Anti-Bribery & Anti-Corruption Policy

  1. Policy Statement
    AFI Brake Manufacturing Sdn. Bhd. (“AFI Brake”) adopts a zero-tolerance policy towards all forms of bribery and corruption. We are fully committed to acting professionally, ethically, and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems to counter bribery and corruption. This policy is established in accordance with the Malaysian Anti-Corruption Commission Act 2009 (MACC Act 2009), including Section 17A on corporate liability, and other applicable anti-corruption laws and guidelines in Malaysia.
  1. Objectives
    • To prevent bribery and corruption in any form within AFI Brake and among our stakeholders.
    • To ensure compliance with applicable Malaysian laws and regulations.
    • To protect the company, its directors, employees, and business associates from the risks and consequences of corrupt practices.
    • To promote a culture of transparency, integrity, and accountability.
  1. Scope of Application
  2. This policy applies to:
    • All employees, including directors, managers, and executives of AFI Brake.
    • Third parties acting on behalf of or representing AFI Brake, such as agents, contractors, consultants, suppliers, and business partners.
    • Any transactions, activities, or interactions involving public officials, government agencies, or private entities.
  1. Definitions
    • Bribery: The offering, giving, receiving, or soliciting of something of value to influence a decision or gain an unfair advantage.
    • Corruption: The abuse of entrusted power for personal or organizational gain.
    • Gratification: As defined under the MACC Act, including money, donation, gift, loan, reward, or any benefit.
  1. Key Principles
  2. 5.1 No Bribery or Corrupt Practices
    • Employees and representatives are prohibited from offering, giving, soliciting, or accepting bribes in any form.
    • Facilitation payments and “kickbacks” are strictly prohibited.
    5.2 Corporate Liability (Section 17A, MACC Act)
    • AFI Brake may be held liable for corrupt acts committed by persons associated with the company unless it can prove that adequate procedures were in place to prevent such conduct.
    5.3 Adequate Procedures AFI Brake commits to implementing adequate procedures as outlined in the Guidelines on Adequate Procedures (GAP) issued pursuant to Section 17A(5) of the MACC Act. These include:
    • Top-Level Commitment: Senior management sets the tone from the top and fosters a culture of integrity.
    • Risk Assessment: Regular assessment of bribery risks and implementation of mitigating actions.
    • Undertake Control Measures: Development of procedures, training, and communication to manage risks.
    • Systematic Review and Monitoring: Regular audits and reviews of anti-bribery programmes.
    • Training and Communication: Ongoing education and awareness for employees and stakeholders.
  1. Gifts, Hospitality, and Donations
    • Gifts and entertainment must never be offered or accepted with the intent to influence a business decision.
    • Any gift or hospitality that could be perceived as a bribe must be declined.
    • Charitable donations and sponsorships must be transparent, properly recorded, and not used as a means to gain influence.
  1. Political Contributions
  2. AFI Brake does not make political contributions. Employees may engage in political activities in their personal capacity but must not represent the company or use company resources for such purposes.

  1. Third Party Due Diligence
    • Due diligence must be performed on all third parties before engagement.
    • Contracts must include anti-bribery and corruption clauses and allow termination if misconduct is identified.
  1. Whistleblowing and Reporting
  2. AFI Brake encourages all employees and third parties to report any suspected or actual bribery or corruption via the company’s Whistleblowing Channel. Reports will be treated confidentially and without retaliation. Reporting Channels:
    • Email: afm@afibrake.com
    • Phone: +609-666 8666
  1. Disciplinary Action
  2. Violations of this policy will lead to disciplinary action, including dismissal, and may result in legal prosecution under applicable anti-corruption laws.

  1. Review and Governance
  2. This policy shall be reviewed annually or as necessary to ensure continued effectiveness and compliance with current laws and best practices. The Board of Directors is responsible for overseeing the implementation and enforcement of this policy.
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