1. Purpose and Commitment

Corporate FinEdge Management Services and, where relevant, its related corporations, affiliated businesses, associated firms, representatives and service providers involved in carrying on business with or for Corporate FinEdge Malaysia (collectively, “Corporate FinEdge Malaysia”, “we”, “us” or “our”) are committed to conducting business ethically, lawfully, professionally and with integrity.

Corporate FinEdge Malaysia adopts a zero-tolerance approach to bribery and corruption in all forms. We do not tolerate any act of bribery, corruption, kickback, facilitation payment, improper inducement or abuse of position for personal, business or commercial advantage.

This Policy is adopted as part of Corporate FinEdge Malaysia’s governance and compliance framework and is intended to support compliance with all applicable anti-bribery and anti-corruption laws, including the Malaysian Anti-Corruption Commission Act 2009, including Section 17A on corporate liability, and any applicable guidelines, directives or standards relating to adequate procedures.

2. Scope of Policy

This Policy applies to all directors, partners, principals, employees, secondees, interns, temporary staff, consultants, agents, intermediaries, referral parties, representatives, contractors, suppliers, vendors and any other persons associated with Corporate FinEdge Malaysia or acting on its behalf.

All such persons are required to comply with this Policy when acting for or in connection with Corporate FinEdge Malaysia, regardless of location or business function.

3. Policy Statement

Corporate FinEdge Malaysia prohibits:

• offering, promising, giving, soliciting or receiving any bribe or corrupt gratification;
• providing or accepting anything of value in order to improperly influence a decision, action or outcome;
• using third parties, agents, consultants, intermediaries or other associated persons to do anything that Corporate FinEdge Malaysia is not permitted to do directly;
• giving or receiving kickbacks, secret commissions, improper rebates or hidden benefits;
• making facilitation payments, even if small or customary, unless there is an imminent threat to health, safety or liberty;
• falsifying books, records, invoices, expense claims or supporting documents in order to conceal improper conduct; and
• retaliating against any person who raises a concern or reports suspected misconduct in good faith.
  
  

4. Definitions

For the purposes of this Policy:

“Bribery” includes offering, promising, giving, requesting or receiving any gratification or advantage as an inducement or reward for acting improperly.

“Corruption” includes the abuse of entrusted power, position or influence for private, personal or business benefit.

“Facilitation payment” means an unofficial or improper payment made to secure or expedite a routine action or administrative process.

“Associated person” includes any person who performs services for or on behalf of Corporate FinEdge Malaysia.

“Anything of value” may include cash, gifts, vouchers, travel, entertainment, discounts, commissions, fees, favours, donations, sponsorships, employment opportunities, referral benefits or any other direct or indirect benefit.

5. Gifts, Entertainment and Hospitality

Corporate FinEdge Malaysia recognises that reasonable and proportionate business hospitality may be acceptable in limited circumstances. However, gifts, entertainment and hospitality must never be used to improperly influence a decision or create the appearance of impropriety.

Any gift, entertainment or hospitality given or received must:

• be lawful, reasonable, infrequent and proportionate;
• be for a legitimate business purpose;
• not be in cash or cash equivalent form;
• not be offered, given, requested or accepted during a tender, approval, licensing, enforcement, procurement or sensitive decision-making process;
• not place the recipient under any obligation or create an appearance of improper influence; and
• be capable of withstanding internal and external scrutiny.
  
  

Corporate FinEdge Malaysia may impose internal approval, declaration, recording or threshold requirements for gifts, entertainment and hospitality. If there is any doubt, the item must not be offered or accepted without prior approval from management.

6. Facilitation Payments

Corporate FinEdge Malaysia prohibits facilitation payments.

If any person is pressured to make a payment in circumstances involving an immediate threat to health, safety or liberty, that person should, where possible, prioritise safety, make a record of the incident and report the matter to management as soon as practicable.

7. Donations, Sponsorships and Charitable Contributions

Donations, sponsorships and charitable contributions must not be used as a substitute for bribery or as a means to obtain an improper business advantage.

Any such payment or contribution made in the name of or connected with Corporate FinEdge Malaysia must:

• be lawful and transparent;
• serve a legitimate purpose;
• be properly documented and approved in advance; and
• not be linked to any actual or anticipated business decision, award, licence, regulatory outcome or improper influence.
  
  

Political contributions shall not be made in the name of Corporate FinEdge Malaysia unless specifically approved in accordance with applicable law and internal governance requirements.

8. Dealing with Public Officials and Counterparties

Extra caution must be exercised when dealing with public officials, government-linked entities, regulators, statutory bodies, immigration-related parties, licensing authorities, tax authorities, customs authorities, enforcement personnel and politically exposed persons.

No person may offer, give, promise or authorise any payment, gift, hospitality or other benefit to a public official or related person for the purpose of obtaining or retaining business, securing an advantage, expediting an official act, influencing discretion or avoiding a disadvantage.

The same standard of integrity applies when dealing with private sector clients, referral sources, agents, intermediaries, business partners and vendors.

9. Third Parties and Associated Persons

Corporate FinEdge Malaysia may be exposed to risk through the actions of third parties or associated persons acting on its behalf. Accordingly, appropriate due diligence should be undertaken, where relevant and proportionate, before appointing or continuing to engage agents, intermediaries, consultants, introducers, referral parties, contractors or other higher-risk business partners.

Red flags may include unusual commissions, vague scopes of work, requests for cash payments, payments to unrelated parties, lack of qualifications, refusal to agree to compliance terms, close connections with public officials or unusual urgency.

Corporate FinEdge Malaysia reserves the right to impose contractual anti-bribery obligations, request supporting information, require declarations or terminate dealings where bribery or corruption risk is identified.

10. Books, Records and Internal Controls

All books, records, invoices, claims, approvals, receipts and supporting documents must be complete, accurate, honest and fairly reflect the underlying transaction.

No undisclosed, unrecorded, off-book, false or misleading account, fund, payment or arrangement may be established or maintained.

Expense claims, reimbursements, commissions, referral payments, gifts, hospitality and third-party payments must be properly supported and approved in accordance with internal controls.

11. Reporting and Whistleblowing

Any person covered by this Policy who knows of, suspects, witnesses or is asked to participate in conduct that may breach this Policy or any applicable anti-bribery law must report the matter promptly.

Reports may be made to management, the designated compliance contact or any reporting channel established by Corporate FinEdge Malaysia.

Reports should be made as soon as practicable and with sufficient detail to enable review. Corporate FinEdge Malaysia will treat such reports seriously and, where appropriate, confidentially, subject to legal, investigative and operational requirements.

12. Non-Retaliation

Corporate FinEdge Malaysia prohibits retaliation against any person who makes a report, raises a concern, declines to participate in suspected bribery or corruption, or assists in an investigation in good faith.

Any retaliation, victimisation or adverse treatment for good-faith reporting is itself a serious breach of this Policy.

13. Investigation and Disciplinary Action

Corporate FinEdge Malaysia may investigate any suspected or actual breach of this Policy.

Any breach may result in disciplinary action, suspension, termination of employment or engagement, withdrawal from a transaction, reporting to the relevant authorities, legal action, or any other appropriate remedial step, subject to applicable law and internal procedures.

14. Training, Communication and Review

Corporate FinEdge Malaysia may provide periodic communication, training, declarations, reminders or compliance measures to support awareness and implementation of this Policy.

This Policy may be reviewed and updated from time to time to reflect changes in law, business operations, risk profile or governance expectations.

15. Responsibility for Compliance

All persons covered by this Policy are responsible for understanding and complying with it.

Management is responsible for promoting a culture of integrity, ensuring appropriate oversight and supporting the implementation of proportionate anti-bribery controls.

No person will be excused from compliance on the basis that bribery is customary, expected, commercially expedient or requested by another party.

16. Contact and Reporting Details

Questions, declarations or reports relating to this Policy may be directed to:

Corporate FinEdge Management Services

No. 15-02, Jalan Molek 1/42,

Taman Molek, 81100 Johor Bahru, Johor, Malaysia

Tel: +60 10-711 5229

Email: cliff.goh@corporatefinedge.com

17. Website Publication Version

This version may be adopted for publication on the Corporate FinEdge Malaysia website as a public-facing Anti-Bribery and Anti-Corruption Policy.

Corporate FinEdge Malaysia may also maintain internal procedures, approval matrices, reporting processes, due diligence checklists, disciplinary protocols and training records separate from this published version.

18. Bahasa Malaysia Version

If this Policy is made available in both English and Bahasa Malaysia, both versions are intended to assist understanding. In the event of inconsistency, the version adopted by Corporate FinEdge Malaysia for compliance purposes shall prevail to the extent required by applicable law.

Last updated: 30 April 2026