Anti-Bribery & Anti-Corruption (ABC) Policy Statement

As part of our commitment to good governance, UNO.com.my Sdn. Bhd. (“the Company”) upholds the highest standards of ethics and integrity in all business and operational activities. The Company maintains a zero-tolerance policy against bribery and corruption in any form, whether committed by Directors, Management, employees, or any individuals or organizations acting on its behalf. We take a strong stance against such practices and expect all stakeholders to adhere strictly to ethical business conduct.

Purpose of this Policy Statement

This policy statement aims to:

• Define the Company’s responsibilities, as well as those of its employees and service providers, in adhering to our anti-bribery and corruption stance.
• Provide guidance on ethical business conduct and equip individuals with the knowledge to identify and address bribery and corruption risks.
• Establish clear procedures for raising concerns, including reporting any breaches of this policy.

Definitions

• Bribery refers to any act that constitutes an offence under the Malaysian Anti-Corruption Commission (MACC) Act, including offering, giving, receiving, or soliciting something of value to improperly influence a decision or action within an organization.
• Corruption includes bribery and extends to extortion, collusion, breach of trust, abuse of power, undue influence, embezzlement, fraud, or money laundering.

Anti-Bribery and Corruption Program

In line with its commitment, the Board of Directors and Management have implemented a comprehensive Anti-Bribery and Corruption (ABC) Policy, which aims to:

• Prevent, detect, and monitor bribery and corruption in all aspects of the Company’s business.
• Guide Directors, Management, employees, and external parties on how to handle unethical solicitations, bribery risks, and other corrupt activities.
• Manage key bribery and corruption risks effectively.
• Ensure full compliance with all applicable laws and regulations related to anti-bribery and corruption.

Prohibited Activities

The Board of Directors, Management, employees, and any individual or organization acting for or on behalf of the Company are strictly prohibited from directly or indirectly soliciting, accepting, or offering bribes in any form related to the Company’s business and operations.

Expectations for Business Partners and Third Parties

The Company expects all individuals and organizations acting on its behalf to:

• Be aware of and fully comply with the ABC Policy, Whistleblowing Policy, and Vendor Code of Conduct.
• Commit to ethical business practices when providing services or conducting transactions for the Company.
• Undergo due diligence assessments before entering into any formal agreements, ensuring they do not have a history of corrupt practices. The Company will not engage in business dealings with individuals or entities under suspicion unless concerns are thoroughly investigated and resolved.
• Ensure that any subcontractors involved in fulfilling Company contracts also adhere to the ABC Policy, Whistleblowing Policy, and Vendor Code of Conduct.

Failure to comply with these policies may result in penalties, including contract termination, and, if necessary, legal action if the Company’s interests have been compromised.

(Last updated: 2nd Jan 2025)