Legal
Anti-Corruption Policy.
We win work on merit. We do not offer, pay, request or accept bribes, in any form, anywhere.
01 Our position
Sentient Concepts has zero tolerance for bribery and corruption. We comply with the Malaysian Anti-Corruption Commission Act 2009, including the corporate liability provisions of Section 17A, and with anti-corruption laws in every country where we operate.
02 Who this applies to
This policy applies to our directors, employees and contractors, and to anyone acting on our behalf, including agents, consultants and partners.
03 What is prohibited
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Offering, promising, giving, requesting or accepting anything of value to improperly influence a decision
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Facilitation payments, however small, to speed up routine government action
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Using third parties, family members or intermediaries to do any of the above
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Concealing or misrecording any payment or transaction
“Anything of value” includes cash, gifts, hospitality, travel, employment offers, donations and favors.
04 Gifts and hospitality
Modest gifts and hospitality can be part of normal business. They must be reasonable in value, given openly, recorded, and never offered or accepted where they could influence, or appear to influence, a decision. Nothing is offered to or accepted from any party during a tender or procurement process.
05 Working with third parties
We carry out due diligence proportionate to risk before engaging agents, partners and suppliers, and expect them to uphold standards equivalent to ours. We will end relationships where these standards are not met.
06 Conflicts of interest
Personal interests that could conflict with the company’s must be declared and managed before any related decision is made.
07 Political contributions
We do not make political contributions on behalf of the company.
08 Accurate records
All transactions are recorded completely and accurately. Off-book accounts are prohibited.
09 Raising a concern
Anyone, inside or outside the company, can report a suspected breach of this policy in confidence by writing to dpo@sentientconcepts.com. Reports are treated seriously and investigated promptly.
We do not tolerate retaliation against anyone who raises a concern in good faith.
10 Consequences
Breaches of this policy will lead to disciplinary action, up to and including dismissal or termination of contract, and may be reported to the relevant authorities.