Anti Corruption & Bribery Policy


The Board of Directors of Tong Herr Resources Berhad (“THR” or “the Company”), including its subsidiaries (“the Group”), has established and adopted the following Anti Corruption and Bribery Policy. THR is committed to conduct its business ethically and govern appropriately in the prevention of corruption, as well as complying with all applicable laws, which include compliance with the Malaysian Anti Corruption Commission Act 2009 (“MACCA”) and the Malaysian Anti Corruption Commission (Amendment) Act 2018 and any of its amendments or reenactments that may be made by the relevant authority from time to time.


In line with MACCA, the Company has developed and implemented a comprehensive set of measures to combat bribery and corruption of all forms related to the Group’s operations.

Under the MACCA, “gratification” or what most people call “bribery” is defined as money, donation gift, loan, fee, reward or any valuable thing of any kind, any forbearance to demand any money or money’s worth or valuable thing, any other service or favour of any kind, or any offer, undertaking or promise of any such gratifications.

Corruption is the act of giving or receiving of any gratification or reward in the form of cash or in kind of high value for performing a task in relation to his/her job description. Corruption means the abuse of entrusted power for personal gain. However, corruption has a broader definition than bribery. This Guide therefore refers to “bribery and corruption” as a standard term to cover all types of gratification.


The objective of this Policy is to provide information and guidance to the Directors and Employees of the Company on standards of behaviour to which they must adhere to and how to deal with bribery and corruption issues, as well as set out our responsibilities to comply with the law.


All Directors and Employees of the Group

The Policy is applicable to all Directors and Employees of the Group. Each Employee has a duty to read and understand the Policy. Violation of any of the Policy’s provisions may result in disciplinary action, including termination of employment. Every Head of Departments (“HODs”) or Head of Business Units (“Managers“) are responsible to communicate and ensure compliance to this policy within their respective department.

The Company’s Business Associates

This policy applies to the Company’s business associates, which includes customers, suppliers, contractors, consultants, agents, representatives, outsourcing providers, tenants and other intermediaries who are performing work or services, for and on behalf of the Group. All Personnel, regardless of their position or role, are responsible to communicate this policy to their business associates.

All Parties Engaging with the Company

This policy applies to all parties that are currently engaged with Tong Herr Resources Berhad and its subsidiaries or have intentions to engage with the Company or its subsidiaries in the future.

Guidance on Common Forms of Bribery and Corruption


Employees are disallowed to receive gifts from, or send gifts to any third party (including suppliers, customers, business partners, potential employees, and potential suppliers, etc).

However, the above policies may be exempted in certain circumstances, subject to approval by the General Manager, with the following regulations must be met:

  • is for legitimate business purposes, such as building goodwill and strengthening working relationships;
  • does not occur during contract negotiations or during business proposal pending;
  • such as cards, thank you letters, certificates or other written forms of thanks and recognitions;
  • is given to the company and should state the name of the company but not the name of any employee; and
  • these gifts are offered during the holiday season (New Year, Lunar New Year, Hari Raya and Deepavali, etc.).

Benefits and Entertainment

Business entertainment can play an important role in strengthening the working relationship between business partners. As a result, employees can accept or provide commercial entertainment for legitimate business purposes, such as establishing goodwill and strengthening relationships with customers or suppliers, provided that the nature of entertainment is consistent with this policy. Specifically, subject to approval by the General Manager, entertainment is allowed or accepted only in such circumstances:

  • relevant to legitimate business purposes (for example, accompanying a customer or supplier to an event or attending a business meal);
  • is not given as a bribe, payoff, or kickback (e.g., to obtain or retain business);
  • does not mean that the gift giver is entitled to special treatment, commercial rewards, more favorable prices or better sales terms;
  • is reasonable and appropriate in the context of business occasion; and
  • would not influence, or appear to influence the employee’s ability to act in the best interest of the Group.

Charitable Contribution

Charitable support and donations in kind of services or financial contributions are acceptable subject to approval by the General Manager. However, Directors and Employees must ensure that the charitable contributions are not used as a scheme to conceal bribery. No donation can be offered or made without the prior approval of the General Manager.

In short, we encourage the use of good judgement when giving or accepting the Gifts, Benefits and Entertainment. All the benefits must be reasonable, transparent and open, infrequent, and not given for to obtain other purpose.

Awards and Allowances

Raffle gifts, door gifts, rewards and other business/sales rewards can be offered to employees provided it is in legitimate form/ event and not biased, subject to approval by the General Manager. Any incentives given must comply with applicable pay, benefits and tax laws.


Any violation of this Anti Corruption and Bribery Policy may result in disciplinary action, including but not limited to, termination of employment.


The Group shall keep all financial records and have appropriate internal controls in place which will evidence, substantiate and justify that business reason for making payments to, and receiving payments from, third parties.

The Group shall also ensure all expenses claims relating to gifts or entertainment made to third parties are submitted in accordance with the Group’s reimbursement procedures and/or applicable policy and specifically record the reason for such expenditure. All the parties shall further ensure that all expense claims shall comply with the terms and conditions of this Policy.

All of the documents, accounts and records which are related to deal with third parties, such as customers, suppliers and business contracts, should be prepared and maintained with strict accuracy and completeness. No accounts should be kept “off-book” to facilitate or conceal improper payments.