Anti-Bribery and Corruption Policy

Johore Tin Berhad (“JTB”) and its subsidiaries (collectively referred to as the “Group”) are responsible members of our community and we stand for a bribe and corruption-free corporate culture. We conduct ourselves with integrity and we perform our commercial activities legally and ethically.

The Group requires all employees and Directors of the Group to be committed in the business dealings with ethical manner and integrity. The Group’s Anti-Bribery and Corruption Policy (“this policy”) leverages the core principles set out in the Group’s Code of Ethics and Conducts and this policy should be read in conjunction with the ISO as well as the Group’s various policies and guidelines.

2.APPLICATION AND COMPLIANCE

The Group comply with all applicable law including the Malaysian Anti-Corruption Commission Act 2009 and the Malaysian Anti-Corruption Commission (Amendment) Act 2018 or any amendments thereto.

Under the MACC Act, bribery and corruption are criminal offence and the legal consequences include fine of unlimited amount and/or imprisonment of up to twenty (20) years.

3.GRATIFICATIONS AND CONFLICTS OF INTEREST

Conflicts of interest for our employees arise when they are in a relationship that competes with the interests of the Group. These include relationships with business associates or any party that competes with the Group.

The receipt of undue gratifications by a director or employee of the Group from these third parties may also place them in a position of conflicts of interest. Gratifications include and are not limited to gifts, hospitality, loan, fee, financial benefit, non-monetary consideration and any offer and services provided. Gifts include and are not limited to different forms of monies, festive money packets and tangible and intangible goods and services. Hospitality includes meals, entertainment, accommodation and travel.

The directors and employees of the Group and anyone who acts on our behalf, shall not give, agree to give, promise, offer or accept any gratification, directly or indirectly, amongst ourselves or between ourselves and any party, if it cause conflicts of interest.

4.GIFTS AND HOSPITALITY

The Group recognises that the offering, receiving or exchanging of gifts and hospitality are normal social customs and business etiquette. The intention behind gifts and hospitality is often courtesy, simple gratitude or to render assistance. Before offering, accepting or exchanging gifts and hospitality, we shall consider the Group’s and our own positions, and not cause any unethical conduct.

The employees of the Group and associates may offer and receive gifts and hospitality as long as they are legal, appropriate, commensurate in value, and given in good faith and in a transparent manner. There must not be expectation to gain an improper advantage, reward or benefit to the Group. It must also not put us in a position of conflicts of interest that will influence our duties.

5.SPONSORSHIPS AND DONATIONS FOR CHARITY

The Group promotes sustainability in our communities, and we accommodate requests for sponsorships and donations to charity. We support organisations, groups and individuals within our ability and accountability to our shareholders. We receive each request, give them consideration and conduct due diligence, before we provide funds and resources. We exercise additional prudence when the organisation, group or individual is related to an associated person or a business associate.

The Group also encourages our employees to be charitable and donate to the needy and the less privileged within each of our own capacities. We take reasonable precautions, so as to receive comfort that our resources are reaching legitimate causes and those who are truly in need. Our employees shall exercise prudence and seek appropriate approval when the organisation, group or individual is related to an associated person or business associate.

6.FACILITATION PAYMENTS

The employees of the Group and associates shall not make facilitation payments to any officials to expedite their duties. The only exception is when we are compelled to defend our life, limb or liberty. Our employees and associates are then required to report these incidents to the Group to strengthen our risk management.

7.INTEGRITY PLEDGES

We will disseminate this policy to all business associate and we will request their cooperation to adhere to this Policy.

As for the major suppliers, we will ensure that they commit their pledges to adhere to this Policy by mail/e-mail.

All employees and Directors of the Group must also pledges to adhere to this Policy.

8.TRAINING AND COMMUNICATION

Training on this policy forms part of the induction process. All employees will be provided with regular anti-corruption compliance training programmes to educate them about the requirements and obligations of anti-bribery and corruption laws and this Policy. Where necessary, specialised training will be provided to employees with significant compliance responsibilities or who operate in higher risk areas of the Group’s businesses.

Records will be maintained to verify that all relevant personnel have received the necessary training to perform their responsibilities ethically and in compliance with rules and regulations.

The Group’s stance against bribery and corruption and this Policy must be communicated to all third parties at the outset of our business relationship with them.

9.RAISING A CONCERN AND REPORTING VIOLATIONS

Employees who encounter violations of this Policy and our Manual are encouraged to report their concerns. The procedures to report are provided in our Whistle Blower Policy that is available on our website: http://www.johoretin.com.my/investor/cg/wbp.

10.RESPONSIBILITY AND REVIEW OF THE POLICY

The Human Resources Manager is primarily responsible for the implementation and administration of this Policy and the Manual. The Human Resource Manager shall also receive queries and provide interpretation.

The Board will monitor compliance with the Policy and review the Policy regularly to ensure that it continues to remain relevant and appropriate.

Approved on 16/06/2020