1. Rgtech Spritvest Sdn Bhd (the “Company”) and those who work for the Company on the requirement to observe and uphold the Company’s zero-tolerance position on “bribery and corruption” (collectively known as “corrupt gratification”).
2. This Policy provides a source of information and guidance for those working for the Company. It helps them recognise and deal with corrupt gratification, as well as understand their responsibilities.
3. This Policy is supplemental to, and shall be read in conjunction with the Code of Ethics and Conduct of the Company as annexed herewith, Whistle Blowing Policy, the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act 2009”) and  the Malaysian Anti-Corruption Commission (Amendment) Act 2018.
4. For the purpose of this Policy:
   • Bribery means the act of giving or receiving something of value in exchange for some kind of influence or action in return, that the recipient would otherwise not offer;
   • Corruption means the act of soliciting, giving, accepting or receiving gratification, directly or indirectly, to/from a person in authority either in the form of money, services or valuable goods as an inducement or reward to or not to do an act in relation to the person’s principal affairs – in short, corruption is essentially an abuse of entrusted power or position to obtain a gain or benefit; and
   • Gratification is defined in Section 3 of the MACC Act 2009 and includes:
     • 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;
     • any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
     • any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;
     • any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;
     • any forbearance to demand any money or money’s worth or valuable thing;
     • 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).

The provision or receipt of gratification is not an offense unless it is done corruptly.