Anti-Bribery & Anti-Corruption Policy

With the introduction of Section 17A of the MACC, there are significant ramifications on the liability of commercial organizations and the Boards and Management. Section 17A of the MACC introduces the strict liability concept of "Corporate Liability".

This effectively means that:

• the commercial organization itself is now deemed to have committed the bribery offense; and

• the Boards and Management are also now deemed to have committed the bribery offence.

Even if the commercial organisation or Boards and Management did not authorize the bribe nor had any knowledge of it, such a defense is insufficient, by itself, to absolve them of liability.