Anti-Bribery and Anti-Corruption Policy
Effective Date: 14th September 2026
Version: 1.0
1. Our Commitment
Mackyclyde SEO Sdn. Bhd. (“Mackyclyde”) is committed to conducting business with integrity, transparency and professionalism.
We maintain a zero-tolerance approach towards bribery, corruption and improper business practices. We expect our directors, employees, representatives and relevant business partners to uphold these principles in all business activities.
This Policy is established with consideration of the Malaysian Anti-Corruption Commission Act 2009, including the corporate liability provisions under Section 17A, and is applied proportionately to the size, nature and risk profile of our business.
2. Prohibition of Bribery and Corruption
Mackyclyde prohibits the offering, promising, giving, requesting or accepting of bribes, improper gratification or other undue advantages.
No employee or representative may:
- Offer or accept improper payments or benefits to influence a business decision.
- Make facilitation payments or unofficial payments to obtain a business advantage.
- Use third parties or intermediaries to make improper payments on behalf of Mackyclyde.
- Offer gifts, entertainment or other benefits with the intention of improperly influencing a person or business decision.
- Participate in fraudulent, dishonest or corrupt activities.
3. Gifts and Hospitality
Reasonable and legitimate business gifts or hospitality may be provided or accepted where they are lawful, proportionate and appropriate to the circumstances.
Gifts or hospitality must not be used to improperly influence a business decision or create an obligation to provide preferential treatment.
Employees should seek guidance from management where there is uncertainty about whether a gift or hospitality is appropriate.
4. Conflicts of Interest
Employees and representatives are expected to disclose any actual or potential conflict of interest that could improperly influence their business decisions.
Management will review disclosed conflicts and determine appropriate measures where necessary.
5. Business Partners and Third Parties
Mackyclyde expects its suppliers, contractors, consultants and other relevant business partners to conduct their activities ethically and comply with applicable anti-bribery and anti-corruption laws.
Depending on the nature and risk of the engagement, Mackyclyde may conduct reasonable due diligence before engaging relevant third parties.
Mackyclyde will not knowingly engage a third party to perform an activity that would constitute bribery or corruption if performed directly by Mackyclyde.
6. Accurate Records
Mackyclyde is committed to maintaining accurate and appropriate business and financial records.
Payments and business expenses must be recorded accurately and must not be used to conceal improper payments, benefits or transactions.
7. Reporting Concerns
Employees and relevant business partners are encouraged to report suspected bribery, corruption or other violations of this Policy to Company management.
Reports should be made in good faith and contain information that is reasonably available to the person raising the concern.
Mackyclyde will review concerns raised in good faith and take appropriate action based on the circumstances.
8. Non-Retaliation
Mackyclyde does not tolerate retaliation against any person who raises a genuine concern or assists with an investigation in good faith.
9. Management Responsibility
Management is responsible for overseeing the implementation and review of this Policy.
Given the size and nature of Mackyclyde’s operations, anti-bribery and anti-corruption responsibilities may be managed as part of normal management and business operations rather than through a dedicated compliance department.
Mackyclyde will take reasonable and proportionate measures to identify and address bribery and corruption risks relevant to its business.
10. Compliance and Review
Mackyclyde is committed to complying with applicable Malaysian anti-bribery and anti-corruption laws and regulations.
This Policy will be reviewed periodically and may be updated where there are changes to applicable laws, business activities or identified risks.