1. POLICY STATEMENT
Corruption and bribery have serious economic and social consequences and pose significant risks to ethical business conduct, sustainable development, and the rule of law. The Board of Directors, Management, and employees of Evyap Sabun Malaysia Sdn. Bhd. (“Evyap”) recognize the severity of these risks and are fully committed to preventing any form of corruption or bribery that may undermine the Company’s ethical values, reputation, and long-term business sustainability.

Evyap is committed to fostering a strong anti-corruption culture and to ensuring that all its activities and transactions are conducted in an open, transparent, and ethical manner, in full compliance with applicable laws, regulations, and internal policies governing its operations. Accordingly, all Employees and Associated Persons (as defined in this Policy) are required to act honestly, fairly, and with integrity in all business dealings and relationships undertaken on behalf of the Company.

In line with this commitment, Evyap has established this Anti-Corruption and Anti-Bribery Policy to provide clear guidance on expected standards of conduct and to ensure compliance with the Malaysian Anti-Corruption Commission Act 2009 (Section 17A) and other applicable anti-corruption laws and regulations.


2. POLICY STATEMENT
The purpose of this Policy is to:
•    Establish a zero-tolerance approach towards corruption and bribery
•    Provide clear guidance on acceptable and unacceptable conduct
•    Promote a culture of integrity, transparency, and ethical behaviour
•    Protect Evyap, its Employees, and Associated Persons from legal, financial, and reputational risks
•    Ensure compliance with Malaysian and other applicable anti-corruption laws and regulations

Where local laws, regulations, or internal Evyap policies impose more stringent requirements, those requirements shall prevail.


3. SCOPE
This Policy applies to:
•    All directors, officers, trustees, partners, and employees of Evyap, including permanent, probationary, contract, and temporary staff (collectively referred to as “Employees”); and
•    All persons and entities associated with Evyap (“Associated Persons”).

This Policy applies to all business activities and transactions conducted in Malaysia and in any other jurisdiction where Evyap operates or conducts business.


4. DEFINITION
4.1 Corruption
The abuse of entrusted power, position, or authority to improperly influence a business decision, obtain an unfair advantage for Evyap or any other party, or for personal gain.

4.2 Bribery
The offering, giving, promising, requesting, receiving, or accepting of any gratification or thing of value to influence the actions or decisions of a person in a position of trust.

4.3 Gratification
“Gratification” includes, but is not limited to : 
a)    Money, donation, gift, loan, fee, reward, valuable security, property, or financial benefit;
b)    Office, title, employment, contract, or services;
c)    Payment, release, discharge, or settlement of any loan or liability;
d)    Discounts, commissions, rebates, bonuses, deductions, or percentages;
e)    Forbearance from demanding money or valuable consideration;
f)    Any service, favour, advantage, or protection from penalty, disciplinary, civil, or criminal action; or
g)    Any offer, undertaking, or promise of gratification as described above.


5. PROHIBITED CONDUCT
Employees and Associated Persons are strictly prohibited from:
•    Offering, giving, promising, requesting, receiving, or accepting bribes or gratification
•    Engaging in facilitation payments, kickbacks, or improper advantages
•    Using intermediaries or third parties to conduct corrupt acts
•    Falsifying documents or records to conceal corrupt activities
•    Abusing position or authority for personal or business gain

Any attempt or intention to engage in corruption or bribery is a violation of this Policy, regardless of whether the act is completed.

6. GIFT, BENEFITS AND HOSPITALITY
Evyap discourages the giving or acceptance of gifts, entertainment, hospitality, or other benefits that may influence or appear to influence any business decision, transaction, or relationship.

Unsolicited gifts or business courtesies may only be given or accepted if they:
•    Are reasonable, modest, and infrequent
•    Are given transparently and in good faith
•    Have a legitimate business purpose
•    Are not in cash or cash equivalents
•    Do not create an actual or perceived conflict of interest

Local management may issue additional guidelines to reflect local customs and industry practices, provided such guidelines remain consistent with this Policy.


7. SPONSORSHIP AND DONATIONS
Evyap may provide sponsorships and donations for legitimate purposes related to education, humanitarian, community, environmental, health, sports, arts, and cultural initiatives, subject to applicable laws and internal approvals.

All sponsorships and donations must:
•    Be lawful and transparent
•    Not be used to obtain improper business advantage
•    Be properly documented and approved


8. THIRD-PARTY MANAGEMENT
Evyap is committed to conducting business with integrity and will implement proportionate due diligence measures on Associated Persons to assess corruption and bribery risks.

Employees and Associated Persons must ensure that all dealings with third parties, including government and public bodies, are conducted in compliance with applicable laws and this Policy.

Evyap reserves the right to terminate any relationship or arrangement if corruption or bribery is proven to have occurred.


9. REPORTING AND WHISTLEBLOWING
The prevention, detection, and reporting of corruption and bribery are the responsibility of all stakeholders.

Any suspected or actual violation of this Policy must be reported promptly through the following channels:
i.    Malaysian Anti-Corruption Commission (MACC) : 1-800-88-6000
ii.    ESM Ethics Committee : [email protected]
iii.    HQ Ethics Committee : [email protected] / [email protected]


10. TRAINING AND COMMUNICATION
Evyap shall ensure that Employees are informed of this Policy through appropriate communication and training programmes.

Training shall be conducted to enhance understanding of anti-corruption requirements and to reinforce ethical behaviour across the organisation.


11. MONITORING AND REVIEW
Anti-corruption measures shall be proportionate to the identified risks. This Policy and its implementation shall be monitored, reviewed, and evaluated periodically to ensure its adequacy and effectiveness.

Responsibility for monitoring and review lies with the ESM HR Department and Ethics Committee.


12. CONSEQUENCES OF BREACH
Under Malaysian law, individuals convicted of corruption or bribery offences may face severe penalties, including substantial fines and imprisonment.

Any breach of this Policy, whether or not it results in legal action, shall be regarded as serious misconduct and may result in disciplinary action, including termination of employment or engagement. Evyap may also report violations to the relevant authorities.