Anti-Bribery & Anti-Corruption Policy

SK Luxury Construction Sdn. Bhd. (“the Company”) is committed to conducting its business with honesty and integrity, and adopts a zero-tolerance approach to bribery and corruption in all forms. This Policy sets out the standards expected of everyone who works for or on behalf of the Company.

1. Purpose

This Policy affirms the Company’s commitment to preventing bribery and corruption and provides the framework through which the Company intends to meet its obligations under the Malaysian Anti-Corruption Commission Act 2009, including the corporate liability provision under Section 17A. It is intended to guide the Company’s development and maintenance of adequate procedures aligned with the Guidelines on Adequate Procedures issued under Section 17A(5) (the T.R.U.S.T. principles).

2. Scope

This Policy applies to the Company’s directors, officers and employees at every level, and extends to associated persons who perform services for or on behalf of the Company — including agents, consultants, subcontractors, suppliers, joint-venture partners and other business associates. Associated persons are expected to adhere to standards consistent with this Policy in their dealings connected with the Company.

3. What Is Prohibited

The Company and its personnel must not, directly or through a third party:

• offer, promise, give, request, agree to receive or accept a bribe — any financial or other advantage intended to induce or reward the improper performance of a function or activity;
• pay or accept kickbacks, secret commissions or unauthorised rebates in connection with the award of contracts, tenders, approvals, or the supply of goods and services;
• make facilitation payments (small unofficial payments to expedite routine actions), which are prohibited regardless of local custom or the amount involved;
• offer or accept gifts, entertainment or hospitality that could improperly influence a business decision or create a sense of obligation. Modest, reasonable and transparent business courtesies may be acceptable, but must never be used to obtain or retain an improper advantage.

4. Public Officials and the Construction Sector

The Company recognises that construction and related activities — tendering, permits, inspections, and dealings with public authorities and their officers — carry heightened corruption risk. Personnel must exercise particular care in all interactions with public officials, and must never offer any advantage to influence an official act or decision.

5. Donations and Sponsorships

Political donations are not made by the Company. Charitable donations and sponsorships, where made, must be legitimate, properly recorded, and never used as a channel for improper influence.

6. Conflicts of Interest

Personnel must avoid situations in which their personal interests conflict, or may appear to conflict, with those of the Company. Actual or potential conflicts of interest must be disclosed to Management so they can be managed appropriately.

7. Responsibilities and Commitment to Adequate Procedures

The Board and Management provide top-level commitment to a culture of integrity. The Company is committed to progressively establishing and maintaining adequate procedures proportionate to its business, which are intended to include corruption risk assessment, due diligence on associated persons, communication and training, and monitoring and review. Every director, employee and associated person is responsible for complying with this Policy.

8. Reporting Concerns

Anyone who suspects or becomes aware of bribery or corruption connected with the Company is encouraged to raise it promptly. Concerns may be reported to the designated Integrity Officer or to Management at admin@skluxury.com.my, in accordance with the Company’s Whistleblowing Policy. Reports made in good faith will be treated in confidence, and the Company does not tolerate retaliation against anyone who raises a genuine concern.

9. Consequences of Breach

Breach of this Policy is a serious matter and may result in disciplinary action up to and including termination of employment or engagement, and may expose the individuals involved and the Company to criminal liability under Malaysian law.

10. Review

This Policy will be reviewed periodically and updated as the Company’s procedures mature or as legal requirements change.