Anti-Bribery & Anti Corruption Framework and Policy ("ABAC")

Dagang NeXchange Berhad (“DNeX”) and its subsidiaries (collectively known as “DNeX Group or “Group”) is committed for the development and establishment of framework, policies and procedures guiding the conduct of our businesses with honesty, fairness and high ethical standards and not allowing certain types of behavior contrary to commercial integrity which would put the Group’s reputation at risk.

Thus, the Group has established the ABAC that defines the main guidelines for the detection and prevention of fraudulent behaviours. The Group prohibits any type of corruption and bribery such as promising, offering, giving or accepting any incentive or advantage of any nature, directly or indirectly, in order to influence any type of decision that may result in an undue benefit to the Group.

The objectives of the ABAC are:

• To ensure the policies and guidelines/ practices are oriented towards embedding ABAC stance organisation wide, with guidance from Guideline on Adequate Procedures and requirements of Malaysian Anti-Corruption Commission (“MACC”) Act 2009, introduced via Section 4 of the MACC (Amendment) Act 2018;
• To ensure adequate and standardised ABAC policies and guidelines are consistently applied throughout the Group by all staff; and
• To ensure that business operations within the Group are strictly adhering to the ABAC.

All Directors (executive and non-executive), employees and all vendors or agents, customers, business partners, public officials and others who are performing work or services, for and on behalf of DNeX Group shall comply with the rules and guidelines described in this framework and policy and must avoid any behaviour, situation or activity that would breach them.

The key features of the ABAC are:

The roles and responsibility of the Board and all level of employee are clearly outlined in the development of an ethical and high integrity culture within the Group, within which includes clear policies and lines of authority to adequately address corruption risk.

A corruption risk management assessment guided by ISO 37001:2016 Anti-Bribery Management System and GAP is conducted to assess and outline the governance, structure and policies, and integration of risk management into DNeX’s Group operations. Corruption risk assessment of all business unit within the Group have been conducted and a baseline risk profile have been built to capture the potential corruption schemes. Specific mitigation plans have been identified for continuous review and monitoring.

1. An integrated anti-bribery and anti-corruption plan is established to control such misconduct at a strategic, tactical and operational level. It outlines the actions that need to be taken to prevent, detect and response to potential threat. The plans will be reviewed on a regular basis to take into account any changes in the internal and/ or external environment. Amongst key control plans established are:
   • Gift and corporate hospitality
   • Entertainment
   • Corporate social responsibility
   • Donation and sponsorship
   • Facilitation and extortion payments
2. In order to guide decision making, the Group has also established guidelines for due diligence exercise in dealing with employees’ recruitment and external parties such as vendors/agents, customers, business partners and public officials.
3. Effective detection systems are also vital, as preventative methods may not always be successful. Hence internal reporting system and grievance processes is reviewed and enhanced for internal and external parties to raise concerns or report misconducts.

Responding effectively to suspected cases of fraud, corruption and other compliance breaches is critical. Guidelines have been established which involves a well conducted internal – and if necessary, external investigation to ascertain the facts. The information gained and lessons learned from each case will form part of an on-going review of fraud and corruption prevention controls, to ensure the Group’s reporting procedures on suspected bribery and corruption activities remains comprehensive and effective as possible.

Annual training and awareness programme on ABAC shall be provided to DNeX’s employees and key stakeholders. The ABAC with regards to its content as well as regulatory requirement affecting the ABAC practices will also be communicated to DNeX’s employees and key stakeholders on regular basis.