Infocrest — WatchGuard Malaysia Partner | Cybersecurity & Information Security Solutions
1.0 Introduction
Our Code sets out standards with which the management and employees of INFOCREST TECHNOLOGIES SDN BHD (“the Company” or “Infocrest”) are required to comply with when dealing with each other, suppliers, customers and other stakeholders. Our Code is not exhaustive, and Infocrest has developed or will develop specific detailed policies, procedures, directives and/or guidelines to support, promote or ensure compliance with our Code. Our Code is to be read and applied in conjunction with such policies, procedures, directives and guidelines. An employee must not, without prior consent of Infocrest place himself in a position in which there is a conflict between his duties and personal interest or, between those duties and any duties he owes to any other person.
2.0 Conflict of Interest
A conflict of interest arises when an employee’s personal activities or relationships interfere with his or her objectivity in doing what is best for the Company. Conflicts of interest, be it real, potential and even by appearance, can result in serious consequences for the employee and the Company. Conflicts of interest can occur in both direct and indirect situations. Employees of Infocrest is expected to diligently avoid such conflicts.
2.1 Financial Interest in Suppliers and Customer
An Employee shall not have any financial interest or own, either directly or indirectly in companies which:
- Supply material, equipment and/or service or have other business dealings with the Company
- Are customers of the Company
2.2 Family Interest
Taking part in any business decision involving a company that employs a spouse, relative or friend.
The definition of ‘relative’ according to the MACC Act 2009 is as follows:
- A spouse of the employee
- A brother or sister of the employee
- A brother or sister of the spouse of the employee
- A lineal ascendant or descendent of the person
- A lineal ascendant or descendent of the spouse of the person
- A lineal descendant of the person referred to in paragraph (ii)
- The uncle, aunt or cousin of the employee
- The son in-law or daughter in-law of the employee
3.0 Anti-Bribery & Corruption Policy
Any form of bribery and corruption is prohibited. All Employee must not provide, offer or accept bribes, kickbacks, corrupt payments, facilitation payments, or inappropriate gifts, to Government Officials or any commercial person or entity, regardless of local practices or customs. All Employee must comply with all applicable anti-bribery laws and regulations, including, but not limited to, the Malaysian Anti Corruption Commission Act (MACC Act).
The MACC Act covers the following conduct:
- the giving and accepting gratification;
- the giving or accepting gratification by an agent;
- corruptly procuring the withdrawal of a tender;
- bribery of an officer of a public body;
- bribery of foreign public officials;
- using an office or position for gratification; and
- dealing with, using, holding, receiving or concealing gratification or advantage in relation of any offence under the MACC Act.
The expression “gratification” under the MACC Act includes:
- money, donation, gift, loan, property, financial benefit or other similar advantage;
- any office, dignity, employment, contract of services;
- any payment, release or discharge of any loan, obligation or other liability;
- any discount, commission, rebate, bonus or percentage;
- any forbearance to demand any money or money’s worth or valuable thing;
- any favor of any description, including protection from any penalty or proceedings of a disciplinary or criminal nature or forbearance from the exercise of any right, power or duty; and
- any offer or promise of any gratification within the meaning of any of the preceding items
4.0 Confidentiality and Reporting
Infocrest encourage openness and will provide support to any individuals who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.
We are committed in ensuring that no individuals are subject to any form of detrimental treatment by virtue of their refusal to partake in corruption / bribery activities, any form of activities that may contravene against the law or because of concerns in reporting wrongdoings as prescribed in this Policy.
Thus, all reports made to Infocrest management pursuant to the Whistleblowing policy and procedure are kept confidential and we will not divulge any details and identities of the individuals who made such reports.
5.0 Monitoring and Review
All Employees and Third Parties are responsible for the success of this Policy and should ensure adherence to this Policy and use it to disclose any suspected wrongdoing. All internal control systems and procedures will be subject to periodic reviews and audits to ensure the continued effectiveness in preventing corrupt and bribery practices within Infocrest. We will also ensure continual improvement of the suitability, adequacy and effectiveness of this Policy from time to time. Any amendments to this Policy shall be approved by the Management.
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For any questions or further information, reach out to us at [email protected].