As our reputation is of utmost importance to us here at ESGright, we value honest and ethical business conduct in all our dealings. We recognise that a zero-tolerance approach to any form of corruption and bribery is essential to promote professionalism, integrity and honesty in all our business activities and relationships between our staff, clients, business partners and other stakeholders. This policy acts as a guide on bribery, corruption and the prevention, detection and reporting of any incidents related to corruption and bribery.
Scope
This policy applies to all shareholders, directors, management, and staff of ESGright, including full time, part time, seconded staff, agency staff, agents, interns, and any other persons who perform services on behalf of ESGright. The policy guidance also covers external dealings with clients, suppliers, government bodies and other businesses and organisations.
What is Corruption and Bribery?
Under the Malaysian Anti-Corruption Act 2009 corruption involves the use of entrusted power for private gain or to win, retain or secure an advantage in business. Corrupt practices involve solicitation, receiving, agreeing to receive himself or for some other person, anything of value as an inducement (reward or incentive) to improperly influence another party. In addition, giving, promising, or offering for himself or some other person anything of value as an inducement.
Corrupt practices include bribery (money, fees, loans, securities, employment and other valuable consideration), facilitation payments, kickbacks, discounts, conflicts of interests, cronyism, certain donations, favours, false claims and protection from penalties, etc., as set out in section 3 of the Act.
The policy
Bribery and Corruption
ESGright prohibits the solicitation or acceptance of bribes in any form, to or from its staff, clients, business partners or agents to gain a personal, commercial or regulatory advantage, (including for anyone connected with the individual or company) whether from the public or private sectors.
This policy does not prohibit
- hospitality that is commensurate with the normal social courtesies of life but limited to a monetary value of RM200.
- the giving or receiving of gifts provided they are promotional items only, such as those from conferences, exhibitions or trade shows which may include pens, notebooks and gift bags. However, such gift items must not be exorbitant and not exceed monetary value of RM200.
- Charitable donations which are legal and ethical under local Malaysian laws. However, such donations must not be exorbitant and not exceed monetary value of RM300.
Conflicts of interest
Staff should avoid situations where their personal interest conflicts with their professional duty to the interests of ESGright. A conflict arises from using company assets, resources or information for personal gain compromising ESGright’s interests. In addition, conflicts of interest may arise whilst collaborating with clients, impairing ESGright’s objectivity. These might include family members working for clients or serving in an executive position in a client or any other organisation.
If there is doubt as to what is and is not acceptable practice, the person must refer to the Principal Consultant or to the department head immediately.
Responsibilities of staff
The prevention, detection and reporting of all forms of bribery and corruption is the responsibility of all staff throughout ESGright.
Staff should familiarise themselves with the requirements of this policy.
Staff members must report confidentially to the Principal Consultant or to the relevant department head if they suspect or know that a conflict with this policy has occurred or have been offered a bribe or induced to offer a bribe. They should also refer to the Whistleblowing Policy.
Staff who breach this policy may face disciplinary action which could result in dismissal from employment.
External parties including business associates and clients, if made aware of any activity which might lead to a breach or breaches this policy, should raise their concerns with the Principal Consultant or to the department head immediately.
Noncompliance by external parties may lead to the discontinuance of any business relationship and termination of employment with ESGright.
