Kinetic DAX Sdn. Bhd. (the "Company" or "Kinetic") is committed to maintaining ethical business practices and preventing bribery and corruption, as outlined in its Anti-Bribery, Corruption & Whistleblowing ('ABC') Policy (“the Policy”). The Policy defines the Company's zero-tolerance stance on bribery, corruption, with a whistleblowing provision that allows for confidential reporting of actual and potential improper conduct (including any criminal act).
The Policy applies to the Company's internal parties such as the Shareholders, Board of Directors, Board Committee, Senior Management, employees (temporary, fixed-term, or permanent), and associated person(s) (any individuals or entities with whom the Company interacts, such as existing and potential customers, professional traders, market makers, affiliates, business partners, agents, advisors, consultants, trainees, volunteers, sponsors, officers, trustees, subsidiaries and their employees, and government and public bodies – this encompasses their advisors, representatives and officials, politicians, or any external parties), regardless of location.
Kinetic strictly prohibits bribery and corruption in all operations, upholding ethical and professional standards. The Company complies with all Malaysian laws and regulatory requirements on ABC, with oversight from the Securities Commission Malaysia (SC), and adheres to the Guidelines on Recognized Markets and Guidelines on Adequate Procedures pursuant to Subsection 5 of Section 17A under the Malaysian Anti-Corruption Commission (MACC) Act 2009.
The Company prohibits any person acting on its behalf, directly or indirectly, from offering, soliciting, or accepting bribes or making corrupt payments under any circumstance, whether in interactions with government and public officials or private individuals and entities.
Kinetic recognises that bribes can take many forms, including but not limited to gifts, hospitality, entertainment, provision of travel, facilitation payments, kickbacks, contributions, sponsorships, employment offers to close associates, and other forms of gratification or services of value. These actions are strictly prohibited, whether offered directly or through a third party.
Kinetic’s ABC Compliance Programme and policies are overseen by the Board of Directors, and this policy statement emphasises that all internal parties, including the Board of Directors, must comply with the principles set forth in this policy in the performance of their services for or on behalf of Kinetic.
The Compliance Department oversees all ABC matters, providing guidance and ensuring the timely implementation of the Company’s ABC Compliance Programme, which is based on corruption and bribery risk assessments. For advice or reporting inquiries related to ABC and Whistleblowing, the Compliance Department can be contacted at abc@kdx.com.my.
Kinetic performs due diligence to ensure that the internal parties and associated person(s) align with its zero-tolerance approach to bribery and corruption. Background checks, document verifications, and interviews are conducted prior to and during the association with each individual or entity. All internal parties must refrain from accepting or offering gifts, entertainment, or other benefits that could influence their professional duties.
Kinetic seeks to prevent situations where conflicts of interest could negatively impact the Company internal parties and associated person(s). To achieve this, the Company has set up processes to identify, prevent, and manage any potential conflicts of interest. In a situation when conflict does occur, all internal parties and associated person(s) must disclose any personal and business related interests they or connected persons may have in any decision or matter involving the Company, as outlined in the Company’s Conflict of Interest Policy.
Kinetic’s Whistleblowing Policy protects whistleblowers' identities and guards against retaliation, provided reports are made in good faith. Internal parties and associated person(s) are encouraged to report concerns regarding bribery, corruption, or improper conduct. Reports can be submitted using the Whistleblower Report Form, attached herein as Annex 1 or available through internal channels or via email at abc@kdx.com.my. All reports are handled confidentially, and investigations are conducted thoroughly.
Failure to comply with this policy may result in termination of employment or contractual agreements. Kinetic is dedicated to upholding integrity in all operations and expects all internal parties and associated person(s) to adhere to the highest standards of ethical conduct.
All internal parties and associated person(s) with the Company agree to adhere to the policies and standards outlined in this Policy Statement.