1. OVERVIEW & OBJECTIVE

1.1. INGENIOUS WORKS INTERNATIONAL (M) SDN. BHD. has sanctioned a ZERO TOLERANCE policy against all forms of bribery and corruption. Ingenious Works International (M) Sdn. Bhd. (hereinafter referred to as “ING” or “The Company”) is committed to conducting its business in accordance with all applicable laws, rules and regulations and the highest ethical standards.

This Anti- Bribery & Corruption Policy (hereinafter referred to as the “ABC Policy” or “Policy”) aims to guide The Company to conduct its business in a law abiding, ethical and professional manner.

1.2. The purpose of this ABC Policy is to provide guidance to ING Employees and/or any person(s) associated with ING (hereinafter referred to as “Associates” – as defined in Section 3) concerning how to deal with bribery and corruption related issues that may arise in the course of business. It reiterates ING’s commitment to full compliance by its Employees and Associates with the Malaysian Anti-Corruption Commission (MACC) Act 2009 and the MACC (Amendment) Act 2018 and any other local anti-bribery or anti-corruption laws that may be applicable. This Policy complements and should be read in conjunction with our Whistle-blower Policy, under section 13, Whistle Blowing Policy: Raising A Concern or Complaint.

2. SCOPE

2.1. This Policy applies to the ING’s Directors, Employees, Employees of Controlled Organizations and Business Associates acting on the ING’s behalf, within the ING’s internal dealings as well as the ING’s external dealings with other businesses, organizations, local authorities as well as government.

2.2. This Policy is intended to supplement all applicable laws, rules, and other internal policies and is not intended to supplant any local or international laws.

3. DEFINITIONS

“ABC POLICY” or “Policy” means the Anti-Bribery and Anti-Corruption Policy;

“Associates” means Business associates, partners, agents, vendors, suppliers, contractors, consultants and any other third-party service providers or persons who perform any commercial or non-commercial services for or on behalf of the Company;

“Bribery & Corruption” means Act of giving, agreeing to give, promises or offers to any person any gratification (including payment of cash, gifts, or excessive entertainment, or an inducement of any kind offered or given to any person) with the intent (a) to obtain or retain business for the company; or (b) to obtain or retain an advantage in the conduct of business: or (c) to abuse of entrusted power for private or company gain or both under the Malaysian Anti-Corruption Commission Act 2009 (MACC Act 2009);

“Gratification” is defined in the MACC Act 2009 to mean the following:

a) money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;

b) any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;

c) any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;

d) any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;

e) any forbearance to demand any money or money’s worth or valuable thing;

f) any other service or favor of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and any offer, undertaking or promise, whether conditional or unconditional, of any Gratification within the meaning of any of the preceding paragraphs (a) to (f).

“Conflict of Interest” means when an Employee’s personal interests either influence, have the potential to influence or interfere with objectivity in performing his/her duties, exercising judgment or decision-making on behalf of The Company;

“Contractor” or “third party service provider” means Entity or individual who provides, and receives payment for, services or goods related to any aspect of ING’s operations, and includes subcontractors;

“Employees” means All employees including directors of the company and its subsidiaries (if any);

“Entertainment / Hospitality Expenses” means Meals, drinks, lodging, travel or other expenses given to or received from people who have or who may have facilitated the creation of a business relationship with the Company. This includes expenses incurred by a prospective client, customer or business partner. Expenses can be a legitimate contribution to achieving a business outcome and also includes attendance at social, cultural or sporting events;

“Family Members” means Includes spouse(s), children (including step-children and adopted children), parents, step-parents, siblings, step-siblings, grandparents, grandchildren, in-laws, uncles, aunts, nieces, nephews, and first cousins, as well as other persons who are members of your household;

“Gifts” means Money, goods or services, which, if given appropriately, are a mark of friendship or appreciation. Gifts should be given without expectation of consideration or value in return;

“Money Laundering” means Process of introducing money, property or other assets derived from illegal and criminal activities into the legal financial and business cycle to give it a legitimate appearance. It is a process to clean ‘dirty’ money in order to disguise its criminal origin;

“Public Officials” means Includes officers to Public Bodies, candidates for public office, officials of any political parties and officials of any state-owned enterprises;

“Public Bodies” means Includes the Government of Malaysia, State Government, any local and statutory authority, national or state department, registered societies, registered sport’s governing bodies, company or subsidiary of any public bodies.

4. POLICY STANCE

4.1. Bribery&Corruption
ING prohibits all acts of Bribery and Corruption in its business dealings. Employees and its Associates shall not offer, give, receive or solicit any item of value to influence the other party to secure benefit or outcome either for the organization or the person concerned. No Employee or external party shall suffer demotion, penalty or adverse consequences as retaliation for refusing to participate in any illicit behaviors. All Employees are reminded that he/she will be subjected to stern disciplinary action, including dismissal as well as civil and criminal liability if he/she is found in violation of this policy.

4.2. ING is committed to take all necessary measures to ensure that our businesses do not participate in corrupt activities and to implement adequate procedures effectively to comply with the provisions of Section 17A of the amended MACC Act 2009.

5. GIFTS, ENTERTAINMENT AND HOSPITALITY

5.1. Gifts, Entertainment and Hospitality are usually assessed as high-risk areas for bribery. The Company has adopted a “NO GIFT” Policy whereby, subject only to certain narrow window of exceptions, ING employees are prohibited from, directly or indirectly, receiving or providing gifts. ING requires employees and directors to abide by this policy to avoid conflict of interest or the appearance of conflict of interest for either party in on-going or potential business dealings between ING and external parties as gifts can be seen as a bribe that may tarnish ING’s reputation or be in violation of anti-bribery and corruption laws.

However, the Company recognizes that the exchange of business courtesies, such as modest gifts, hospitality and entertainment (including meals, invitations to attend promotional events or parties) particularly during festive periods is customary and legitimate to create goodwill, and/or strengthen business and commercial relationships. Such courtesies are allowed if they are not lavish, appropriate and reasonable in the light of accepted business practices of the relevant businesses that the Company operates in and is not intended to improperly influence the decisions of the person involved or the benefits is targeted to be of employee’s personal gain or benefits.

5.2. ING’s Employees or Associates must not give or request favors or offer or accept gifts or any personal benefit or privilege of any kind with a value that could in any way influence (for example, by causing the person to act or fail to act in violation of a legal duty, by causing the person to abuse or misuse their position, by securing an improper advantage, contract or concession, etc.) the judgment of the recipients or a third party in their business dealings with or on behalf of ING or any other party.

5.3.The basic rules on Gifts, Entertainment and Hospitality expenses² are: –

a) Bona Fide: Made for the right reason: if a gift, entertainment or hospitality, it should be given clearly as an act of appreciation, if travel expenses then for a bona fide business purpose.

b) No Obligation: The activity will not create any obligation or expectation on the recipient.

c) No Undue Influence: The expenditure will not be seen as intended for, or capable of, achieving undue influence in relation to a business transaction or public policy engagement.

d) Made Openly: It will not be performed in secret and be undocumented – if it is, then the purpose becomes questionable.

e) Legality: It is compliant with relevant laws.

f) Accords with Stakeholder Perception: The activity would not be viewed unfavorably by stakeholders were it made known to them.

g) Proportionate: The value and nature of the expenditure is not disproportionate to the occasion.

h) Conforms to the Recipient’s Rules: The gift, hospitality or reimbursement of expenses will meet the rules or code of conduct of the recipient’s organization.

i) Infrequent: The giving or receiving of gifts, entertainment and hospitality is not overly frequent between the giver and the recipient.

j) Documented: The expense will be fully documented including purpose, approvals given and value.

k) Reviewed: The records of entertainment and hospitality expenses and the effectiveness of the policy and procedures are reviewed by management.

5.4. When unsure, Employees and Associates should consult his/her Head of Department or seek for consultation via ingenious.mgmt@gmail.com.

6. DONATIONS, SPONSORSHIP & CORPORATE RESPONSIBILITIES (CR)

6.1. As a responsible corporate citizen, ING understands that it is the nature of our business that the Company gets requests to contribute to social investment activities in the areas where the Company operates. In principle the Company provides such assistance for legitimate and deserving cases in both financial and non-financial ways. Care needs to be exercised that such sponsorships, donations and contributions reach the legitimate beneficiaries, and comply with the relevant laws.

6.2. Employees must ensure that all sponsorships and donations are not used as a subterfuge for bribery. Employees of ING need to be certain that donations to local or foreign-based charities or beneficiaries are not disguised illegal payments or bribes to government officials, and must ensure that the charity does not act as a conduit to fund illegal activities in violation of international anti-money laundering, anti-terrorism and other applicable laws.

6.3. Generally, all sponsorships and donations must comply with the following:

a) Ensure such contributions are allowed by applicable laws;

b) Obtain all necessary internal and external authorizations;

c) Be made to well established entities having an adequate organizational structure to guarantee proper administration of the funds;

d) Be accurately stated in the company’s accounting books and records;

e) Not to be used as a means to cover up an illegal payment or bribery;

Examples of red flags to look out for are as follows:

f) The proposed recipient /organization has affiliations with a Public Official or their relatives are involved;

g) The contribution is made on behalf of a Public Official;

h) There is a risk of a perceived improper advantage for ING;

i) The proposed recipient is based in a high-risk country, the request comes from a high-risk country or the activity takes place in a high-risk country.

6.4. Corporate Responsibility (CR)

a) As part of ING’s commitment to corporate responsibility and development, as a general principle, ING provides such assistance in appropriate circumstances and in an appropriate manner. However, such requests must be carefully examined for legitimacy and not be made to improperly influence a business outcome.

b) The proposed recipient of assistance must be a legitimate organization and appropriate due diligence must be conducted. Even requests determined to be legitimate must be carefully structured to ensure that the benefits reach their intended recipients. If you are in any doubt as to whether a charitable contribution or social benefit is appropriate, please consult relevant Head of Department or seek for consultation via ingenious.mgmt@gmail.com.

7. POLITICAL CONTRIBUTIONS

7.1. As a matter of general policy, ING does not make or offer monetary or in-kind political contributions to political parties, political party officials or candidates for political office.

7.2. If any contribution is made, it must be permissible under applicable laws and must not be made with any promise or expectation of favorable treatment in return and must be accurately reflected in ING’s accounting records. Under no circumstances, however, will any employee be compensated or reimbursed in any way by the Company for a personal political contribution.

8. FACILITATION PAYMENTS & KICKBACKS

8.1. “Facilitation Payments” is defined as payments made to secure or expedite the performance by a person performing a routine or administrative duty or function. “Kickbacks” are typically payments made in return for a business favor or advantage.

8.2. ING prohibits all its Employees from making or accepting, facilitation payments or “kickbacks” of any kind. Associates must avoid any activity that might lead to a facilitation payment or kickback being made or accepted

8.3. Any request for a facilitation payment MUST be refused and the matter MUST be reported immediately to the Company through the Whistleblowing Policy and Procedures (as listed in Section 12 – “Whistleblowing: Raising a Concern or Complaint”).

8.4. All Employees are reminded that offering and/or receiving “facilitation payments” / “kickbacks” is a major misconduct and shall face stern legal and disciplinary actions.

9. MONEY LAUNDERING

9.1. ING strongly objects to practices related to money laundering, including dealing in the proceeds of criminal activities

9.2. To avoid violating anti-money laundering laws, Employees are expected to always conduct reasonable customers and counterparty due diligence to understand the business and background of ING’s prospective business customers and counterparties and to determine the origin and destination of money, property and services.

10. DEALING WITH ASSOCIATES & THIRD PARTIES

10.1. ING’s dealings with Associates and third parties, which include contractors, suppliers, agents, consultants, joint venture partners, unincorporated business partners, introducers, intermediaries etc., must be carried out in compliance with all relevant laws and consistent with the values and principles of ING. As part of this commitment, all forms of bribery and corruption are unacceptable and must not be tolerated.

10.2. To help ensure that all businesses are transacted with Associates and third parties that share ING’S standards of integrity, the following must be adhere:

a) Conduct reasonable due diligence, where practical and relevant, to assess the integrity of ING’s prospective business counterparties. Do not enter into any business dealings with any Associates and third party reasonably suspected of engaging in bribery and improper business practices.

b) All third parties are made aware of the ING’s ABC Policy and our expectations of them

c) Appropriate background checks, where practical and relevant, should be conducted on the company, its directors and top management and this can be done through the due diligence process and procedures as established in your jurisdiction. The scope and extent of the due diligence required will vary depending upon the circumstances of each proposed transaction.

11. DEALING WITH PUBLIC OFFICIALS

11.1. ING strives to build transparent and fair relationships with government agencies and public officials. ING’s Employees and Associates must exercise caution when dealing with public officials and appropriate action must be taken to comply with applicable laws and regulations of bribery and corruption in Malaysia.

11.2. ING’s Employees are prohibited from providing gift, entertainment or hospitality to public officials or their family/household members in exchange for future benefits or results.

12. RECRUITMENT OF EMPLOYEES

12.1. ING, being a diversified corporate, provides equal opportunity for any qualified and competent individual to be employed by the company from various multicultural and multiracial background, sourced local and internationally.

The recruitment of employees should be based on approved selection criteria to ensure that only the most qualified and suitable individuals are employed. This is crucial to ensure that no element of corruption is involved in the hiring of employees.

In line with this, for all recruitments: –

a) Where applicable, proper background checks should be conducted in order to ensure that the potential employee has not been convicted in any bribery or corruption cases nationally or internationally;

b) Offers of employment should not be given in exchange for or to reward any benefit received by ING. The Company should not offer employment, procure and/or create an opening within The Company in exchange for a personal benefit or seek an unfair advantage in any business negotiation or as an inducement for future business.

13. WHISTLEBLOWING POLICY: RAISING A CONCERN OR COMPLAINT

13.1. Our success in combating all forms of bribery and corruption hinges on our personal commitment to adhere to this Policy. Therefore, it is our responsibility to promptly report any suspected contraventions of this Policy.

13.2. If you have any suspicions or concerns regarding conduct to which this Policy applies, or if you become aware of any action in conflict with this Policy, you must report those concerns or actions to your human resources or legal department, or report your concerns, alternatively if you prefer to remain anonymous, you can scan the QR below to proceed with anonymous reporting.

13.3. Any ING Employee who fails to report known or suspected violations may be subject to disciplinary action including termination of employment. In Malaysia, any person who knows and fails to report an act of giving and offering of bribes is committing an offence under Section 25 (1) and (2) of the MACC Act 2009.

13.4. Any report made in accordance with Section 13.2 will be treated with utmost confidentiality. No Employee or Associate acting in good faith will suffer adverse consequences to his employment or retaliation for reporting or for refusing to engage in prohibited conduct, even if such refusal results in loss of business opportunities to the Company.

14. TRAINING & COMMUNICATIONS

14.1. ING Employees and Associates will be provided with anti-corruption compliance awareness to educate them about the requirements and obligations of anti-bribery and corruption laws and this Policy.

14.2. Records pertaining to training, education and communication programs of ING Employees and associates are kept and maintained by the ISO Coordinator and management team for reference.

15. RESPONSIBILITY FOR THE POLICY

15.1. This Policy is reviewed and approved by the Directors and oversight of this Policy has been delegated to the Management, which monitors the effectiveness of and compliance with this Policy.

16. SYSTEMATIC REVIEW & MONITORING

16.1. ING recognizes that managing an anti-bribery and corruption program is a continuous process and a systematic review and monitoring process is necessary to ensure its objectives are being met. The Management will be responsible for overseeing the process of reviewing the effectiveness and compliance to the anti-bribery and corruption program and policy. The reviews may take the form of internal audits carried out by the Group Internal Audit Department (GIAD) or independent audits carried out by an external party, where necessary.

17. RECORD KEEPING

17.1. The Company will keep financial records and have appropriate internal controls in place which will evidence the business reasons for making payments to, and receiving payments from, any person.

17.2. Employees must ensure that all expense claims relating to hospitality, gifts or expenses incurred to Associates and/or any person are submitted in accordance with the Company’s applicable policy and specifically record the reason for such expenditure. Employees shall further ensure that all expense claims shall comply with the terms and conditions of this policy.

17.3. All accounts, invoices, contracts and other documents and records relating to dealings with Associates and/or any person shall be prepared and maintained with strict accuracy and completeness.

17.4. All Associates are reminded that no records shall ever be kept “off-book” to facilitate or conceal improper payments. All record keeping and Document Management System shall be fully in line with the respective ING’s ABC policies.

18. EFFECTIVE DATE

18.1. The Policy is approved by the Directors and effective as of 1ˢᵗ October 2025.