For the purpose of this Policy:

Term Definition
Board The Board of Directors, including the Risk Management Committee of the Legal Entity Board/ Group Board, where the responsibilities of the Board have been delegated to such a Committee.
Senior Management
  • Group Chief Executive Officer (GCEO);
  • Chief Executive Officers, Managing Directors – Line of Business, Group Chief Risk Officer, Group Chief Compliance Officer, Group Chief Human Resource Officer, Group Chief Financial Officer, Group Chief Operations Officer, Group Chief Internal Auditor and Group Company Secretary;
  • Direct reports of (i) & (ii).
Group Chief Compliance Officer (“GCCO”) The appointed person who is the central point of authority on compliance matters and responsible for the management of compliance risk in the Bank.
Group Compliance The compliance function that carries out the responsibilities of identification, assessment, monitoring and reporting of compliance risks as well as providing advisory, guidance and training on regulatory requirements governing the Bank’s activities.
Business Units (BUs) Include Lines of Business (LOB) such as:
  • Wholesale Banking
  • Business Banking
  • Retail Banking
  • Investment Banking
  • Private Banking
  • Funds Management
  • Stockbroking
  • Futures broking
Group Shared Services(GSS) Include support and operations units within AmBank Group such as:
  • Group CEO’s Office
  • Group Corporate Communications & Marketing
  • Group Company Secretarial
  • Group Compliance
  • Group Finance (including Capital & Balance Sheet Management, Group Corporate Services, Group Tax, Group Strategic Sourcing and Group Administration)
  • Group Human Resource,
  • Group Information, Operations and Digital Banking
  • Group Internal Audit
  • Group Legal
  • Group Risk Management (including Group Loan Rehabilitation)
Bribery and Corruption Any action which would be considered as an offence of giving or receiving ‘gratification’ under the Malaysian Anti-Corruption Commission Act 2009 (MACC Act). In practice, this means offering, giving, receiving or soliciting something of value in an attempt to illicitly influence the decisions or actions of a person who is in a position of trust within an organisation. Bribery may be ‘outbound’ or ‘inbound’. Outbound is where someone acting on behalf of the Bank attempts to influence the actions of someone external, such as a government official or client decision-maker, whilst inbound is where an external party is attempting to influence someone within the Bank such as a senior decision-maker or someone with access to confidential information.
Gratification Defined in the MACC Act to mean the following:
  • money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;
  • any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
  • any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;
  • any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;
  • any forbearance to demand any money or money’s worth or valuable thing;
  • any other service or favour of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and
  • any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f).
Business Associate Any external party with whom the Bank has, or plans to establish, some form of business relationship. This may include clients, customers, joint ventures, joint venture partners, consortium partners, outsourcing providers, contractors, consultants, subcontractors, suppliers, vendors, advisers, agents, distributors, representatives, intermediaries and investors.
Employees All individuals directly contracted to the Bank on an employment basis, including permanent and temporary employees.
Conflict of Interest Any situation when a person uses his influence and/or position at the Bank to act in favour of his personal interests instead of that of the Bank’s.
Donation & Sponsorship Charitable contributions and sponsorship payments made to support the community. Examples include sponsorship of educational events, supporting NGOs, and other social causes.
Hospitality The considerate care of guests, which may include refreshments, accommodation and entertainment at a restaurant, hotel, club, resort, convention, concert, sporting event or other venue such as Company offices, with or without the personal presence of the host. Provision of travel may also be included, as may other services such as provision of guides, attendants and escorts; use of facilities such as a spa, golf course or ski resort with equipment included.
Government Officials Includes, without limitation, candidates for public office, officials of any political party, and employees of government, national, municipal or local governments, state-owned enterprises and government linked companies.
Gift Anything of value including items such as money, securities, business opportunities, goods, services, entertainment, company sponsored events, food, drink or vacations.