________________________________

AXIATA GROUP BERHAD

ANTI-BRIBERY AND
ANTI-CORRUPTION POLICY

________________________________
Effective Date: 06/12/2021
Document No: AGB/ABAC/2020/01
Version: 2.0
Policy Owner: Risk & Compliance Division
Classification: Private and Confidential

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

Page 1
Table of Contents

1. Abbreviation ....................................................................................................................3
2. Definitions ........................................................................................................................4
3. Our Beliefs and Values ......................................................................................................8
4. Introduction .....................................................................................................................9
5. Scope, Objectives and Applicability ................................................................................. 10
6. Responsibilities............................................................................................................... 11
7. Non-compliance to ABAC Policy ...................................................................................... 12
8. Bribery & Corruption ...................................................................................................... 13
10. Gifts, Entertainment and Corporate Hospitality............................................................... 15
11. Donations and Sponsorships ........................................................................................... 18
12. Corporate Social Responsibility (“CSR”) ........................................................................... 19
13. Facilitation Payments ..................................................................................................... 20
14. Conflict of Interest .......................................................................................................... 21
15. Dealing with Third Parties .............................................................................................. 22
16. Interactions with Public/Government Officials and Politically Exposed Persons (“PEPs”) .. 23
17. Political Contributions .................................................................................................... 25
18. Mergers, Acquisitions and Investments ........................................................................... 26
19. Avoiding Nepotism ......................................................................................................... 27
20. Anti-Money Laundering/Counter Terrorism Funding ....................................................... 28
21. Record-keeping and Documentation ............................................................................... 29
22. Speak Up Channel........................................................................................................... 30
23. Training and Communication .......................................................................................... 31
24. Risk & Compliance (R&C) Division ................................................................................... 32
25. Review and updates to this Policy ................................................................................... 33

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1. Abbreviation
Abbreviation Description

ABAC Anti-Bribery and Anti-Corruption

AGB Axiata Group Berhad

AML/CFT Anti-Money Laundering and Counter Financing of Terrorism

BAC Board Audit Committee

Board Board of Directors

BRCC Board Risk and Compliance Committee

CEO Chief Executive Officer

CSR Corporate Social Responsibility

DC Disciplinary/Defalcation Committee

GCEO Group Chief Executive Officer

GCHRO Group Chief Human Resource Officer

GCIA Group Chief Internal Auditor

GCRCO Group Chief Risk and Compliance Officer

GDS Gifts, Donations and Sponsorship

GDSC Gifts, Donations and Sponsorship Committee

HOD Head of Department

HR Human Resources

LOA Limits of Authority

P&P Policies & Procedures

PEP(s) Politically Exposed Person(s)

R&C Risk & Compliance

RCMC Risk and Compliance Management Committee

SLT Senior Leadership Team

[Link] Uncompromising Integrity and Exceptional Performance

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2. Definitions

“ABAC Policy” or “This Policy” is defined as this Anti-Bribery and Anti-Corruption Policy.

“ABAC Procedure” refers to Anti-Bribery and Anti-Corruption Procedure.

“Associates” is defined as entities which the Group has significant influence but not control or
joint control, generally accompanying a shareholding of between 20% and 50% of the voting rights.
Significant influence is the power to participate in the associates' financial and operating policy
decisions but not power to exercise control or joint control over those policies.

“Axiata Group” or “the Group” is defined as AGB and its Subsidiaries and Associates, owned
directly or indirectly by AGB as well as joint venture entities established.

“Axiata Group Instruments” is defined as all applicable policies and procedures including but
not limited to the Code of Conduct, AGB Group Policies and AGB Limits of Authorities (“LOA”).

“Board of Directors” is defined as a corporate governing body of the organisation or entity.

“Board Members” is defined as a group of individuals elected to represent the shareholders to

act as a corporate governing body to supervise the activities of an organisation.

“Corporate Social Responsibility Activity” or “CSR Activity” is defined as a voluntary, self-

regulated and ethics-driven action to ensure the sustainability of the society and our environment.

“Donation” is defined as a contribution, in cash or in kind, directly or indirectly, to a charitable

organisation or association without expecting any incentives, advantages or returns.

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copying of this document and attachments is strictly prohibited.

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“Entertainment, Corporate Hospitality” is defined as anything of value, which includes but is
not limited to accommodation, travel tickets, event tickets (e.g., tickets for concert organised or
sponsored by Axiata given to enterprise/customers/partners), meals provided or hosted by a Third
Party directly or indirectly through its representatives, agents, business associates to develop
and/or maintain good business/stakeholder relationship.

“Facilitation Payment” is defined as ‘speed’ or ‘grease’ payment (financial or non-financial) made

directly or indirectly intending to secure or expedite the performance of a person carrying out a
routine or administrative duty or function.

“Family Member(s)” is defined as any of the Personnel’s spouse, parents, children, brothers,
sisters and spouse of the Personnel’s children, brothers, or sisters.

“Gift” is defined as anything of value, in cash or in kind, that is given to or received from a third
party as a present and without expecting payment or fair value compensation from the recipient.

“GDS Policy” is defined as the Gifts, Donations & Sponsorships Policy.

“GDS Procedure” is defined as this Gifts, Donations & Sponsorships Procedure.

“Money Laundering” is defined as a process whereby criminals attempt to hide and disguise the
true origin and ownership of the proceeds from their criminal activities thereby avoiding
prosecution, conviction, and confiscation of the criminal funds.

“Nepotism” is defined as the act of influence whereby a Personnel seeks unfair advantage for his
or her Family Member employed or to be employed in Axiata Group even though the said Family
Member or friend is not qualified or deserving.

“Personnel” is defined as SLT, heads, senior managers, managers and individuals at all levels
including permanent and contract employees, temporary employees and trainees or interns of
Axiata Group.

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copying of this document and attachments is strictly prohibited.

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“Politically Exposed Person (PEP)” is defined as follows: -
(i) foreign PEPs – individuals who are or who have been entrusted with prominent public
functions by a foreign country. For example, Heads of State or Government, senior politicians,
senior government, judicial or military officials, senior executives of state-owned corporations
and important political party officials.

(ii) domestic PEPs – individuals who are or have been entrusted domestically with prominent
public functions. For example, Heads of State or Government, senior politicians, senior
government, judiciary or military officials, senior executives of state-owned corporations and
important political party officials; or

(iii) persons who are or have been entrusted with a prominent function by an international
organisation, which refers to members of senior management. For example, directors, deputy
directors and members of the board or equivalent functions.

“Public/Government Official” is defined as any person who is a member, an officer, an employee

or a servant or who acts in an official capacity for or on behalf of a public body (i.e. government
department or agency or instrument of a government) and includes a Foreign Public Official, a
member of the administration, a member of Parliament, a member of a State Legislative Assembly,
a judge of the High Court, Court of Appeal or Federal Court, and any person receiving any
remuneration from public funds, and, where the public body is a corporation sole, includes the
person who is incorporated as such.

“Sponsorship(s)” is defined as a support, financially or non-financially, extended to an individual,

entity, organisation or association to fund, care or sustain a project, activity, individual or event
with the primary purpose to promote our brand and build our reputation in return.

“Stakeholders” is defined as internal and external parties that have dealings with Axiata Group
which includes all members of the Board and sub-Board Committees, Personnel, Third Parties,
and other external stakeholder(s) acting for or on behalf of Axiata Group.

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“Subsidiaries” is defined as any company or entity in which Axiata Group, directly or indirectly,
has more than 50% shareholding or control.

“Terrorism Funding” is defined as a process by which terrorists fund their operations to perform
terrorist acts.

“Third Party” or “Third Parties” are defined as Axiata Group’s suppliers, contractors, sub-
contractors, competitors, state-owned enterprises, regulators, investors, media, analyst, vendors,
agents, intermediaries, consultants, representatives, distributors, joint venture partners, business
partners and other external Stakeholder(s) acting for or on behalf of Axiata Group.

“Whistleblowing or Speak Up Channel” is defined as the whistleblowing or Speak Up platform

developed and maintained/operated by an independent service provider, which has been adopted
by Axiata Group as its official communication channel for any party to lodge a complaint or concern.

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copying of this document and attachments is strictly prohibited.

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3. Our Beliefs and Values

3.1 Axiata Group advances and enriches

Asia by developing and enhancing OUR VALUES
today’s digital communications for a Uncompromising Integrity,
better tomorrow.
Exceptional Performance

3.2 Each Stakeholder plays an important role in Axiata Group’s commitment to

conducting its business fairly, impartially and in full compliance with all applicable
laws and regulations in Malaysia and in all other countries where the Group
operates. To the extent this Policy contradicts or is inconsistent with requirements
to any law, statute or regulation, the higher standards shall prevail.

3.3 We strongly believe that our values of [Link] will serve as the core and foundation
of our operations that enable us to provide agile, quality and reliable services and
conduct business with integrity, honesty and transparency:

Uncompromising Integrity - always doing the right thing and fulfilling promises
made to earn the trust of our Stakeholders. We are committed to upholding the
highest standards of lawful and ethical conduct; and to demonstrating honesty,
fairness, and accountability in all our dealings.

Exceptional Performance – always pushing ourselves to deliver outstanding

performance. We are determined to be the winner, leader and best-in-class in what
we do. While we are tough with performance standards, we are compassionate
with people – we call it “performance with a heart”.

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copying of this document and attachments is strictly prohibited.

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4. Introduction

4.1 Axiata Group takes pride in its beliefs and core values of
[Link] and is committed to conducting business with zero
tolerance of any forms of bribery and corruption. The ABAC Policy
governs Axiata

4.2 The Group embraces the core values of UIEP and strictly Group’s Personnel
and Third-Party
prohibits the receipt and the giving of bribes, or
practices in
participation in any acts or situations that may lead to, or
conducting business
be perceived as, bribes such as promises, offers, for and on behalf of
acceptance, receipt or solicitation of gifts and hospitality, the Group.

anything of value, facilitation payment, or improper

payment, to or from any person, entity or agency, to obtain, retain or provide an
improper business advantage or favourable treatment.

4.3 All Stakeholders are committed to upholding their We strongly believe that
commitment to prevent bribery and corruption and to no one business
complying with this Policy. opportunity or
relationship is valued
4.4 The LOA, GDS P&P, and ABAC procedures detail the steps more than the brand
and reputation of the
and guidelines to support the implementation of this Policy.
Axiata Group.

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copying of this document and attachments is strictly prohibited.

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5. Scope, Objectives and Applicability

5.1 This Policy sets out Axiata Group’s commitment to (i) uphold its core values of
[Link]; (ii) conduct business with zero tolerance of any forms of bribery and
corruption; and (iii) ensure compliance to all applicable laws and regulations relating
to ABAC. To the extent this Policy contradicts or is inconsistent with requirements
to any law, statute or regulation, the higher standards shall prevail.

5.2 The objectives of this Policy are set out below:

(i) To reinforce Axiata Group’s core values of [Link], Axiata’s zero tolerance of any
forms of bribery and corruption and its commitment to comply with all applicable
ABAC laws.
(ii) To provide guidance to Stakeholders and Third Parties on circumstances that can
be or may be perceived to be improper, unethical, or related to bribery and
corruption.
(iii) To provide information on the available confidential channel available to all
Stakeholders and Third Parties to raise concerns without fear of reprisal.

5.3 This Policy is applicable to:

(i) All Stakeholders which include all members of the Board (executive and non-
executive directors) and its sub-Board Committees (BAC, BRCC, etc); the senior
leadership team members (CEO, CxOs, HODs, etc) and all other Personnel at
Axiata Group; and
(ii) all Third Parties that conducts business with Axiata Group.

Joint-venture companies in which Axiata Group does not have a controlling stake
or co-venture and associated companies are encouraged to adopt this Policy or
similar principles.

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copying of this document and attachments is strictly prohibited.

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6. Responsibilities
6.1. The following illustrates the roles and responsibilities of the governance parties in
place to ensure compliance with this Policy. place to ensure compliance with this
Policy.

Board of Directors
u Embraces, adhere and uphold the Axiata value of [Link] in any decision-making
process.
u To ensure that the organisation upholds the highest ethical standards in its
business operations.
u Create and encourage a positive, open, honest and transparent environment
where Personnel and Third Parties are comfortable to raise and report concerns.
u Does not tolerate or allow discrimination or retaliation against those who raise
or report genuine concerns.
u Establish a proper function or person in charge to curb bribery and corruption risks
in the organisation through an ABAC program.

Personnel
Third party
a. Read, understand, and adhere to this Policy
during the performance of and carrying out of a. Understand and share the
duties for or on behalf of Axiata Group. same core and ethical
b. Embrace the principle of not operating outside values as Axiata Group.
the law or being inconsistent with the policies b. Act in accordance with this
and values. Policy that is consistent with
c. Acknowledge ABAC compliance and attend Axiata Group’s core values
regular training on ABAC-related matters. during the performance of
d. Raise or speak up regarding suspected or its work for or on behalf of
actual concerns, violations, or non-compliance. Axiata Group.

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copying of this document and attachments is strictly prohibited.

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7. Non-compliance to ABAC Policy

7.1 Failure to comply with this Policy may subject an individual to disciplinary action, up
to and including termination of employment, in accordance with Axiata Group’s
Disciplinary Policy.

7.2 Non-compliance to this Policy by a Personnel should be escalated immediately

through the available reporting channels, including via the Speak Up Channel at
[Link] All investigations will be done
confidentially, and all complaints lodged via the Speak Up Channel will be
investigated independently by the Group Investigations Unit (GIU) of the Group
Internal Audit Department.

7.3 Failure by a Third Party to comply with this Policy and any applicable ABAC laws
may result in the termination of the non-complying party’s relationship with Axiata
Group and other adverse consequences.

7.4 Axiata Group is committed to protect, within reason and means, anyone who reports
or raises a concern in good faith, and those who participate in or conduct an
investigation, from retaliation.

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copying of this document and attachments is strictly prohibited.

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8. Bribery & Corruption
What is bribery?
8.1 Bribery is an act of giving/offering or
receiving/accepting or promising to give/offer or
receive/accept anything of value or gratification
soliciting an undue advantage of any value (which
could be financial or non-financial), directly or
with the intention of
influencing a person’s indirectly, irrespective of location(s) and in violation of
actions applicable law with the intention of influencing a
person’s actions or decisions to obtain or retain an
improper advantage or refraining from acting in relation
to the performance of that person’s duties.

What is corruption?
8.2 Corruption involves the misuse of office or position
or power for gain to oneself, relatives, or associates,
by directly or indirectly offering, giving, receiving or
promising anything of value or a gratification (which

misuse of office or could be financial or non-financial), to/from any person

position or power for one is dealing with to obtain or retain business or to gain
gain to oneself an improper business advantage which is illegitimate,
immoral or incompatible with ethical standards.
Any form of bribery and
corruption is strictly 8.3 The Group strictly prohibits the receipt and the giving of
prohibited.
bribes, or participation in any acts or situations that may
lead to, or be perceived as, bribes such as promises,
offers, acceptance, receipt or solicitation of gifts and
hospitality, anything of value, facilitation payment, or
improper payment, to or from any person, entity or
agency, to obtain, retain or provide an improper
business advantage or favourable treatment.

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copying of this document and attachments is strictly prohibited.

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9. What is anything of value or gratification?

9.1 Gratification or bribe may be in any form, monetary or

otherwise, to obtain or retain an undue business or
personal advantage, which includes but is not limited to:
a. Cash or cash equivalent, for example, money,
Cash or cash loan, valuable security (shares, bonds etc.),
equivalent, gifts and
hospitality, promises rebates, commissions, discounts and jewellery.
or offers of services

b. Gifts and hospitality that are or deemed to be

lavish, for example, providing or receiving 5-star
hotel and first-class air travel, tour packages for
self and/or family.

c. Promises or the award of contract, employment or

business opportunity to any Stakeholder (directly
or indirectly) in breach of Axiata Group
Instruments; and

d. Offers of free services of whatever nature to any

Stakeholder.

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10. Gifts, Entertainment and Corporate Hospitality

10.1 Axiata Group has adopted a “No Gift Policy” whereby all
Stakeholders are prohibited from, directly or indirectly,
receiving or providing gifts. However, subject to certain
narrow exceptions, Gifts may be given subject to prior
approval in accordance with the LOA and in compliance
with VITAL Principles.
Common examples of
10.2 Third Parties are prohibited from giving any Gifts, modest and acceptable

Donations, Entertainment and Corporate Hospitality to gifts are fruit baskets,

Axiata Group Personnel or Family Members, if it could flowers, caps, mugs, pen
drives, and other tokens
reasonably give the appearance of influencing the
of Axiata Group
business relationship with Axiata or any business
corporate gifts that are
decision arising out of the business relationship.
within the Group
approved threshold.
10.3 Axiata Group recognises that occasional acceptance or
offer of modest gifts, entertainment and corporate
hospitality may be a legitimate contribution to good
business relationships. All Stakeholders are required to
observe the VITAL Principles before accepting or providing
Gifts, Donations, Entertainment and Corporate Hospitality:

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 Value – GDS Transactions offered or received shall not be (actual
or perceived) extravagant, excessive, outside the norm or exceed
the aggregated or equivalent threshold stipulated in the LOA.
Exceptions to the general rule of “No Gift” Policy must be
assessed with caution and approved in accordance with GDS
Procedures and Axiata Group Instruments. Approval in
accordance with

Intention – Anything of Value offered or received should not the LOA must be
obtained prior to
convey an expressed or perceived “advantage” or “benefit”,
giving and
monetary or otherwise, with the intention to improperly influence
receiving any Gifts.
the decision-making process to obtain, secure or retain opportunity
although it is occasional or within the approved value.
Any Entertainment
and Corporate
Timing – Anything of Value should not be offered or received Hospitality offered
during the period that may give the appearance (actual or and received shall
perceived) of it being offered or received to improperly influence be in accordance
the decision made to obtain, secure or retain a business with the LOA.
opportunity.
If you are in doubt
please consult your
Line Manager, or the
Risk & Compliance
Division.

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copying of this document and attachments is strictly prohibited.

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 Avoid conflict of interest – Anything of Value should not be offered or received if it
gives rise to actual/real or perceived conflict/conflict of interest and creates an
obligation or impact to the objectivity of the Personnel in making impartial decision for
and on behalf of the Group. All Personnel should refrain from taking advantage or
their position or exercise their authority for their own personal interest at the expense
of Axiata.

Limited frequency – Anything of Value offered to or received from a party should not
be repetitive or have a recurring pattern, albeit the value is low to avoid any actual or
perceived conflicts/conflicts of interest or inappropriate influence.

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11. Donations and Sponsorships

11.1 Axiata Group occasionally makes

Donations and participates in
Sponsorships in countries in which we All Stakeholders exercise
operate to further our business good judgement and
Donation is perform reasonable due
something objectives. Such Donations or diligence.
contributed or given Sponsorships shall not violate our core
(in cash or in kind) values, policies and applicable laws.
by Axiata Group as
charity without 11.2 The Donations or Sponsorships should not be made to secure
expecting any any improper advantage or retain any business relationship.
advantages or
returns. 11.3 Good judgement and due diligence must be exercised to
assess the purpose and intention of the Donation or
Sponsorship, and the reputation or status of the beneficiaries.
All Sponsorships or Donations shall be offered and made
transparently in accordance with Axiata Group.
Sponsorship is
financial support
given to an
association,
organisation or
event for branding
display or other
benefits in return,
e.g. tickets/passes,
hospitality etc.

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copying of this document and attachments is strictly prohibited.

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12. Corporate Social Responsibility (“CSR”)

12.1 Axiata Group actively supports various types of CSR activities

in countries in which we operate, to ensure the sustainability of
society and our environment.

CSR is
CSR is aaself-
self- 12.2 CSR activities must be carefully examined and assessed for
regulated and
regulated and
ethics driven legitimacy and genuineness in not being carried out to
activity with the
ethics-driven improperly influence a business outcome.
aim to ensure the
activity to ensure
sustainability of
the society and
the sustainability 12.3 The proposed recipient must be a legitimate organisation and
our environment
of society
through and our
voluntary the rightful recipient. Therefore, appropriate due diligence must
activity.
environment
be conducted to ascertain whether any Public/Government
through voluntary
Officials are affiliated with the organisation. There should be a
activity.
transparent selection and decision-making process, with
proper records kept.

12.4 CSR activities must be approved and implemented in

accordance with Axiata Group Instruments wherein the
activities are structured to ensure that the intended purpose is
met, and benefits are extended to the intended recipient(s).

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13. Facilitation Payments

13.1 Facilitation Payments are gratification or inducements to secure or expedite a

routine function which one person shall be or is responsible for performing as part
of his/her daily roles and responsibilities. The payments are usually small payments
paid unofficially to expedite routine administrative processes on matters such as
visas, permits, licenses, and custom clearance.

13.2 Stakeholders are prohibited to directly or indirectly offer, promise, give, solicit or
accept, agree to accept, or attempt to obtain anything that might be regarded as a
Facilitation Payment in any form.

13.3 There may be certain exceptional situations or circumstances where Stakeholder(s)

may have to make Facilitation Payments under duress or coercion, including life-
threatening and actual or potential loss of life, limb and liberty situations. However,
it must be immediately reported to the designated R&C Officers and appropriate
document(s) of such incident along with the reasons must be recorded. The R&C
Officers shall take immediate action(s) as may be required.

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14. Conflict of Interest

14.1 All Stakeholders have a contractual obligation and are accountable for decisions
made or actions taken, which should always be in the best interest of Axiata Group.

14.2 All Stakeholders shall recognise and avoid situations of conflict of interest (actual,
real, perceived or potential) to maintain integrity and develop trust by making
professional and impartial business decisions.

14.3 Conflict of interest arises when an individual’s

objectivity is compromised or perceived to have
To make impartial
decisions in the best
been compromised, and there is a conflict
interest of Axiata Group by
between his/her professional duties or recognising actual or
responsibilities at Axiata and his/her personal potential conflict of interest
interest.

14.4 If any conflict of interest is identified, even if it is

perceived or potential, the Stakeholder must immediately declare and report the
situation(s) as referred in the Axiata Group Instruments. The Stakeholder shall also
take the necessary actions to immediately distance, recuse or remove
himself/herself from the situation.

14.5 In the event of any conflict of interest by a Third Party, they must report the same
to the Axiata Head of Procurement in accordance with the Supplier Code of
Conduct.

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15. Dealing with Third Parties
15.1 The Axiata Group’s commercial success is built upon knowing our business
partner who shares the same ethical values and beliefs. Axiata Group builds trust
and a constructive business relationship or enters into a contractual agreement
with Third Parties and any person or organisation working for on behalf of Axiata
Group.

15.2 All Third Parties are expected to:

(i) comply with this Policy.
(ii) to execute the Supplier Code of Conduct, Supplier Declaration Form and/or
any other documents as shall be prescribed by Axiata prior to
commencement of any business activities with Axiata Group.
(i) participate in any due diligence activities as prescribed by Axiata Group;
(ii) ensure compliance of all applicable laws and regulations (including but not
limited to anti-bribery and anti-corruption laws) at all times;
(iii) ensure that any sub-contractors appointed are made aware, amongst others,
of this Policy, Axiata’s zero tolerance to bribery and corruption and also its
“No Gift” Policy; and
(iv) carry out any business activities for and on behalf of Axiata Group in a
professional and ethical manner at all times.

15.3 For further guidance business relationships with Third Parties, all Personnel are
required to refer to the ABAC Procedures.

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16. Interactions with Public/Government Officials and
Politically Exposed Persons (“PEPs”)

16.1 Axiata Group operates in an industry with regular interactions with

Public/Government Officials (including regulators) and PEPs, who are in a position
(actual or perceived) to make or influence decisions that have an effect or impact
on its business and operations.

16.2 Axiata Group shall never improperly influence a Public/Government Officials and
PEP to seek or retain a business advantage and will make committed efforts to
transact in a fair and transparent manner. A high degree of caution and diligence
shall be exercised in all dealings and interactions with regulators,
Public/Government Officials and PEPs.

16.3 When dealing or interacting with Public/Government Officials and PEPs, all
Personnel are required to adhere to the ABAC Procedures, GDS P&P and
applicable laws, and all rules and regulations governing interactions with
Public/Government Officials.

Things to keep in mind while interacting with Public/Government Officials and PEPs

16.6 All Stakeholders are strictly prohibited from any acts of bribery and corruption
involving Public/Government Officials and PEPs.

16.7 All Stakeholders, who are required to interact with Public/Government Officials
(domestic and foreign) and PEPs for or on behalf of Axiata Group shall exercise
due care by observing “PLOD” principles as explained below:

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Page 23
 erception – All our interactions with Public/Government Officials or PEPs must be
conducted professionally and aligned with the Axiata Group’s values and code of conduct.

egitimacy – All our interactions with Public/Government Officials or PEPs shall always
be aligned with the Axiata Group’s corporate objectives.

bjectivity – All our interactions with the Public/Government Officials or PEPs shall be
conducted objectively in furtherance of our corporate values and commercial relationships.

eclaration – Any Gifts, Entertainment and Corporate Hospitality with

Public/Government Officials or PEPs shall be declared by a Personnel via the VITAL
System and approved in accordance with the LOA.

16.8 While maintaining professional working relationships with Public/Government

Officials and PEPs, all Stakeholders shall exercise due care and diligence in all the
dealings.

16.9 The Stakeholder(s) shall also not use/receive private funds for, on behalf of or to
benefit the Group and/or any of the Stakeholder(s), while dealing with
Public/Government Officials, PEPs or any of their relatives or associates.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

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17. Political Contributions

17.1 Axiata Group prohibits any kind or form of political contributions. Stakeholder(s)
must not use Axiata Group’s funds and resources to make contributions or
donations to any political campaigns, political parties, political candidates or their
respective offices/officials or any Stakeholder affiliated organisations.

17.2 Stakeholder(s) are prohibited from acting as follows:

a. Using their position to influence any person to make any political contributions
or to support politicians or their parties in any country.

b. Making any contribution or incurring any expenditure using Axiata Group’s

resources to benefit any political campaign, party or politician in any country.

c. Using Axiata Group’s personnel, assets, facilities, equipment and resources to

support any government party candidates or political campaigns; and

d. Contributing or donating to a charity of a Public/Government Official’s choice.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

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18. Mergers, Acquisitions and Investments

18.1 Axiata Group invests, acquires, mergers or leverages other forms of investments to
extend its reach to new businesses, geographical areas, and countries.

18.2 Any form of investment to expand Axiata Group’s footprint exposes the Group to
inheriting potential fraud, bribery and corruption risks etc. Therefore, appropriate
controls must be in place to mitigate, ring-fence or minimise those associated risks
such as conducting comprehensive due diligence.

18.3 ABAC due diligence shall be applied to all investments on a risk-based approach,
with the extensiveness and comprehensiveness of the due diligence proportionate
to the investment and the perceived likelihood of risk. Due diligence processes shall
take place before and where applicable, post-acquisition and investment.

18.4 Axiata Group or its respective subsidiaries’ Board and relevant committees
overseeing mergers, acquisitions or investments should seek to develop a full
understanding of bribery and corruption risks related to the target companies.

18.5 The working committee handling the merger, acquisition or investment shall ensure
that the target (i.e., a company that is a target for merger, acquisition or investment)
has the equivalent of Axiata Group Instruments.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

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19. Avoiding Nepotism

19.1 Axiata Group adheres to a transparent and fair manner in its recruitment process
and does not discourage multiple family members from working for the Group.
However, the Group strictly condemns nepotism and is committed to minimising
potential, actual or perceived conflicts of interest which may arise when a Personnel
reports to another Personnel or is bound by work authority in addition to family
relationships, intimate relationships, and such similar relationships.

19.2 Axiata Group also reserves the right to take relevant action when relationships of
its Personnel’s impact work ethics.

19.3 Any requests/references for employment received from public officials, third parties
or customers shall undergo regular recruitment due process and shall be identified
separately (irrespective of whether appointed or rejected). Acceptance or offer of
anything of value or in kind for such cases is strictly prohibited.

19.4 In case any department intends to hire a relative of a Public/Government Official or

customer, it should be declared to the GCRCO, and due diligence should be
conducted on the individual before recruitment.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

Page 27
20. Anti-Money Laundering/Counter Terrorism Funding

20.1 Axiata Group strictly prohibits money laundering/terrorism funding under the
applicable laws and regulations in all the respective countries where it operates.

20.2 All Personnel are expected to be mindful of the risk that the Group’s business may
be used for money laundering/terrorism funding activities and must familiarize
themselves with the Axiata Group’s Policy.

20.3 When in doubt or if any suspicious transactions or potential cases of money

laundering/terrorism funding are observed, Personnel shall immediately notify their
Line Manager or the Legal/ R&C Division.

20.4 Any non-compliance with money laundering/terrorism funding laws, whether those
of Malaysia or any foreign country where we operate, will be investigated diligently.
Appropriate and immediate actions shall be taken based on the outcome of the
investigation to ensure we remain committed to Axiata Group Instruments.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

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21. Record-keeping and Documentation

21.1 Axiata Group is committed to maintaining accurate and detailed

books and records that always fairly reflect all transactions of the
Group. All transactions shall be accounted in a transparent manner
and accurately reflect and disclose the business rationale,
Axiata Group has
purpose, substance and legality of all local and cross-border
established a
transactions, payments, and expenses.
global Speak Up
channel and
21.1 Axiata Group affirms that it will not:
website at
a. Alter, conceal any information, falsify and omit or misrepresent [Link]
the facts of any record. [Link]

b. Encourage or allow anyone else to compromise the accuracy This reporting

and integrity of the Group’s records; and channel is available
24 hours a day, 7

c. Engage in any scheme to defraud anyone. days a week.

21.2 Our records management and retention policies shall also ensure
records are maintained to meet the relevant legal, tax and
regulatory requirements and the records that are no longer needed
or are beyond the statutory retention period are securely disposed
of.

21.3 All Personnel should take adequate measures to retain information

that may be relevant for litigation purposes or be subject to a legal
prohibition or stipulation until they are authorised in writing to do
otherwise by the relevant department.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

Page 29
22. Speak Up Channel

22.1 Axiata Group is committed to upholding the highest standards of lawful and ethical
conduct, by demonstrating honesty, fairness and accountability in all our conduct
and dealings.

22.2 To encourage Stakeholders and Third Parties to voice their concerns, including
actual or suspected misconduct, illegal or unethical behaviour, Axiata Group has
established a group Speak Up Channel at [Link]

22.3 This Speak Up Channel is available 24 hours a day, 7 days a week. In addition,
reported concerns can be submitted in native languages within Axiata Group’s
footprint.

22.4 An individual can opt to remain anonymous if he/she wishes and his/her identity will
be protected in accordance with this Whistleblowing/Speaking Up Policy and
Procedures at all stages of the investigation.

22.5 An individual shall ensure that there is a reasonable belief or basis for the concern
and the disclosure is made in good faith and not for the personal gain or motivated
by ill or malicious intention. Mere rumour or hearsay information is not the basis for
speaking up or to whistle blow.

22.6 For further information on the Speak Up Channel, refer to Axiata Group’s
Whistleblowing/Speaking Up Policy and Procedures.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

Page 30
23. Training and Communication
23.1 Trainings are key to build, refresh or improve the necessary competencies and
capability of every Personnel in Axiata. In this regard, Axiata Group will provide the
necessary ABAC awareness and training to its Personnel, as appropriate to their
roles, risks and business scenarios they encounter.

23.2 All Personnel must complete any mandatory ABAC training programs organized by
Axiata Group within the stipulated timeline. Such training programs shall be
monitored by the Risk and Compliance Division for its completion.

23.3 Axiata Group shall communicate to its Stakeholders the necessity to comply with
this Policy at the outset of business relations through the appropriate
communication channels.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

Page 31
24. Risk & Compliance (R&C) Division

24.1 Axiata Group has a dedicated R&C Division to oversee the design, implementation,
monitoring and management of the Axiata Group ABAC program.

24.2 The R&C Division is headed by the GCRCO and it shall perform functions as set
out below within the Group’s structure, equipped to act effectively against bribery
and corruption:
a. provide advice and guidance to Personnel on ABAC matters.

b. take appropriate steps to ensure that adequate monitoring, measurement,

analysis and evaluation of ABAC is performed.

c. report on the performance and monitoring of ABAC to the RCMC and the BRCC
regularly.

d. appropriate resources shall be provided for the effective operations of the ABAC
program, and the R&C shall be staffed by persons who have the appropriate
competency, status, authority and independence.

e. to implement and strengthen the adequate procedures in Axiata Group in

accordance with all applicable laws and regulations.

f. To establish, monitor and report on the Corruption Risk Register for Axiata Group
to the BRCC and the Board.

24.3 Axiata Group shall ensure that its corruption risk is included in its annual risk
assessment of the Group.

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

Page 32
25. Review and updates to this Policy

25.1 This Policy shall be monitored and reviewed at least once every two (2) years by
the R&C Division. The required updates and modifications shall be recommended
by the GCRCO to the BRCC which in turn shall recommend to the Board for
approval. All Stakeholders shall be informed of any revisions made to this Policy.

25.2 Axiata Group reserves the right to vary and/or amend the terms of this ABAC Policy
from time to time.

END OF DOCUMENT

This document and its contents are the property of Axiata Group Berhad (“AGB”). Any dissemination, distribution, or
copying of this document and attachments is strictly prohibited.

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