (Chap. 131)]

 

 

 

 

5.0 GIFTS AND HOSPITALITY

 

5.1 This policy prohibit normal and appropriate hospitality (given and received) to or from third parties.

5.2 The giving or receipt of gifts is prohibited, if the following requirements are met:

  1. it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
  2. it complies with local law;
  3. it is given in the Company’s name (or one of its subsidiaries’), not in an affected person’s personal name;
  4. it does not include cash or a cash equivalent (such as gift certificates or vouchers) unless approved by an affected person’s regional finance director;
  5. it is appropriate or customary in the circumstances;
  6. taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
  7. it is given openly, not secretly;
  8. gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of an affected person’s Regional MD.

 

 

Further Details of the Policy will only be shared among vendors, contractors and clients.