1. INTRODUCTION & PURPOSE

This Policy establishes Evyap Sabun Malaysia Sdn. Bhd.’s (“Evyap” or “the Company”) commitment to preventing, detecting, and addressing corruption and bribery in all business activities.

It is designed to :

  • • Ensure compliance with applicable laws including the Malaysian Anti-Corruption Commission Act 2009 (Section 17A)
  • • Align with international standards including ISO 37001 and Sedex SMETA requirements.
  • • Embed a culture of integrity consistent with Evyap Group’s Code of Ethics Procedure
  • • Protect the Company from legal, financial, and reputational risk.


2. POLICY STATEMENT

Evyap adopts a zero-tolerance approach towards all forms of corruption and bribery.

The Company strictly prohibits :

  • • Any form of bribery (direct or indirect)
  • • Abuse of position for personal or business gain
  • • Improper influence over business decisions

All Employees and Associated Persons must :

  • • Act with integrity, transparency, and accountability
  • • Comply with all applicable anti-corruption laws
  • • Avoid any situation that may create actual or perceived improper advantage.


3. LEGAL & STANDARD FRAMEWORK

This Policy is aligned with :

  • • Malaysian Anti-Corruption Commission Act 2009 (Section 17A – Corporate Liability)
  • • MACC Guidelines on Adequate Procedures (T.R.U.S.T Principles)
  • • ISO 37001: Anti-Bribery Management Systems
  • • Sedex SMETA Ethical Trade Requirements
  • • ILO Conventions on ethical business conduct
  • • Applicable local and international laws

Where stricter requirements apply, the stricter standard shall prevail.
 

4. SCOPE & APPLICABILITY

This Policy applies to :

4.1. Internal

  • • Directors / Management
  • • All employees (permanent, contract, temporary, trainees)

4.2. External (Associated Persons)

  • • Suppliers, contractors, vendors
  • • Agents, consultants, intermediaries
  • • Joint venture partners
  • • Any party acting on behalf of Evyap

Applies across all jurisdictions where Evyap operates
 

5. KEY DEFINITIONS

5.1. Corruption - Abuse of entrusted power for private or business gain.

5.2. Bribery - Offering, giving, receiving, or soliciting anything of value to improperly influence a decision

5.3. Gratification - Includes (non-exhaustive) :

  • • Money, gifts, commissions, discounts
  • • Employment or contracts
  • • Travel, hospitality, entertainment
  • • Any advantage or benefit

5.4. Facilitation Payment - Unofficial payments made to expedite routine government actions (strictly prohibited).


6. GOVERNANCE & RESPONSIBILITIES

6.1. Board of Directors

  • • Provide oversight and tone-at-the-top
  • • Ensure anti-corruption framework effectiveness

6.2. Management

  • • Implement and enforce this Policy
  • • Ensure risk-based controls are in place

6.3. Human Resources

  • • Training, awareness, disciplinary enforcement
  • • Integration into performance management

6.4. Compliance / Ethics Committee

  • • Investigate violations
  • • Monitor policy effectiveness
  • • Report to HQ and leadership

6.5. All Employees

  • • Comply with Policy
  • • Report violations
  • • Avoid conflicts of interest


7. PROHIBITED CONDUCT

Strictly prohibited :

  • • Bribery in any form (direct or indirect)
  • • Facilitation payments
  • • Kickbacks or secret commissions
  • • Use of third parties to bypass laws
  • • Falsification of records or accounts
  • • Abuse of authority


8. GIFTS, HOSPITALITY & BUSINESS COURTESIES

Evyap discourages the offering or acceptance of gifts, hospitality, entertainment, or other business courtesies where such actions may influence, or be perceived to influence, business decisions, transactions, or relationships.

Gifts and hospitality may only be permitted where they are reasonable, proportionate, and made in good faith for a legitimate business purpose. Such courtesies must not be in the form of cash or cash equivalents, must not create any actual or perceived conflict of interest, and must be conducted transparently and properly recorded. Under no circumstances shall gifts or hospitality be offered or accepted during tender processes, contract negotiations, or decision-making periods.

The following are strictly prohibited :

  • • Gifts, hospitality, or benefits intended to obtain or retain business advantage
  • • Excessive, lavish, or inappropriate entertainment
  • • Undisclosed, concealed, or misleading benefits

As a general control, the value of gifts shall not exceed USD 50 per person per calendar year, in line with Group standards. Any exception to this threshold must be justified, documented, and formally approved by Management.

Local guidelines may be issued to reflect cultural practices, provided they remain consistent with this Policy and do not compromise integrity standards.


9. SPONSORSHIP, DONATIONS AND CORPORATE SOCIAL RESPONSIBILITY (CSR)

Evyap supports sponsorships and donations that contribute to social, environmental, educational, and community development initiatives. All such contributions must be lawful, transparent, and aligned with the Company’s values and ethical standards.

Sponsorships and donations shall only be permitted where there is no expectation of business advantage, and where appropriate due diligence has been conducted to assess the legitimacy and integrity of the recipient. All transactions must be properly documented, approved, and recorded in accordance with internal controls.

The following are strictly prohibited :

  • • Political donations, unless expressly approved by the Board and permitted by law
  • • Donations or sponsorships linked, directly or indirectly, to business decisions or contractual arrangements


10. THIRD-PARTY RISK MANAGEMENT

Evyap recognises that corruption risks may arise through third-party relationships and is committed to ensuring that all Associated Persons uphold equivalent standards of integrity.

A risk-based approach shall be applied in the selection, engagement, and monitoring of third parties. Prior to engagement, appropriate due diligence must be conducted to assess the integrity, reputation, and compliance profile of suppliers, contractors, agents, and business partners.

At a minimum, Evyap shall ensure :

  • • Due diligence is performed proportionate to the risk level
  • • Contractual safeguards are in place, including anti-bribery clauses, audit rights, and termination provisions
  • • Ongoing monitoring is conducted, particularly for high-risk third parties, including periodic reviews and identification of red flags

Evyap reserves the right to suspend or terminate any relationship where corruption or bribery risks are identified or confirmed, in accordance with the Company’s Disciplinary and Grievance Policy and applicable contractual provisions.
 

11. CONLICT OF INTEREST

All Employees are required to act in the best interest of the Company and must avoid situations where personal interests conflict, or appear to conflict, with their professional responsibilities.

Any actual, potential, or perceived conflict of interest must be promptly declared and appropriately managed. This includes, but is not limited to :

  • • Personal or family relationships with suppliers, contractors, or competitors
  • • Financial interests that may influence decision-making
  • • External employment or activities that may interfere with official duties

Failure to disclose a conflict of interest shall be treated as a breach of this Policy.


12. RECORD KEEPING AND FINANCIAL CONTROLS

Evyap is committed to maintaining accurate, complete, and transparent financial and business records. All transactions must be properly recorded and supported by appropriate documentation.

The Company strictly prohibits :

  • • Off-the-book accounts or unrecorded transactions
  • • False, misleading, or incomplete entries

Robust internal controls, approval processes, and audit trails shall be maintained to ensure accountability and traceability of all business activities.


13. REPORTING AND WHISTLEBLOWING

All Employees and Associated Persons have a duty to report any suspected or actual breach of this Policy promptly.

Reports may be made through the following channels :

  • • ESM Ethics Committee: hrmalaysia@evyap.com.tr
  • • HQ Ethics Committee: etikkurulu@evyap.com.tr / ethicalcommittee@evyap.com.tr
  • • Malaysian Anti-Corruption Commission (MACC): 1-800-88-6000

Evyap is committed to ensuring that all reports are handled confidentially, fairly, and without retaliation. Any form of retaliation against individuals who raise concerns in good faith is strictly prohibited.

Where appropriate, anonymous reporting channels may be made available in line with best practices and compliance requirements.
 

14. TRAINING AND AWARENESS

Evyap shall ensure that this Policy is effectively communicated and understood across the organisation. All Employees are required to undergo anti-corruption training as part of their induction and on a periodic basis thereafter.

Targeted training shall be provided to employees in high-risk roles, including procurement, finance, and commercial functions, to strengthen awareness and practical application of anti-corruption controls.


15. RISK ASSESSMENT

Evyap shall conduct periodic assessments to identify, evaluate, and mitigate corruption risks within its operations and supply chain.

These assessments shall consider :

  • • Industry-specific risks
  • • Geographic and country risk exposure
  • • Third-party and transactional risk factors

Findings from risk assessments shall be used to strengthen internal controls and preventive measures.


16. MONITORING, AUDIT AND REVIEW

The effectiveness of this Policy shall be regularly monitored through internal controls, audits, and management reviews.

This includes :

  • • Internal audits conducted by HR, Quality Management Systems, and relevant functions
  • • External audits, including customer, certification, and ethical compliance audits
  • • Continuous improvement actions to address identified gaps

Responsibility for oversight lies with the HR Department and the Ethics Committee.


17. BREACH AND DISCIPLINARY ACTION

Any violation of this Policy shall be treated as serious misconduct and may result in disciplinary action, including termination of employment or contractual engagement.

Where appropriate, Evyap may report violations to the relevant authorities.

Under Malaysian law, offences related to corruption and bribery may result in severe penalties, including fines, imprisonment, and corporate liability under Section 17A of the MACC Act.


18. CONTINUOUS IMPROVEMENT

Evyap is committed to continuously strengthening its anti-corruption framework. This includes regular review of this Policy, alignment with evolving legal and regulatory requirements, and enhancement of internal controls and governance practices.


This Policy applies to all Employees and Associated Persons of Evyap Sabun Malaysia Sdn. Bhd.

Evyap is committed to upholding the highest standards of ethical conduct, integrity, and responsible business practices. This includes continuous improvement in environmental sustainability, ethical operations, and responsible sourcing, in line with applicable legal requirements, international standards, and evolving stakeholder expectations

 

Muhammad Farid bin Basir
Regional Director
Human Resources & Corporate Services
Evyap Sabun Malaysia Sdn Bhd
PT Evyap Sabun Indonesia

Published Jan 2026