NO FACILITATION PAYMENT POLICY AND PROCEDURES

1. OBJECTIVES

   1. The objective of this Policy is to provide awareness and guidance for PPB Group’s¹ Personnel²and its Business Associates³ on PPB Group’s No Facilitation Payment Policy and Procedures.
   2. This guidance is applicable to PPB Group’s Personnel and its Business Associates in all business dealings, and in particular, who have business dealings with countries that have high exposure to risk of corruption, regardless of whether they are working/ operating in Malaysia or overseas.

2. WHAT IS A FACILITATION PAYMENT?

   1. Facilitation Payment is a payment or other provision made to an individual in control of a process or decision, to secure or expedite a routine or administrative duty or function. Facilitation Payments may be requested by authorities, e.g. for the issuance of a visa, work permit or customs clearance. It may also occur in the private sector, e.g. an employee holding up processing an invoice until a payment has been received.
   2. Facilitation Payments are classified as acts of bribery and corruption under the Malaysian Anti-Corruption Commission Act 2009 and are illegal in most jurisdictions. Therefore, PPB Group prohibits the soliciting (asking), receiving, giving, offering, or promising of Facilitation Payments , whether in cash or in kind, by both Personnel and Business Associates who are acting for and on behalf of the Group.
   3. In the event employee receives a request or demand for Facilitation Payment; or is offered or promised a Facilitation Payment during a business transaction, he/ she must politely and firmly refuse such request/ demand/ offer/ promise. Employee must immediately, or as soon as practicable, report such request to the Head of Department (“HOD”), and thereafter to the Risk/ Integrity Officer, or Head of Risk/ integrity, or the PPB Group Berhad’s Risk Management & Integrity Department (“PPBHQ RMID”) . For directors, they are to report to the Company Secretary.
      
      Please refer to Appendix A for the information required when reporting of Facilitation Payment, and Appendix B and the reporting process flow for employees.
   4. It is PPB Group’s policy that its Personnel or Business Associate are not permitted to claim any Facilitation Payments made, as expense claims.

3. EXCEPTION UNDER THE FACILITATION PAYMENT PROCEDURE

   PPB Group is committed to providing a safe environment for all its Personnel. However, it is important to note that there may be circumstances in which individuals are left with no alternative but to make payments. Payments may be made where individuals fear for their health, safety, or liberty. In such cases where payment is unavoidable, the full details should be reported (when it is safe to do so) to the HOD and Risk/ Integrity Officer, or Head of Risk/ integrity, or the PPBHQ RMID.

4. HOW SHOULD PERSONNEL DEAL WITH REQUEST(S) FOR FACILITATION PAYMENTS

   The 4Rs approach to resisting facilitation payments stresses the importance of knowing how to plan in advance to avoid these situations and how to deal with them when they arise. The 4Rs:

   • Research
   • Resist
   • Record
   • Report
   1. RESEARCH in advance of your travel:
   1. Find out about any local anti‐bribery and corruption initiatives.
   2. Official payment requirements, authorisations or permits may be required. If possible, obtain official written confirmation that all documents are in order.
   3. Risk assessment – identify the likelihood that you will be asked to make a facilitation payment, the type of payment, and response. If necessary, enter into an agreement with those whom you are working with so that they are aware of the Group’s zero-tolerance approach to bribery and corruption, including on facilitation payments.
   4. Build in the necessary time required to get through the administrative formalities in advance of your travel.
   5. You may also seek assistance from a person familiar with the local context, procedures, and process.
   2. RESIST if it feels safe to do so:
   1. Question the legitimacy of the request.
   2. Explain that you have confirmation that your papers are in order from the relevant authorities.
   3. Explain that facilitation payments are against Group policy and Malaysian law (or the relevant local law where applicable).
   4. Even if after resisting the payment, the payment still appears unavoidable, try asking to make a payment through an office or with a receipt. This can be a useful tactic to avoid making facilitation payments.
   3. RECORD and keep full and accurate records of:
   1. All payments that have been requested.
   2. If possible (and safe to do so), discreetly record the details of the individual requesting the payment and any other details.
   4. REPORT immediately, or as soon as practicable:
   1. Report the request to your manager or HOD.
   2. Explain what happened with as much details as possible.
   3. Thereafter, all suspected incidents of bribery and/or corruption must be reported to the HOD and Risk/ Integrity Officer, or Head of Risk/ integrity, or the PPBHQ RMID.

5. REPORTING PROCEDURE FOR BUSINESS ASSOCIATES

   The Group encourages all Business Associates to report any concerns or possible violations of the Group’s ABAC policies and procedures. In the event Business Associates are asked by the Group’s Personnel to make facilitation payments, they are to immediately lodge their report, in good faith, to PPB Group via the whistleblowing channels. For more information on the Group’s whistleblowing policy and procedures, please refer to the Whistleblowing Policy and Procedures as published on each entities website.


Appendix A: Information Required for Reporting to the Risk/ Integrity Officer, or Head of Risk/ Integrity, or PPBHQ RMID

Appendix B: Reporting of Facilitation Payment Process Flowchart for Employees



Footnote

1. PPB Group refers to PPB Group Berhad and its subsidiaries.

2. Includes directors and employees.

3. For purposes of this Policy and Procedures, the term “Business Associates” includes, but not limited to, suppliers, vendors, contractors, agents, service providers, consultants, advisers, distributors, joint venture, or partners consortia parties, and any other third party acting for or on behalf of PPB Group.