ANTI-BRIBERY & ANTI- CORRUPTION POLICY

1. Purpose

Abayu Ignitra Sdn. Bhd. (“the Company”) is committed to conducting business with integrity, transparency, and accountability. This policy sets out the Company’s stance against all forms of bribery and corruption and outlines the responsibilities of employees and associated persons in preventing such practices.

2. Scope

This policy applies to:

• All directors, employees, and management of the Company

• Contractors, consultants, agents, and business partners acting on behalf of the Company

3. Policy Statement

The Company adopts a zero-tolerance approach to bribery and corruption. All forms of bribery are strictly prohibited, whether direct or indirect, and regardless of the amount or benefit involved.

The Company complies with all applicable laws and regulations, including the Malaysian Anti-Corruption Commission Act 2009 (MACC Act).

4. Definition of Bribery and Corruption

Bribery refers to offering, promising, giving, accepting, or soliciting any undue advantage to influence a decision or gain an improper business advantage.

Corruption includes abuse of entrusted power for personal gain.

5. Prohibited Conduct

Employees and associated persons must NOT:

• Offer or accept bribes in any form (cash, gifts, services, favors, etc.)

• Facilitate or engage in kickbacks or secret commissions

• Make facilitation payments to expedite routine processes

• Use third parties to carry out bribery on behalf of the Company

6. Gifts, Hospitality, and Entertainment

• Modest and reasonable gifts or hospitality may be allowed if they are:

  • Not intended to influence business decisions

  • In line with customary business practices

  • Transparent and properly recorded

• Any gift or hospitality exceeding acceptable thresholds must be declared and approved by management

7. Conflict of Interest

Employees must avoid situations where personal interests conflict with the Company’s interests. Any actual or potential conflict must be disclosed promptly.

8. Donations and Sponsorships

All donations and sponsorships must:

• Be transparent and properly documented

• Not be used as a means to gain improper advantage

• Receive prior approval from management

Political contributions are strictly prohibited unless explicitly approved by the Board and compliant with applicable laws.

9. Record Keeping

The Company shall maintain accurate and complete financial records. False, misleading, or incomplete records are strictly prohibited.

10. Reporting Violations (Whistleblowing)

Employees and stakeholders are encouraged to report any suspected bribery or corruption.

Reports can be made confidentially to:

• Management, or

• A designated compliance officer (if applicable)

The Company prohibits retaliation against individuals who report concerns in good faith.

11. Training and Awareness

The Company will provide training and guidance to employees to ensure understanding and compliance with this policy.

12. Enforcement and Disciplinary Action

Any breach of this policy may result in:

• Disciplinary action, including termination of employment

• Legal action, where applicable

13. Responsibilities

• Management: Ensure implementation and enforcement of this policy

• Employees: Comply with this policy and report any concerns

14. Review of Policy

This policy shall be reviewed periodically to ensure its effectiveness and relevance.