Anti-Corruption & Bribery Policy

This policy establishes Malaysia Transformer Manufacturing Sdn. Bhd. standards regarding the prevention of bribery and fraud, and to establish key pillars in its structure to protect the company against the impact of bribery.

Policy Statement

Bribery in all its forms related to MTM's activities is prohibited. It is the responsibility of Personnel at all levels to act with integrity. MTM holds a ‘No Gifts’ policy, although certain exceptions are allowed. Integrity Pledges shall be signed by Personnel on a regular basis, as well as a Conflict of Interest declaration.

Business Associates acting on behalf of the company must be managed carefully. Reporting of misconduct by Personnel or third parties is expected, with protection provided for all disclosers acting in good faith. The company is committed to enforcing its position, with the Compliance Management Unit (CMU) taking on this role. The Anti-Bribery Management System (ABMS) shall be assessed and updated on a regular basis to ensure its effectiveness is maintained.

Conflicts of Interest Policy

This policy establishes Malaysia Transformer Manufacturing Sdn. Bhd. (MTM) standards regarding the relevant principles and rules for preventing or managing conflicts of interest, and how such principles and rules are to be implemented.

Policy Statement

It is the policy of MTM that the disclosure and management of Conflicts of Interest is the responsibility of its Personnel at all levels. All potential, perceived, and actual conflicts are to be declared in a timely manner and managed using the mechanisms provided by the company.

Primary responsibility for managing the declaration lies with the person's own Manager, with support provided by the Human Resources (HR) Department and the Compliance Management Unit (CMU). Sanctions for non-compliance can be severe, depending on the nature of the declared conflict and its impact on the company.

Whistleblowing Policy

Malaysia Transformer Manufacturing Sdn. Bhd. (MTM) seeks to deter and detect misconduct and to ensure that genuine concerns about bribery, fraud, illegal, and unethical practice which an individual (whistleblower) believes may be taking place are raised at an early stage in a responsible and confidential manner. It also ensures the protection of the whistleblower.

Policy Statement

MTM expects Personnel at all levels to report concerns they may have on any behaviour they observe in relation to the company’s activities via the channels established for this purpose. External parties encountering misconduct as they work with MTM Personnel are likewise expected to report their concerns through the designated channels. Protection will be provided to all parties acting in good faith.

Gifts, Hospitality, Donation and Related Benefits Policy

This policy establishes Malaysia Transformer Manufacturing Sdn. Bhd. (MTM) guidelines and actionable steps for stakeholders to manage challenges regarding gifts, hospitality, and related matters such as political donations, charitable donations, and sponsorships. Expectations of external parties are also stated.

Policy Statement

MTM holds a ‘No Gifts’ policy. However, there are some exceptions allowed, provided no Conflict of Interest arises and decision-making behaviour is not influenced. Likewise, normal business hospitality is permitted but shall not be so frequent or extravagant that a sense of obligation is created on the side of the receiver.

Festive hampers are discouraged and are to be refused wherever possible. Discounts for staff by External Providers shall be provided transparently as part of a general agreement between the Provider and MTM. Facilitation payments shall not be made.

Charitable donations and sponsorships shall be made transparently and for the general well-being of the company and the communities it serves. Political contributions are prohibited.