Anti-Bribery and Anti-Corruption Policy

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
Copyright: Blue-I Corporation Sdn Bhd
All rights reserved.
None of the information contained in this document shall be disclosed outside the recipient’s own company, and no part of this document may be reproduced or transmitted without the written permission of Blue-I Corporation.
Effective Date: [2^nd January 2026]

1. Introduction

1.1 This Anti-Bribery and Anti-Corruption Policy (“ABAC Policy” or “this Policy”) is developed as part of Blue-I Corporation’s anti-bribery and anti-corruption program and is applicable to Blue-I Corporation and its subsidiaries (“Blue-I Group”).

1.2 This Policy applies to both Blue-I Personnel and Blue-I Business Associates.

1.3 Blue-I Corporation does not condone bribery or corruption and expects all Blue-I Personnel and Blue-I Business Associates to adhere to the same principles in representing Blue-I or in their business conduct with Blue-I.

1.4 For ease of reference, certain sections of this Policy are divided based on their applicability to Blue-I Personnel and Blue-I Business Associates respectively.

2. Definitions

In this ABAC Policy, unless the context requires otherwise:

• “Bribery” refers to the act of offering, giving, receiving, or soliciting gratification as an inducement for an action that is illegal, unethical, or a breach of trust.
• “Corruption” refers to the abuse of entrusted power for private gain, including acts of bribery, fraud, or embezzlement.
• “Facilitation Payments” means unofficial payments made to expedite routine administrative actions.
• “Gift” or “Gifts” include cash, cash-equivalent gifts, and non-cash items such as corporate gifts, hampers, food, or other valuables.
• “Gratification” includes donations, gifts, loans, fees, rewards, or any other advantage, whether monetary or non-monetary.
• “Public Official” includes officers of the Government of Malaysia, state governments, local authorities, statutory bodies, or anyone receiving remuneration from public funds.
• “Blue-I Business Associate” refers to any individual or organization that Blue-I Group contracts with during the course of its business, including customers, suppliers, agents, consultants, subcontractors, and service providers.
• “Blue-I Personnel” refers to every director, employee, contract worker, and intern of Blue-I Group.

3. Policy Statement

3.1 Blue-I Corporation is committed to maintaining the highest standards of ethics and integrity in its business operations. Blue-I Personnel must never, directly or indirectly, offer or accept improper financial or other advantages to obtain or retain business or other benefits. Blue-I Business Associates are expected to adopt the same ethical standards.

3.2 Blue-I Corporation complies with all applicable laws and regulations, including the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act”) and its amendments. Where stricter standards apply in your jurisdiction, you must comply with those standards.

4. Anti-Bribery and Anti-Corruption General Principles

4.1 Blue-I Personnel and Business Associates must not engage in corrupt activities, including offering, accepting, or soliciting bribes or gratification.

4.2 Facilitation payments are strictly prohibited as they are considered bribes under Malaysian law.

4.3 Any request for a bribe or offer of a bribe must be reported immediately to the relevant authority within Blue-I Corporation.

4.4 Violations of this Policy may result in legal consequences under the MACC Act.

5. Gifts

For Blue-I Personnel:
5.1 Corporate gifts may be given or received to foster goodwill and build business relationships, provided they are not lavish or excessive.

5.2 Gifts must be given openly and not with the intention of influencing business decisions or actions.

5.3 Cash or expensive gifts must be politely declined and returned with an explanation of this Policy.

5.4 Records of all gifts must be maintained in accordance with Blue-I’s internal procedures.

For Blue-I Business Associates:
5.5 Business Associates must not offer gifts to Blue-I Personnel with the intention of influencing their professional judgment or decisions.

6. Hospitality and Entertainment

For Blue-I Personnel:
6.1 Hospitality and entertainment are permitted if they are reasonable, proportionate, and not excessive.

6.2 All hospitality and entertainment must be given openly and not with the intention of influencing business decisions.

6.3 Records of hospitality and entertainment must be maintained and declared in accordance with Blue-I’s internal procedures.

For Blue-I Business Associates:
6.4 Business Associates must not offer or accept hospitality or entertainment that could be perceived as influencing Blue-I Personnel’s professional judgment.

7. Dealing with Public Officials

7.1 Blue-I Personnel and Business Associates are prohibited from offering gifts, entertainment, or hospitality to Public Officials or their relatives to avoid the perception of bribery.

8. Referrals

8.1 Blue-I Corporation adheres to a zero-referral policy for all Public Officials. Referral payments to other parties must be approved by the Board and documented clearly to avoid the perception of bribery.

9. Facilitation Payments

9.1 Blue-I Corporation strictly prohibits facilitation payments to expedite administrative processes.

10. Donations and Sponsorships

10.1 Donations and sponsorships must align with Blue-I Corporation’s corporate social responsibility efforts and be approved by the Board.

10.2 Donations and sponsorships must not be offered during sensitive periods, such as during tender processes.

11. Audit and Record Keeping

11.1 Regular audits will be conducted to ensure compliance with this Policy.

11.2 All interactions with Blue-I Corporation must be documented and retained for six years.

11.3 Falsifying or failing to record transactions accurately may result in penalties.

12. Conflict of Interest

12.1 Blue-I Personnel and Business Associates must avoid activities or interests that conflict with their responsibilities to Blue-I Corporation.
12.2 Any actual, potential, or perceived conflicts of interest must be disclosed and managed appropriately.

13. Non-Compliance

For Blue-I Personnel:
13.1 Non-compliance may result in disciplinary actions, including termination of employment, and legal action if it harms Blue-I Corporation’s interests or reputation.

For Blue-I Business Associates:
13.2 Non-compliance may result in penalties, including suspension or termination of contracts, and legal action if it harms Blue-I Corporation’s interests or reputation.

This policy is designed to align with the Malaysian Anti-Corruption Commission Act 2009 and other relevant laws, ensuring ethical business practices and integrity in all operations.