Anti-Bribery and Corrupt Practices Standards
As enshrined in the Bank’s Code of Conduct and Code of Ethics (compliant, responsible, ethical, accurate, trustworthy, equitable), the Bank strictly prohibits any act of bribery and corruption regardless of its form, and requires all its employees to observe and apply the Bank’s core ethical values in their day-to-day operations and business affairs to protect the Bank’s reputation.
The following are the key ABCP standards that must be adhered to:
Giving and Accepting of Gifts & Hospitality
- All employees must strictly adhere to the AmBank Group No Gift Policy. All relationships with customers and business associates must remain objective, fair, transparent and free from conflict.
- The Bank prohibits employees from offering, soliciting or receiving any gifts or hospitality in any form, to or from current or potential customers, vendors, agents and business partners, either directly or indirectly which may influence the employee’s judgment in a decision making process or put the employee in a position of conflict.
- All directors shall not give or accept gifts or hospitality in any form, to or from current or potential customers, vendors, agents and business partners, either directly or indirectly which may put the director in a position of conflict of interest, perceived or actual.
- The Bank prohibits the following practices:
- Accept or give cash or cash equivalents (e.g. cheques, cash convertible gift certificates or cards, securities and loans, meals etc.);
- Accept or give anything that could be viewed as a bribe, payoff or improper influence;
- Use of position in any way to obtain anything of value from prospective or existing customers, suppliers or business partners;
- Provide entertainment that is lavish or too frequent for an existing or prospective customer or supplier;
- Accept or give gifts or hospitality from any supplier during the selection process, whether or not you are the primary relationship manager or involved directly in the negotiation;
- Participate in any action that would cause the other person to violate their own company’s standards for gifts and entertainment;
- Provide gifts or entertainment to an existing or prospective customer or supplier that are not recorded in the Gift Register.
- Save for the above, any gifts (including during festive seasons), meals and entertainment that is valued below RM200 is allowable and not required to be recorded in the Gift Register. All employees are required to exercise due care and professional judgement when dealing with gifts and hospitality to ensure they are not perceived as a kickback or bribe in any way.
Dealing with Government Officials
Any giving or receiving directly or indirectly of, kickbacks or gratuities to/ from government officials is not allowed. Due care and diligence must be exercised at all times when dealing with government officials or associated persons.
The Bank prohibits any form of offering, giving or accepting any form (either in cash or anything of value) of improper payments such as bribes or kickbacks in exchange for business favours, information and favourable treatment. The following (non-exhaustive) practices are prohibited:
- Any request for cash payment or for payment to be diverted to a third party or country outside normal payment terms and processes;
- Doing business with a potential customer with known history of engaging in corrupt acts particularly where the business sector is highly exposed to corrupt practices
- Payments to influence the award of contracts;
- Payments to obtain confidential information about the activities of competitors
Donations and sponsorships
AmBank does not allow its business to be used as a channel for money laundering, terrorist financing or other criminal activities. All employees must adhere to the Bank’s relevant Anti Money Laundering (AML), terrorist financing and proliferation financing related policies and regulations.
Any charitable donations and sponsorships including education scholarships must be subject to appropriate due diligence and screening processed as per the Bank’s AML/CFT and Know Your Customer policies.
Recruitment of employees
AmBank prohibits any form of employment opportunities, whether permanent or temporary in nature, that is used as an inducement to obtain or retain an advantage in business.
All candidates must be screened prior to hiring and ensure they have not been convicted in any bribery
or corruption cases nationally or internationally.
Business Associates Relationship
All employees are required to exercise due care and due diligence at all times when dealing with business associates and ensure their affairs do not involve any form of corrupt practices, perceived or actual.
All employees who are involved directly, or indirectly in procurement activities for equipment, supplies, goods and services must adhere to the AmBank Group Procurement Policy, AmBank Group Sourcing Guidelines and principles i.e. transparency, integrity, value for money, total cost of ownership and accountability.
The Bank prohibits the following practices in dealing with procurement activities:
- Collusive practice – arrangement with two or more parties designed to achieve improper purpose or improper influence to the other party;
- Corrupt practice – offering, giving, receiving, soliciting, directly or indirectly anything of value to influence improperly the action of another party;
- Fraudulent practice – any act or omission including misrepresentation that knowingly or recklessly misleads or attempts to mislead a party to obtain a financial benefit or to avoid obligation;
- Theft – misappropriation of property belonging to another party;
- Applying threats – any act by employees to create fear and for example by citing a senior management name or any persons of a higher authority within the Bank or any other acts with the intent to prevent another employee from performing his duties or induce an employee to act against to the standards and principles set by the Bank.
All appointments of business associates must be subject to proper due diligence and screening according to the Bank’s AML/CFT and Know Your Customer Policies prior to on-boarding, and on-going monitoring throughout the lifecycle of the arrangement between the business associate and the Bank.
All business associates are required to comply with this Policy and provide an undertaking to comply with this Policy.
Conflict of interest
The Bank expects its employees to act in a way that reflects our commitment to integrity and responsible business behavior. All employees must ensure that personal and business affairs do not conflict with or appear to be conflicting with the Bank’s interests.
Any potential conflict observed during day-to-day interactions at the Bank must immediately be reported to the employee’s respective supervisor.
All employees must declare in writing that they have read, understood and will abide by this Policy. A copy of this declaration shall be documented and retained by the Human Resources Department for the duration of the employees’ employment.
The Bank reserves the right to request information regarding an employee’s assets in the event that the person is implicated or suspected to be implicated in any bribery and corruption-related accusation or incident.