Our Policy

Rules and Condition

Our Policy

Anti-Bribery Policy Statement

AceTeam (known as AceTeam Networks Sdn Bhd) is committed to conducting its business activities ethically, with integrity and honesty, and with a zero-tolerance approach to bribery and corruption in all forms.

This Policy establishes AceTeam’s commitment to prevent, detect, and respond to bribery risks by implementing and maintaining an effective Anti-Bribery Management System (ABMS) in accordance with ISO 37001 requirements. The organization considers internal and external issues, as well as the needs and expectations of relevant interested parties, in managing bribery risks and opportunities that may affect its operations. AceTeam is committed to:

  • Prohibit all forms of bribery, whether direct or indirect, including offering, promising, giving, requesting, or accepting bribes.
  • Comply with all applicable anti-bribery laws, regulations, and other requirements, including the Malaysian Anti-Corruption Commission (MACC) Act 2009.
  • Implement, maintain, and continually improve the Anti-Bribery Management System to effectively manage bribery risks.
  • Promote an anti-bribery culture of integrity, transparency, and accountability across all levels of the organization.
  • Encouraging raising concerns in good faith, or on the basis of a reasonable belief in confidence, without fear of reprisal to the Whistleblowing Committee.
  • Take appropriate disciplinary action against any personnel who violate this policy or engage in bribery-related misconduct.
  • Ensure that external service providers comply with AceTeam’s anti-bribery management needs and requirements.
  • Regularly review and monitor bribery risks and controls to ensure ongoing effectiveness of the ABMS.

This Policy is applied to the entire Anti-Bribery Management System (ABMS), as defined in the Scope of the ABMS. Users of this document are all employees and business associates of AceTeam Networks Sdn Bhd.

Whistle-Blowing Policy

The policy applies to all AceTeam’s directors, employees, suppliers, contractors, sub-contractors, vendors, agents, consultants, joint venture partners, as well as those who act as representatives of AceTeam.

AceTeam (“the Company”) is committed to achieving and maintaining the highest standards of integrity, transparency, accountability, and work ethics in the conduct of its business and operations. The Whistleblowing Policy (“the Policy”) has been established to enable employees and associates within the company to report any genuine concerns about misconduct, wrongdoings, corruption, and instances of fraud, waste, and/or abuse that they encounter involving the interests of the Company (“Protected Disclosures”).

This Policy provides an avenue for all employees and associates of AceTeam (“the Whistleblower”) to disclose any concerns about misconduct, wrongdoings, corruption, and instances of fraud, waste, and/or abuse (“malpractices”) in accordance with the procedures outlined in this Policy and to provide protection for employees and associates who report such allegations.

What is Whistleblowing?

Whistleblowing is defined as the deliberate, voluntary disclosure or reporting of individual or organizational malpractice by a person who has or had privileged access to data, events or information about an actual, suspected or anticipated Improper Conduct within the organization or by an organization that is within its ability to control.

Improper Conduct is generally described as any conduct which if proved constitutes a criminal offence or any conduct that constitutes a wrongdoing or malpractice and may include any of the following:

  • Abuse of Power;
  • Bribery and corruption;
  • Breach of law and statutory requirements;
  • Criminal Activity;
  • Conflict of Interest;
  • Danger to health and safety or the environment;
  • Sexual harassment;
  • Fraud;
  • Unauthorised and intentional overpayment to suppliers or under any contract;
  • Misuse of any property belonging to the AceTeam;
  • Gross negligence;
  • Theft or embezzlement; and/or
  • Non-compliance with the AceTeam policies, (collectively referred to as “Improper Conducts”)

Protection of Whistleblower

No unfair treatment will be meted out to a Whistleblower by virtue of his/her having submitted a Protected Disclosure under this Policy. The Whistleblower shall be protected against reprisals or retaliation from the Management of the Company and shall be granted immunity from any disciplinary action by the Whistleblower’s immediate supervisor, Head of Department, or any other person exercising power or authority over the Whistleblower in his/her employment.

The identity of the Whistleblower shall be kept confidential to the extent possible unless otherwise required by law or for purposes of any proceedings by or against the Company. Whistleblowers are cautioned that their identities may become known for reasons outside of the control of the Company.

The identity and personal information of the Whistleblower, as well as the person implicated in the Protected Disclosure, may be revealed to persons involved in investigations or any other processes deemed necessary to assist investigations.

Any other employee or person assisting in the said investigation shall also be protected to the same extent as the Whistleblower.

The protection will be in accordance with the Company only when the Whistleblower satisfies all the following conditions:

  • The Protected Disclosure is made in good faith, does not contain any false or misleading information provided knowingly, negligently, or recklessly, and is not made of ill will or with malicious intent.
  • The Whistleblower has reasonable grounds and factual evidence when reporting a wrongdoing; and
  • The Whistleblower has NOT communicated the Protected Disclosure to any other party outside the established reporting channels.
  • While it will be ensured that genuine Whistleblowers are accorded protection from any kind of unfair treatment, any abuse of this protection can warrant disciplinary action. Protection under this Policy will not mean protection from disciplinary action arising from false, frivolous, baseless, or bogus allegations made knowingly by a Whistleblower. If the investigation later reveals that the Protected Disclosure was NOT made in good faith and is with malicious intent, the Whistleblower will be subject to disciplinary action by the Company.

Whistleblowing Channels

Protected Disclosures should be factual and not speculative or in conclusion. They should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern. All Protected Disclosures must be disclosed in accordance with the procedures set out below under the Company’s Whistleblowing Policy:

Disclosure of information shall be made promptly by the whistleblower to one or more members of the Whistleblowing Committee. The whistleblower may raise their concerns by completing the prescribed Whistleblowing Form (ACE-IMS (F) CM037) and attaching any relevant supporting documents, including audio or visual evidence.

Whistleblowing Committee

Contact Information Table
Name Contact Information
Azuin Baharuddin whistleblowing@aceteamnetworks.com
Cheang Suet Wah
Eugene Benjamin Ng

It can be made through the reporting channels as follows:

Open-Door Discussion

Employees are encouraged to raise any issues directly with the Whistleblowing Committee, their immediate managers, or if an employee has reason to believe that his/ her manager is involved or has a conflict of interest, to the next level of management, Human Resources (“HR”), the Anti-Bribery Function, where available. Third parties can directly contact the appropriate business managers at the Company, the HR, the Anti-Bribery Function. The manager/ HR personnel/ Anti-Bribery Function in receipt of the report must submit the Whistleblowing Form and all relevant evidence to the Whistleblowing Committee, who maintains a centralised incident management database.

Email

Employees and third parties may anonymously report issues to the Whistleblowing committee’s email.

Post

Employees and third parties may report issues anonymously by sending a letter marked “Private & Confidential” by post, addressed to the individuals mentioned above. The mailing address is as shown below:

Pusat Perniagaan, C-G09, Jalan SS 20/27, Damansara Intan, 47400 Petaling Jaya, Selangor, Malaysia.

Investigation

Initial Assessment – The Whistleblowing Committee and Anti-Bribery Function will assess the report received from the Whistleblower and determine whether the concern raised constitutes any wrongdoings as defined in this Policy.  Additional information may be requested from the Whistleblower. The initial assessment will be conducted within seven (7) working days from the date the report is received. If the case is closed, the Whistleblowing Committee will inform the Whistleblower on the decision.

Internal Investigation – If the Whistleblowing Committee and Anti-Bribery Function is satisfied with the information of the case based on an initial assessment, he/she may form investigation team or an external independent party to carry out an investigation on the concerns raised by the Whistleblower. During the period of investigation, the accused wrongdoer may temporarily be reassigned to other department/ function or asked to take leave, pending the outcome of the investigation. The investigation shall be completed within thirty (30) to sixty (60) days, unless the complexity of the case requires an extension, in which case the Whistleblower will be informed. An investigation report and accompanying recommendations shall be submitted to the Top Management and Governing Body to decide on any consequential action. 

Communicating with Whistleblower – The Whistleblowing Committee shall inform the Whistleblower of the outcome of the investigation. However, the details of the findings will not be disclosed due to confidentiality.

Follow-up Actions – If the alleged wrongdoer is found to have committed the alleged misconduct, the Anti-Bribery Function will recommend appropriate actions to be taken against the wrongdoer, including but not limited to, employment termination or reporting the case to the police or other relevant authorities.

When forming an Internal investigation team, the Anti-Bribery Function (ABF) shall ensure that the team meets the following criteria:

  1. Independence
    • Members must not have any personal, professional, or financial interest in the case.
    • Members shall not be from the same department or reporting line as the accused wrongdoer, where possible.
  2. Competence and Expertise
    • Members shall possess the necessary knowledge, skills, and experience relevant to the nature of the allegation (e.g., HR, compliance, finance, audit, legal, operations).
    • At least one member should have experience in investigative procedures or misconduct investigations.
  3. Impartiality and Objectivity
    • Members must demonstrate fairness, neutrality, and the ability to conduct investigations without bias.
    • Members must be able to assess facts based solely on evidence.
  4. Confidentiality
    • Members must be capable of maintaining strict confidentiality of all information related to the investigation.
    • Members may be required to sign a confidentiality undertaking before commencing the investigation.
  5. Integrity and Ethical Conduct
    • Members must have a strong track record of integrity and compliance with company policies, including the Anti-Bribery and Corruption (ABC) Policy.
  6. Availability and Commitment
    • Members must be available to participate promptly and actively in the investigation process.
    • Members must commit to completing the investigation within the timeframe determined by ABF, unless extended for justified reasons.
  7. External Independent Party (if applicable)
    • Where expertise is not available internally, or where higher impartiality is required, ABF may appoint an external independent party.
    • The external party must be a qualified professional body or firm experienced in conducting internal investigations.

Internal Investigation and Follow Up

The company will respect and protect the confidentiality of the Whistleblower; and hereby gives the assurance that it will not reveal the identity of the Whistleblower to any third party or other employees and anyone not involved in the investigation or prosecution of the matter unless he or she agrees otherwise. Where concern cannot be resolved without revealing the identity of the employee raising the concern (i.e., if the evidence is required in court), a dialogue will be carried out with the employee concerned as to whether and how the matter can proceed.

The only exception to this assurance relates to any overriding legal obligation to breach confidentiality. The Company is also obligated to reveal confidential information relating to a whistleblowing report if ordered to do so by a court of law.

The Company’s assurance of confidentiality can only be completely effective if the Whistleblower, likewise, maintains confidentiality.

Application of the Whistleblower Protection Act

In June 2010, the Whistleblower Protection Act 2010 (“the Act”) was passed by Parliament and came into force on 15th December 2010. The Act protects persons making disclosures of improper conduct in the public and private sector from civil and criminal action. In addition, the Act allows for proper investigation to be carried out by an enforcement agency set up by the Federal Government, State Government or local government (“Enforcement Agency”).

If an Employee wishes to make a disclosure or report of improper conduct by any Employee pursuant to the Act, then the reporting Employee will have to make the said disclosure of improper conduct to an Enforcement Agency. Any investigations and/or actions taken thereafter would be in accordance with the Act and are independent of the procedures described in this Policy.

Whilst the Company respects the rights of Employees to directly make reports of improper conduct of an Employee to an Enforcement Agency, the Company advises and urges the Employees to report Improper Conduct of an Employee to the Company first so that the Company can remedy any wrongdoings and where applicable, institute the appropriate controls to prevent any serious damage to the Company.