1. This Anti-Corruption & Anti-Bribery Policy (the “Policy”) is established by Messrs. Lee & Tengku Azrina, Johor Bahru, Johor, Malaysia (the “Firm”) in line with Section 17A of the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act”), which was enacted under the Malaysian Anti-Corruption Commission (Amendment) Act 2018.

    Section 17A of the MACC Act provides that a commercial organization commits an offence if any person associated with the commercial organization commits a corrupt act in order to obtain or retain business or an advantage in the conduct of business for the commercial organization.
  1. The term "commercial organization" means:
    1. a company incorporated in Malaysia, whether carrying on business in Malaysia or elsewhere;
    2. a company wherever incorporated and carries on business in Malaysia or part of a business in Malaysia;
    3. a partnership under the Partnership Act 1961 or Limited Liability Partnerships Act 2012, and carries on a business in Malaysia or elsewhere; or
    4. a partnership wherever formed and carries on a business or part of a business in Malaysia.
  1. It is a defence to such corporate liability offence if it can show that it had adequate procedures in place to prevent persons associated with the commercial organization from carrying out the corrupt conduct.

    The Guidelines on Adequate Procedures issued by the National Centre for Governance, Integrity and Anti-Corruption under the Prime Minister’s Department on 4 December 2018 pursuant to Section 17A(5) of the MACC Act is aimed at assisting commercial organizations understand what adequate procedures should be implemented to prevent the occurrence of corrupt practices in their business activities.

    A person is associated with a commercial organization if he/she is a director, or employee of the commercial organization, or is a person who performs services for or on behalf of the commercial organization.
  1. SCOPE

  1. This Policy applies to the following persons :

    • partners, employees (comprising lawyers and support staff, whether full-time, part-time, contract or temporary), pupils-in-chambers and attachment students (collectively, “Members”, and individually “Member”) of the Firm; and

    • consultants, contractors, seconded staff, volunteers, agents, sponsors, suppliers, customers, any third parties and any other person associated with the Firm

    (collectively, “persons connected” or individually “person connected”).

    This Policy sets out the practice of upholding high levels of personal and professional values in all the Firm’s practice, commercial interactions and decisions.
  1. The purpose of this Policy is to:

    1. set out the responsibilities of the Firm and of those working for the Firm, in observing and upholding the Firm’s position on bribery and corruption; and

    2. provide information, guidance and procedures to those working for the Firm on how to recognize and deal with bribery and corruption issues

  1. The Firm takes a zero-tolerance approach towards bribery and corruption, and is committed to behaving professionally, fairly and with integrity in all our business dealings and relationships wherever the Firm operates, and implementing and enforcing effective systems to counter bribery and corruption.

    The consequences of bribery and corruption are severe, and may include imprisonment for individuals, hefty fines, and damage to the Firm’s reputation.

    As a person connected to the Firm, you must not influence others or be influenced, either directly or indirectly, by paying or receiving any forms of gratification that are deemed unethical or will tarnish the Firm’s reputation.

    You must comply with all prevailing anti-corruption and anti-bribery laws and regulations applicable to the Firm. You must not directly or indirectly promise, offer, grant or authorize the giving of money or anything else of value, to government officials, officers of private enterprises and their connected persons to obtain or retain a business or an advantage in the conduct of business. These include:

    • Commissions - that you have reason to suspect will be perceived as bribes or have reason to suspect will be used by the recipient to pay bribes or for other corrupt purposes;

    • Facilitation payments - which are regarded as unofficial payments or other benefits made to government officials to gain access, secure or expedite the performance of a routine function they are in any event obligated to perform. The Firm does not allow facilitation payments to be made. You must inform the appropriate compliance personnel when encountered with any request for a facilitation payment. If you have made any payment which could possibly be misconstrued as a facilitation payment, the appropriate compliance personnel must immediately be notified and the payment recorded accordingly;

    • Bribe – Anything of value given in an attempt to affect a person’s actions or decision in order to gain or retain a business advantage. Anything of value includes cash, entertainment or others gifts or courtesies;

    • Corruption – The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government;

    • Kickbacks – The return of a sum already paid or due as a reward for awarding of furthering work in the Firm; or

    • Political Contribution – while you may act in your personal capacity as a citizen who is not restricted to make any personal political donations, the Firm will not make any reimbursement for these personal political contributions back to you as the Firm adopts an apolitical stance.

    However, the Firm may contribute to the following, subject to qualifications contained herein:

    • Charitable Contributions, sponsorships or donations with corporate social responsibility in mind – these corporate social responsibility activities to the society may be made by the Firm to community projects or charities in good faith, subject to the approval of either of the founding partners of the Firm, namely Lee Ting Kiat or Tengku Azrina (collectively, the “Founding Partners” and individually the “Founding Partner”); or

    • Gifts, hospitality and entertainment – these exchange of business courtesies may be offered to or received from you but only where it is appropriate, reasonable, modest and bona fide to do so in the circumstances that do not influence business decisions. Any such business courtesies offered or received on behalf of the Firm must be approved by a Founding Partner.

    All records of financial transactions under the Policy must be properly kept, substantiated and justified as part of the admissibility documentary evidence.

    You must not directly or indirectly involve in any corrupt conduct, which include but not limited to the abuse of position or authority, and falsification of documents.

    You must also refrain from any activity or behaviour that could give rise to the perception or suspicion of any corrupt conduct or the attempt thereof. Promising, offering, giving or receiving any improper advantage in order to influence the decision of the recipient or to be so influenced may not only result in disciplinary action but also criminal charges.

    You will not suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes even if such refusal may result in the Firm losing work or not meeting targets.

  1. We may modify or amend this Policy from time to time at our discretion. The updated version will apply and supersede any and all previous version. We will update the latest version on our website from time to time.

  1. Apart from understanding and complying with this Policy, a Member of the Firm will be responsible to:

    • provide awareness training and retraining to those reporting to you;

    • ensure those reporting to you understand and comply with the Policy;

    • promote compliance and good ethical values via leadership by example; and

    • provide guidance to others who have raised concerns or questions regarding the Policy.

  1. Any Member of the Firm with any suspicion, concern, or belief regarding a breach of the provisions of MACC Act or policies, guidelines, rules and regulations as may be imposed by the relevant authorities and/or the Firm’s internal policies, are encouraged to raise, notify and make a report via the channel outlined in our Whistleblowing Policy.

    All Members of the Firm must read the Policy published in the Firm’s website, and are deemed to have been notified of the applicability of the Policy to them and agreed to comply with the Policy upon joining the Firm, and may be subjected to disciplinary action, including termination of appointment, employment or dismissal, for violating the Policy. Violation of the Policy that is related to criminal acts may result in prosecution after referral to the appropriate authorities.

    Business partners (clients, suppliers, bankers and stakeholders) are encouraged to adopt similar principles and standards of behaviour.

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  1. Lee & Tengku Azrina, Johor Bahru, Johor, Malaysia (the “Firm”) is committed to upholding values and highest standard of work ethics for partners, employees (comprising lawyers and support staff, whether full-time, part-time, contract or temporary), pupils-in-chambers and attachment students (collectively, “Members”, and individually “Member”) of the Firm, in line with good practices.

    The Firm has adopted the following Whistleblowing Policy (the “Policy”) to provide an avenue for the Members of the Firm and the public to raise genuine concerns of any wrongdoing or improper conduct involving the Firm.

  1. The objective of this Policy is to encourage reporting of any suspected fraud, corruption, conduct or inappropriate behaviour of the Firm. The Policy will provide an avenue for all Members of the Firm and all agents, vendors, contractors, suppliers, consultants and clients of the Firm to raise concerns about any improper conduct without fear of retaliation and to offer protection for the reporter who reports such allegations. This will strengthen the accountability and transparency in the professional practice of the Firm.

  1. The “wrongdoing” or “improper conduct” under this Policy includes but not limited to the following:

    • Fraud; misappropriation of funds or assets

    • Misconduct such as bribery, corruption or blackmail

    • Violation of the Firm’s code of conduct, procedures or policies

    • Improper or unethical conduct or behaviour

    • Conflict of interest

    • Theft or embezzlement of fund or assets

    • Abuse of power or position

    • Breach of confidentiality

    • Criminal breach of trust

    • Failure to comply with any legal obligations or breach of internal control

    • Danger to health and safety of any Member of the Firm or any other individual

    • Sexual harassment.

    The above list is not exhaustive and includes any acts or occasions which, if proven, will constitute an act of misconduct of the person concerned or any criminal offence under relevant legislations in force.

  1. The Firm is committed to ensuring confidentiality in respect of all matters raised under this Policy and those who lodge a report in good faith.

    • Confidentiality

    • The confidentiality of identity of the whistleblower will be ensured and protected, unless otherwise required by law. The Firm assures that all reports will be treated in the strictest of confidence and will be promptly investigated.

    • Assurance against victimization, retaliation and immunity from disciplinary action

    • This Policy provides assurance that the whistleblower, if a Member of the Firm, will be protected against any form of victimization, retaliation and immunity from disciplinary action from the whistleblower’s immediate supervisor or department/division head or any other person exercising power or authority over the whistleblower in his/her employment. However, whistleblowers making a report in bad faith or based on unfounded allegations or containing trivial and malicious claims may be subjected to disciplinary actions by the Firm.

  1. The channel of reporting is through the procedure provided under paragraph 6 below. The Firm will not entertain any anonymous whistleblowing. However, the Firm reserves the right to investigate any anonymous report. The whistleblower must disclose his/her personal identity in the Whistleblower Report Form attached below.

  1. If a Member of the Firm has a concern about the conduct of a fellow Member in the working environment (e.g. that they are not treating colleagues with respect), they should raise these concerns to their immediate superior, or if that is not possible, the concerns should be reported directly to the following personnel, marked “Strictly Confidential – To Be Opened By Addressee Only” :

    • Name : Tengku Azrina binti Raja Abdul Aziz
      Position : Partner
      Address : Unit 13-01, Level 13, Menara Landmark
      12, Jalan Ngee Heng
      80000 Johor Bahru, Johor, Malaysia.

    The Whistleblower Report must contain the following information:

    • Types of misconduct or wrongdoings

    • Name of person/persons involved

    • Time, location and dates of misconduct or wrongdoings occurred

    • How the misconduct or wrongdoings were perpetrated

    • Other witness to the misconduct or wrongdoings

    • Documentation or evidence available

    The Firm will take appropriate action to protect a whistleblower who makes a serious allegation in the reasonable belief that it is in the public interest to do so from any reprisals, harassment or victimization.

    The Whistleblower Report Form is enclosed below.

  1. This Policy cannot be amended without approval from the Managing Partner of the Firm. It will be reviewed from time to time to ensure that it remains effective and meets best practice standards and the needs of the Firm.

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Please provide the following details for any suspected serious misconduct or any breach or suspected breach of law or regulation that may adversely impact the Firm. Please note that you may be called upon to assist in the investigation, if required.

(This section may be left blank if the reporter wish to remain anonymous)

COMPLAINT: Briefly describe the misconduct / improper activity and how you know about it. Specify what, who, when, where and how. If there is more than one allegation, number each allegation and use as many pages as necessary.

1. What misconduct / improper activity occurred? *

2. Who committed the misconduct / improper activity? *

3. When did it happen and when did you notice it? *

4. Where did it happen? *

5. Is there any evidence that you could provide us?

6. Are there any other parties involved other than the suspect stated above?

7. Do you have any other details or information which would assist us in the investigation?

8. Any other comments?



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