Anti-Corruption Policy

Anti-Corruption Policy

Last updated: 17 June 2026

Virtual Network Solutions Sdn Bhd (“VNS”) has a zero-tolerance policy towards bribery and corruption in all forms. This policy is designed to comply with the Malaysian Anti-Corruption Commission Act 2009 (MACC Act), including the Corporate Liability provision under Section 17A, which holds companies criminally liable for corrupt acts committed by associated persons for the company’s benefit.

1. Purpose

This policy aims to:

  • Prevent bribery and corruption in all VNS operations and supply chains
  • Ensure compliance with the MACC Act 2009 and all applicable anti-corruption laws
  • Protect VNS, its employees and directors from legal, reputational and financial risk
  • Demonstrate VNS’s commitment to ethical business conduct

2. Scope

This policy applies to all VNS directors, employees, contractors, agents and any associated person acting on behalf of VNS in Malaysia, Singapore, Indonesia or any other jurisdiction where VNS operates.

3. Definition of Bribery and Corruption

Bribery is the offering, giving, receiving or soliciting of any item of value to influence the actions of a person in a position of trust or authority.

Corruption includes bribery and any other improper use of power or position for personal gain.

This includes both private-sector and public-sector bribery, and both the giving and receiving of bribes.

4. Prohibited Conduct

VNS personnel must never:

  • Offer, promise, give, request or accept any bribe, kickback or improper payment
  • Make or accept facilitation payments (unofficial payments to speed up routine government actions)
  • Use a third party (agent, consultant or intermediary) to offer or accept bribes on VNS’s behalf
  • Offer gifts, hospitality or benefits to any government official or any other person to obtain or retain business or a business advantage
  • Make any false, inaccurate or misleading entry in VNS’s books or records to conceal corrupt conduct

5. Gifts and Hospitality

All gifts and hospitality must comply with VNS’s No Gift Policy. Gifts to or from government officials are strictly prohibited in all circumstances, regardless of value.

6. Third Party Due Diligence

Before engaging agents, consultants, distributors or any intermediaries who interact with government or third parties on VNS’s behalf, VNS will conduct appropriate anti-corruption due diligence. All such parties must agree to comply with this policy and applicable anti-corruption laws as a condition of engagement.

7. Adequate Procedures

Pursuant to Section 17A of the MACC Act 2009, VNS has implemented the following adequate procedures to prevent corrupt conduct by associated persons:

  • This Anti-Corruption Policy and associated compliance policies
  • Anti-corruption training for all employees
  • A Whistleblowing channel for reporting concerns
  • Third-party due diligence procedures
  • Regular risk assessment and policy review
  • Tone-from-the-top commitment from VNS leadership

8. Reporting

Any suspected violations of this policy must be reported immediately through VNS’s Whistleblowing channel:

Employees who report concerns in good faith will be protected from retaliation under VNS’s Whistleblowing Policy.

9. Consequences of Violation

Violation of this policy may result in:

  • Immediate disciplinary action, up to and including termination of employment
  • Civil or criminal prosecution under the MACC Act 2009 or other applicable laws
  • Termination of business relationships with suppliers, agents or partners

Under Section 17A of the MACC Act, a company found guilty of a corruption offence may be liable to a fine of not less than 10 times the value of the gratification, or RM 1 million, whichever is higher, and/or imprisonment of its directors.

10. Review

This policy will be reviewed annually or following any material changes in relevant law or business operations.