Anti-Corruption Policy & Guidelines
Introduction
Creative Elements Communication is committed to conducting business with integrity, accountability, and transparency. We recognize the importance of preventing corruption and upholding ethical practices in compliance with the Malaysian Anti-Corruption Commission Act 2009 (MACC Act) and international standards such as the UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA). Our policy is designed to ensure that corruption, bribery, and unethical conduct are not tolerated within our operations, whether in Malaysia or abroad.
Purpose
This Anti-Corruption Policy outlines the principles and practices Creative Elements Communication adopts to prevent any form of bribery or corruption. It applies to all employees, contractors, consultants, and any third parties acting on behalf of the company.
Scope
This policy is applicable to all personnel of Creative Elements Communication, including the management team, employees, business partners, and anyone working with or on behalf of the company. It applies globally and across all levels of operation.
Our Commitment
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Compliance with Laws
Creative Elements Communication adheres to all applicable anti-corruption laws, including the Malaysian Anti-Corruption Commission Act 2009 and relevant global legislation. We expect our employees and partners to uphold these laws. -
Zero Tolerance for Corruption
We have zero tolerance for bribery, facilitation payments, or any other form of corruption. No employee or third party should offer, give, solicit, or accept bribes in any form. -
Gifts and Hospitality
Gifts or hospitality must never be used to influence a business decision or create any form of obligation. Any offering of gifts or hospitality must be transparent, modest, and within reasonable limits as defined by our internal guidelines. -
Facilitation Payments
Facilitation payments, or “grease payments,” which are typically small payments to expedite services, are strictly prohibited. -
Political Contributions
Creative Elements Communication does not make political contributions to gain a business advantage. Any personal political contributions made by employees must not be linked to the company or used to influence business outcomes. -
Charitable Donations
Any charitable donation made by the company must be transparent, documented, and aligned with legitimate charitable purposes. Donations should never be used as a way to circumvent anti-bribery policies.
Roles and Responsibilities
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Management is responsible for leading by example and ensuring compliance with this policy.
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Employees must read, understand, and follow this policy and report any suspicious activity.
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Third Parties acting on behalf of Creative Elements Communication must comply with this policy, and due diligence will be carried out before engaging with any external entity.
Reporting Concerns
If you encounter any suspicion of bribery or corruption, it is your duty to report it immediately. Employees and partners can report anonymously, and we will take prompt and confidential action to investigate any violations.
Non-Retaliation
We maintain a strict non-retaliation policy to protect employees who report concerns in good faith. Any form of retaliation against whistleblowers will not be tolerated.
Consequences of Non-Compliance
Any employee or partner found to be in breach of this Anti-Corruption Policy will face disciplinary action, including possible termination of employment or business contracts, and legal action where applicable.
Continuous Improvement
We are committed to regularly reviewing and updating this policy to reflect changes in the law and business environment. We provide ongoing training to employees to ensure awareness of and compliance with anti-corruption practices.
Conclusion
At Creative Elements Communication, ethical business practices are at the core of our values. We strive to operate with integrity in everything we do, and we expect the same from all of our stakeholders.
Issued by: Creative Elements Communication