No. 1     Introduction and purpose
Reach Publishing upholds the highest standards of professional integrity and ethical conduct required of every Reach Publishing partner, employee and third parties who perform services for or on behalf of Reach Publishing.Reach Publishng and all the employees are committed to compliance with the Malaysian Anti-Corruption (MACC) Act 2009 (“MACC Act”), subsequent amendments to the Act and all guidelines issued by relevant authorities pertaining to the same.

This Policy aims to ensure that all Employees (defined below) and Associated Persons (defined below) of Reach Publishing are aware of their obligation to disclose any corruptions, briberies, conflicts of interest or similar unethical acts that they may have, and to comply with this Policy to follow highest standards of ethical conduct of business.

No. 2     Scope and coverage 
This Policy applies to all partners, employees, directors and associates of Reach Publishing, including temporary, contract staff or interns (“Employees”).

This Policy sets out the minimum standards to which all Employees of Reach Publishing must adhere to at all times.

Although this Policy is specifically written for the Employees of Reach Publishing, it expects that all parties engaged  or performing work or services for or on behalf  will comply with it in relevant part when performing such work or services. Employees and such other parties engaged  or performing work or services for or on behalf  shall be known as “Associated Persons”.

No. 3     Key requirements of MACC Act 
The main offences under the MACC Act are:

a) Soliciting or receiving gratification

• any person who solicits or receives or agree to receive (for himself or for any other person) or gives, promises or offers to any person any gratification as an inducement to or a reward for any person doing or forbearing to do anything;
• any person accepts or obtains, or agrees to the same, any gratification as an inducement or reward for doing or forbearing to do, any act in relation to his principal’s affairs or business, or for showing or forbearing to show favour or disfavour to any person in relation to his principal’s affairs or business commits an offence;

b) Offering or giving gratification

• any person who gives or agrees to give or offers any gratification to any agent as inducement or reward for doing or forbearing to do, or for having done or forbone to do the same in relation to his principal’s affairs or business, or for showing or forbearing to show favour or disfavour to any person in relation to his principal’s affairs or business;

c) Intending to deceive

• Any person who gives to an agent, or being an agent he uses with intent to deceive his principal, any receipt, account or other document in respect of which the principal is interested, and which he has reason to believe contains any statement which is false or erroneous or defective in any material particular, and is intended to mislead the principal;

d) Using office or position for gratification (abuse of position);

e) Failing to report when offered bribery

• Any person to whom any gratification is given, promised or offered in contravention of MACC 2009 shall report the same.

Upon section 17A of the MACC Act coming into effect, a commercial organization commits an offence if a person associated to the commercial organization corruptly gives, agrees to give, promises or offers to any person any gratification whether for the benefit of that person or another person with intent.

• to obtain or retain business for the commercial organization; or
• to obtain or retain an advantage in the conduct of business for the commercial organisation.

Where an offence is committed by a commercial organization, a person-

• who is its director, controller, officer or partner; or
• who is concerned in the management of its affairs,

at the time of the commission of the offence, is deemed to have committed that offence unless the person proves that the offence was committed without his consent or connivance and that he exercised due diligence to prevent the commission of the offence as he ought to have exercised, having regard to the nature of his function in that capacity and to the circumstances.

Section 17A (6) defines a person associated as a director, partner, an employee or a person who performs services for or on behalf of the commercial organisation.

In relation to anti-bribery and corruption, Reach Publishing requires all Associated Persons to:

• Act lawfully, ethically and in the public interest;
• Prohibit bribery and corruption; and
• Not tolerate illegal or unethical behavior by clients, suppliers or by public officials.

No. 4     Reach Publishing policy 
a) Anti-bribery and Corruption
All Associated Persons are not permitted to pay, offer, accept or receive a bribe in any form. Associated Persons are strictly NOT allowed to:-

• Offer, pay or give anything of value to any parties in order to obtain business or anything of benefit to Reach Publishing.
• Act illegally including bribes, blackmail, inducements, secret commissions, other rewards and similar improper actions.
• Attempt to induce any parties to do something illegal, unethical and permit any parties to violate the rules.
• Give some advantage inconsistent with law and wrongful or unlawful use of official position to procure some benefit or personal gain.
• Corruptly give, promise or offer to any person gratification with the intent to secure business or an advantage Reach Publishing.
• Offer, give, receive or solicit, directly or indirectly, anything of value to influence improperly the actions of another party.

Reach Publishing requires all Associated Persons to:

• Avoid any situation or activity that compromises, or may compromise, their judgement or ability to act in the best interest of Reach Publishing.
• Avoid being in a position where their personal interests are in conflict (or could be in conflict) with the interests or business of Reach Publishing.
• Avoid engaging in activities that will bring direct or indirect profit, commercial or business advantages to the Reach Publishing competitors
• Identify and disclose any conflicts of interest.
• Carefully manage any conflicts of interest.

b) Gifts, Hospitality and Travel
Offering or receiving any gifts, hospitality and sponsored travel that may be perceived to unfairly influence a business relationship must be strictly avoided at all time. They should only be provided and received where they are appropriate, consistent with reasonable business practice, and would not be perceived to have any improper influence on the recipient.

All Associated Persons should use good judgment in offering or receiving the above-mentioned. In determining whether a specific gift item lies within the bounds of acceptable business practice, Associated Persons are encouraged to discuss the issue with HR or management.

All Associated Persons must not request, accept, offer or provide gifts or hospitality designed to induce, support or reward improper conduct in connection with any business or anticipated future business involving Reach Publishing.

Associated Persons must never avoid their obligation to report or seek approval for any business gift by paying personally for it in circumstances where they would otherwise be required to report and/or seek approval for it.

All giving of Gifts, Hospitality and sponsored Travel must get necessary approval from Superior and the Firm.

All receipt of Gifts, Hospitality and sponsored Travel must be submitted and approved by HR or management. All registration and/or declaration must be made in the Associated Persons’ best interests.

In addition, when giving and/or receipt of Gifts, Hospitality, sponsored Travel or any other benefit directly or indirectly to or by the Associated Persons, the Associated Persons must make sure that it:

• is aimed at nothing more than general relationship building;
• could not be perceived as an attempt to gain influence in respect of any particular matter;
• is lawful in the country in which made.

Management of Reach Publishing