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