ANTI-BRIBERY AND ANTI-CORRUPTION STATEMENT

 CTOS is committed to conducting business dealings with integrity and has adopted a zero-tolerance approach against all forms of bribery and corruption. CTOS adheres to the principles of good corporate governance and emphasises on operating its business with fairness and transparency.

Under CTOS’ Anti-Bribery and Corruption Policy (“ABC Policy”), employees who refuse to pay bribes or participate in acts of corruption will not be penalised even if such refusal may result in losing business. Employees are not permitted to give or offer anything of value including gifts, hospitality, or entertainment to anyone for the purpose of improperly obtaining or retaining a business or personal advantage except otherwise governed by the ABC Policy.

This ABC Policy applies to CTOS and its stakeholders which include the directors, employees, business associates, members of public (where relevant) and all parties involved directly or indirectly in the affairs of the company. Full compliance to both the spirit and the letter of this ABC Policy is mandatory and should be maintained using a principle-based approach.

CTOS is fully committed to acting professionally, fairly and with integrity in all its business dealings and expects its employees to observe the same. Should you have any knowledge of, or reasonable belief of the existence of an attempted, suspected or actual bribery or reason to suspect any violation of the policy and the related laws, you are expected to report it in good faith via the following channels:

• Email to: whistleblower@ctos.com.my

SUMMARY OF CTOS’ ABC POLICY

 Introduction

The ABC Policy is a clear-cut set of guidelines and principles stringently adopted by CTOS and formulated based on the provisions under the Malaysian Anti-Corruption Commission (“MACC”) Act 2009, Section 17A of the MACC (Amendment) Act 2018 and all other relevant laws. Having a clear and unambiguous approach on CTOS’ position regarding bribery and corruption forms the cornerstone of an effective business integrity system.

 Purpose

This ABC Policy is intended to:

1. Set out CTOS’ overall position on bribery and corruption in all its forms.
2. Ensure compliance with all applicable anti-corruption regulatory requirements when conducting business.

Applicability

1. Applies to CTOS and its stakeholders which include:
   • Directors;
   • Employees;
   • Business Associates which comprise of customers, vendors, contractors, consultants, agents, outsourcing providers, solicitors, investors and valuers; and
   • All parties involved directly or indirectly in the affairs of CTOS.
2.  Applies to members of the public, where relevant.  

Policy Statement

1. CTOS adopts a zero-tolerance approach against all forms of bribery and corruption. All employees, business associates and individuals acting on behalf of CTOS should be responsible for upholding CTOS’ reputation by conducting business ethically and with integrity.
2. CTOS will not tolerate bribery or corruption directly or indirectly through third parties, whether explicitly prohibited by ABC Policy, laws or otherwise. Bribery and corruption in all its forms as it relates to the activities of CTOS is prohibited. Such acts of corruption may include in relation to:
   • Conflict of interest;
   • Gift, entertainment and hospitality;
   • Sponsorship and donation;
   • Political contribution;
   • Facilitation payment;
   • Money laundering.