Last updated: 17 June 2026

Virtual Network Solutions Sdn Bhd (“VNS”) maintains a strict No Gift Policy to prevent conflicts of interest, uphold our integrity and ensure that all business decisions are made solely on merit.

1. Purpose

This policy aims to:

• Prevent actual or perceived conflicts of interest arising from the giving or receiving of gifts
• Ensure compliance with the Malaysian Anti-Corruption Commission Act 2009 (MACC Act)
• Maintain VNS’s reputation for ethical business conduct

2. Scope

This policy applies to all VNS directors, employees, contractors and agents, in all dealings with customers, suppliers, business partners, government officials and any other third parties.

3. Definition of Gifts

“Gifts” includes any item, benefit or advantage provided without full payment at market value, including but not limited to:

• Physical gifts, hampers, vouchers or cash
• Meals, entertainment or hospitality that is excessive or designed to influence
• Travel, accommodation or recreational activities
• Discounts, favours or services not available to the general public
• Loans or financial benefits

4. Prohibited Conduct

VNS personnel must not:

• Accept any gifts, however small, from any customer, supplier, vendor or business partner
• Offer gifts to any external party on behalf of VNS to obtain or retain business
• Accept gifts on behalf of family members or related parties
• Solicit gifts, hospitality or benefits in any form

5. Permitted Exceptions

The following are permitted provided they are modest, transparent and do not create any conflict of interest:

• Branded promotional materials of minimal value (e.g., pens, notepads)
• Meals during legitimate business meetings at reasonable value (below RM 150 per person)
• Widely available industry events or conferences paid for by VNS

Any gift received that cannot be declined without causing offence must be declared to the Compliance Officer immediately and either returned, donated to charity or surrendered to VNS.

6. Declaration and Reporting

All gifts received or offered (regardless of value) must be declared to the Compliance Officer via compliance@vns.com.my within 5 business days.

7. Consequences of Violation

Violation of this policy may result in disciplinary action, including termination of employment, and may also constitute a criminal offence under the MACC Act 2009.