
Anti-Bribery and Corruption Policy -
Tentspark Sdn Bhd
1. Policy Statement and Commitment
Tentspark Sdn Bhd is committed to conducting business with the highest standards of integrity, transparency, and ethical behavior. We maintain a zero-tolerance approach to all forms of bribery and corruption, whether direct or indirect, and strictly comply with all applicable anti-bribery and corruption laws including the Malaysian Anti-Corruption Commission Act 2009
(MACC Act), particularly Section 17A on corporate liability.
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2. Scope and Application
This Policy applies to all Tentspark Sdn Bhd employees, officers, directors, consultants, contractors, agents, subsidiaries, joint ventures, and third-party representatives acting on behalf of Tentspark Sdn Bhd ("Covered Persons"). This includes all business activities worldwide, regardless of local customs or practices.
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3. Policy Objectives
This Anti-Bribery and Corruption Policy aims to:
• Establish clear responsibilities and obligations for all Covered Persons regarding anti-bribery and corruption compliance
• Provide comprehensive guidance on identifying, preventing, and addressing bribery and corruption risks
• Ensure compliance with all applicable laws and regulations
• Protect Tentspark Sdn Bhd's reputation and business interests
• Maintain stakeholder trust and confidence
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4. Prohibited Activities
Tentspark Sdn Bhd strictly prohibits the offering, giving, receiving, or soliciting of:
• Bribes and kickbacks - Any payment, gift, or benefit intended to improperly influence business decisions
• Facilitation payments - Payments to expedite routine government actions
• Improper gifts and hospitality - Anything of value that could reasonably influence
business decisions
• Political contributions - Made with intent to obtain improper business advantage
• Charitable contributions - When used as a disguise for bribery
• Business courtesies - That exceed reasonable and customary practicesWhat Constitutes "Anything of Value" This includes but is not limited to: cash, gifts, entertainment, travel, accommodation, employment opportunities, charitable donations, political contributions, business opportunities, and services.
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5. Third-Party Risk Management
All business relationships with third parties must undergo appropriate due diligence and ongoing monitoring. Third-party contracts must include anti-bribery and corruption clauses requiring compliance with this Policy.
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6. Gifts and Hospitality Guidelines
• All gifts and hospitality must be reasonable, appropriate, and transparent
• Must not create obligation or appearance of impropriety
• Must comply with Malaysian laws and recipient's policies
• Gifts over RM200 require pre-approval from management
• All business entertainment must have legitimate business purpose
• Under the MACC Act, gifts and hospitality can constitute corruption if there's intent for them to be a bribe
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7. Reporting and Whistleblower Protection
All Covered Persons have a duty to report suspected violations immediately.
Reporting Channels:
• MACC Complaint Hotline: 1800-88-6000 (toll-free)
• Company Ethics Hotline: (6012) 202 7725
• Online Portal: www.tentspark.com
• Email: [ethics@tentspark.com]
• Direct supervisor or designated compliance officer
Whistleblower Protection: Tentspark Sdn Bhd prohibits retaliation against anyone who reports suspected violations in good faith.
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8. Consequences of Non-Compliance
Violations of this Policy may result in:
• Disciplinary action up to and including termination
• Criminal prosecution and civil penalties
• Termination of business relationships• Reputational damage to Tentspark Sdn Bhd
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9. Training and Awareness
All Covered Persons must complete regular anti-bribery and corruption training. Additional
training may be required for high-risk roles or regions.
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10. Policy Governance and Management
• Director has overall responsibility for policy implementation and compliance
• Designated Compliance Officer (if appointed) or senior management oversees day-to-day compliance activities
• All employees have responsibility for compliance and reporting
• Annual policy review and updates
• Regular risk assessments and monitoring
• Senior management oversight and reporting to board/shareholders as required
Corporate Liability Under Section 17A MACC Act 2009
Under Section 17A of the MACC Act 2009