Governance

TNB Engineering Corporation Sdn Bhd (“TNEC”) and its subsidiaries are committed to conducting our businesses and operations in an honest and ethical manner.

We adopt a zero-tolerance approach to bribery and corruption and are committed to acting professionally, transparently, and fairly with integrity in all our business dealings and relationships as well as implementing and enforcing effective systems to counter bribery and corruption.

These policies set out guiding principles to conduct our businesses with honesty, fairness, and high ethical standards. This Policy sets out the minimum standard that must be followed. Where local laws, regulations, or rules impose a higher standard, that higher standard must be followed.

Policy	Objective	Policy Statement
Anti-Bribery	To state TNEC’s position on bribery and related matters, and to establish key pillars in its structure to protect the company against the impact of bribery.	Bribery in all its forms related to TNEC’s activities is prohibited. It is the responsibility of Personnel at all levels to act with integrity. TNEC holds a ‘No Gifts’ policy, although certain exceptions are allowed. Integrity Pledges must be signed by Personnel on a regular basis, as well as a Conflict of Interest declaration. Business Associates acting on behalf of the company must be managed carefully. Reporting of misconduct by Personnel or third parties is expected, with protection provided for all disclosers acting in good faith. The company is committed to enforcing its position, with the Human Resources Management (HRM) taking on this role. The TCIMS will be assessed and updated on a regular basis to ensure its effectiveness is maintained.
Conflict Of Interest	To establish TNEC’s position on Conflicts of Interest, the company’s expectation that Personnel at all levels should declare any conflicts as they arise, and state the sanctions for non-compliance.	It is the policy of TNEC that the disclosure and management of Conflicts of Interest is the responsibility of its Personnel at all levels. All potential, perceived, and actual conflicts are to be declared in a timely manner and managed using the mechanisms provided by the company. Primary responsibility for managing the declaration lies with the person’s own Manager, with support provided by Human Resources Management (HRM). Sanctions for non-compliance can be severe, depending on the nature of the declared conflict and its impact on the company.
Whistleblowing	To establish secure and confidential reporting channels, ensure whistleblower protection, and provide guidelines on managing reports to their conclusion in an effective and timely manner.	TNEC expects Personnel at all levels to report concerns they may have on any behavior they observe in relation to the company’s activities via the channels established for this purpose. External parties encountering misconduct as they work with TNEC Personnel are likewise expected to report their concerns through the designated channels. Protection will be provided to all parties acting in good faith.
Gifts, Hospitality, And Related Benefits	To delineate the difference between a gift and a bribe, and provide guidance on the acceptable behavior for company Personnel at all levels with respect to gifts, hospitality, and related benefits. Expectations of external parties are also stated.	TNEC holds a ‘No Gifts’ policy. However, there are some exceptions allowed, provided no Conflict of Interest arises and decision-making behavior is not influenced. Likewise, normal business hospitality is permitted but must not be so frequent or extravagant that a sense of obligation is created on the side of the receiver. Festive hampers are discouraged and are to be refused wherever possible. Discounts for staff by External Providers must be provided transparently as part of a general agreement between the Provider and TNEC. Facilitation payments must not be made. Charitable donations and sponsorships must be made transparently and for the general well-being of the company and the communities, it serves. Political contributions are only permissible via an established approval procedure (due process) by the TNEC Board of Directors and must be made in line with the law.
Integrity Pact And Committee Integrity Pledges	To strengthen the measures employed by TNEC to safeguard the tendering and procurement procedures against the effects of bribery.	Integrity Pacts set out the behaviors expected of the company’s External Providers when participating in the contracting procedure. Signing the Pact is a prerequisite for entering into a contract with TNEC, and includes provisions for recognized challenge areas such as collusion between providers, bribing of company personnel, and misrepresentation of products. The Pacts are provided to providers at an early stage of the procurement process. Integrity Pledges establish the expected behaviors of TNEC Personnel at all levels participating in tender committees. Like the Integrity Pacts, the Pledges cover the high-risk areas of bribery, sharing of confidential information, and collusion. In addition, the Pledges include a Conflict of Interest statement. All members of the committee who are present must sign their Pledges at the start of the meeting.