ANTI-BRIBERY, CORRUPTION, AND WHISTLEBLOWING POLICY AND PROCEDURE

Company Name: Wanfah Prosper PLT

Effective Date: 1st June 2025

Version: 1.0

SECTION 1: ANTI-BRIBERY AND CORRUPTION POLICY

1.1 Policy Statement

Wanfah Prosper PLT (the “Company”) is committed to conducting its business ethically, professionally, and with the highest level of integrity. The Company enforces a zero-tolerance approach toward all forms of bribery and corruption.

This Policy is established in compliance with the Malaysian Anti-Corruption Commission (MACC) Act 2009 and the MACC (Amendment) Act 2018 (Section 17A) regarding corporate liability.

1.2 Scope

This policy applies to all partners, employees (whether permanent, contract, or temporary), trainers, consultants, vendors, contractors, and any third parties acting on behalf of Wanfah Prosper PLT (collectively referred to as “Associated Persons”).

1.3 Key Definitions

  • Bribery: The offering, promising, giving, requesting, or accepting of any gratification (e.g., cash, gifts, hospitality, favors, or services) to influence a person’s actions or decisions to obtain or retain a business advantage.

  • Corruption: The abuse of entrusted power or position for personal or corporate gain.

1.4 Prohibited Activities

Associated Persons are strictly prohibited from:

  • Offering, promising, or giving any bribe or gratification to secure a contract, business advantage, or regulatory approval.

  • Requesting, agreeing to receive, or accepting any bribe or gratification from clients, vendors, public officials, or third parties.

  • Engaging in “facilitation payments” (small payments made to secure or speed up routine government actions).

1.5 Gifts, Hospitality, and Entertainment

Wanfah Prosper PLT practices a general “No Gift” Policy, subject to limited exceptions.

  • Corporate Gifts & Hospitality: Moderate corporate gifts (e.g., diaries, pens, calendars) or reasonable business hospitality (e.g., standard business lunches) are permissible only if they are transparent, modest, routine, and lack corrupt intent.

  • Pre-Approval: Any gift or entertainment valued above a nominal threshold of RM 300 must be declared and approved in writing by the Designated Compliance Officer / Managing Partner.

SECTION 2: ANTI-BRIBERY PROCEDURES

2.1 Due Diligence

Before engaging any new business associates, corporate clients, trainers, or third-party representatives, Wanfah Prosper PLT will conduct appropriate due diligence to assess their integrity and ensure they do not pose a corruption risk.

2.2 Financial Controls and Record-Keeping

  • All financial transactions, payments, and expenses must be accurately recorded with proper supporting documentation (invoices, receipts).

  • No “off-the-books” or secret accounts are permitted.

  • All claims for reimbursement (including business entertainment) must strictly follow standard internal approval channels.

2.3 Training and Awareness

  • Regular awareness briefings will be provided to all internal staff and associated trainers regarding this policy and MACC Section 17A compliance.

  • This policy will be made accessible to all external partners and published clearly where relevant.

SECTION 3: WHISTLEBLOWING POLICY AND PROCEDURE

3.1 Objective

The Whistleblowing Policy provides a secure, confidential channel for employees, trainers, clients, and stakeholders to report suspected bribery, corruption, financial malpractice, or unethical conduct within Wanfah Prosper PLT without fear of retaliation.

3.2 Protection for Whistleblowers

In line with the Whistleblower Protection Act 2010:

  • Confidentiality: The identity of the whistleblower and the details of the report will be kept strictly confidential.

  • Protection against Reprisal: Wanfah Prosper PLT guarantees that no whistleblower will suffer detrimental action, harassment, or victimization for making a report in good faith, even if the investigation subsequently finds no wrongdoing.

3.3 Reporting Procedure

If you become aware of any actual or suspected bribery, corruption, or misconduct, you should report it immediately through the following channels:

  • Via Email: cwtan@wanfahprosper.com

  • Via Mail / In Person: Mark “Strictly Confidential” and address to:

    The Designated Compliance Officer / Managing Partner

    Wanfah Prosper PLT

    No. 7A, Jalan Panglima Hitam M35/M, Alam Impian, 40470 Shah Alam, Selangor Darul Ehsan, Malaysia

3.4 Information to Include in the Report

To facilitate an effective investigation, the report should ideally include:

  • Brief details of the incident (What happened?).

  • Date, time, and location of the occurrence.

  • Identity of the individual(s) involved.

  • Any supporting evidence, documentation, or witnesses (if available).

SECTION 4: INVESTIGATION AND CONSEQUENCES

4.1 Investigation Process

  1. Upon receiving a report, the Designated Compliance Officer / Managing Partner will log the case and conduct an initial assessment.

  2. If credible, an independent internal investigation will be launched.

  3. The whistleblower may be contacted for further information, subject to strict confidentiality.

  4. Findings will be documented, and corrective actions will be determined by the management.

4.2 Non-Compliance and Penalties

  • For Internal Personnel: Any breach of this policy will be treated as serious misconduct and may result in disciplinary action, up to and including immediate termination of employment or partnership.

  • For External Parties/Trainers: Breach of this policy may lead to immediate termination of contract, blacklisting, and legal action.

  • Legal Consequences: If a criminal offense under the MACC Act is uncovered, the Company will promptly report the matter to the Malaysian Anti-Corruption Commission (MACC) and the Royal Malaysia Police (PDRM).

SECTION 5: POLICY REVIEW

This policy will be reviewed at least once every two years or following any changes to Malaysian anti-corruption legislation to ensure its continued effectiveness and relevance.