GROUP ANTI-BRIBERY AND CORRUPTION POLICY AND PROCEDURES

PPB Group Berhad (“PPB”) and its subsidiaries (“the Group”) has a zero-tolerance approach to all forms of bribery and corruption and shall continuously conduct its business activities ethically, honestly and with high standards of integrity. This anti-bribery and corruption statement applies to the Group’s business dealings with Government (public sector) and commercial (private sector) entities, and includes their directors, employees, and their Appointed representatives.

The Group is committed to effective bribery and corruption risk management and shall have appropriate internal controls in place to mitigate such risk. This includes having in place policies and procedures to manage conflicts of interest, gifts, hospitality and entertainment, donations and sponsorship, and requests for facilitation payment. In addition, the Group has provided guidance for its Personnel on dealing with public officials and business associates, and the importance of conducting due diligence when dealing with third parties. All business transactions shall be recorded accurately, including financial and other records, as evidence of all payments made.

PPB’s Risk Management & Integrity Department (“RMID”) shall oversee the design, implementation, management, and the continuous improvement of the Group’s Anti-Bribery and Corruption (“ABAC”) policies and procedures. Internal control systems and procedures designed to prevent bribery and corrupt gratification are subject to regular audits by either PPB’s Internal Audit Department, or the appointed external third party, to ensure that they are effective in practice. Any non-compliance as identified by auditing, and any risk areas identified by RMID, shall be reported to PPB’s Audit and Risk Committee and PPB’s Board in a timely manner in accordance with the level of risk identified.

Since the provisions in the ABAC policies and procedures are based on legal requirements, any violation may subject individuals and the Group to penalties, including fines and imprisonment. Such violations may also severely damage the reputation of the Group and its Personnel. As such, Personnel and Business Associates shall not, whether directly or indirectly, offer, give, receive, or solicit any item of value, to illicitly influence the decisions or actions of a person in a position of trust within an organization, either for the intended benefit of the Group or the persons involved in the transaction.

The Group will ensure that all Personnel are trained and made aware of the ABAC policies and procedures. Failure to comply may result in disciplinary action, including termination of appointment or employment. For Business Associates, failure to comply with any of the Group’s policies and procedures may result in the termination of their contract.

Personnel and Business Associates are actively encouraged to report suspected incidents of bribery and corruption via the Group’s whistleblowing channels. The Group also provides assurance that no Personnel shall be penalized or suffer any adverse consequences in retaliation for refusing to pay or receive bribes or participate in other illicit behavior.

Please refer to the policies and procedures below pertaining to ABAC. While the following are primarily aimed at the Group’s Personnel and our Business Associates, most have been made publicly available to support transparency and good governance.