Anti-Bribery & Anti-Corruption Policy

Anti-Bribery & Anti-Corruption Policy

(Governance Framework of the IPP Entities)

1. Policy Statement

This Policy applies to the following entities (collectively referred to as the “IPP Entities”):

  • IPP Global Wealth Sdn Bhd (IPPGW) – Strategic coordination platform
  • IPP Financial Advisers Sdn Bhd (IPPFA) – Licensed financial planning entity in Malaysia
  • IPP Wealth Managers Ltd (IPPWM) – Labuan licensed insurance brokerage entity

Each entity is a separate legal entity and operates within its respective regulatory framework.

The IPP Entities adopt a strict zero-tolerance approach towards bribery and corruption in any form. We are committed to conducting business with integrity, transparency, and accountability, in accordance with:

  • The Malaysian Anti-Corruption Commission Act 2009 (including Section 17A corporate liability provisions)
  • Applicable Labuan and other regional regulatory requirements
  • Recognised principles of good corporate governance

All directors, employees, representatives, associates, and service providers are expected to uphold the highest ethical standards.

2. Definition of Bribery

For the purposes of this Policy:

Bribery refers to any act that would constitute an offence under applicable anti-corruption legislation, including the giving, offering, soliciting, or receiving of any form of gratification intended to improperly influence a decision or action.

Gratification includes money, gifts, loans, commissions, rewards, employment opportunities, contracts, services, favours, or any other benefit of value.

3. Scope of Application

This Policy applies to:

  • Members of the Board of Directors
  • Senior management
  • Employees and representatives
  • Associates and introducers
  • Service providers and professional partners acting on behalf of the IPP Entities

All parties are expected to adhere to equivalent anti-bribery standards.

4. Conflict of Interest

The IPP Entities are committed to managing actual and potential conflicts of interest fairly and transparently.

Appropriate organisational and administrative measures are maintained to:

  • Identify and manage conflicts of interest
  • Prevent misuse of confidential information
  • Ensure fair treatment of clients
  • Require disclosure of external engagements and material interests

Where a conflict arises, it must be disclosed promptly and managed appropriately.

5. Gifts and Entertainment

Business courtesies must never influence, or appear to influence, professional judgement.

General Principles:

  • No gift, hospitality, or entertainment should be offered or accepted if it creates an expectation of favourable treatment.
  • Cash or cash equivalents are strictly prohibited.
  • Gifts or entertainment exceeding reasonable or nominal value must be declared in accordance with internal procedures.
  • Excessive or inappropriate hospitality is not permitted.

Overseas holidays, inducement trips, or events where the host is absent are considered inappropriate.

6. Facilitation Payments

The IPP Entities prohibit facilitation payments, defined as unofficial payments made to secure or expedite routine governmental or administrative actions.

Any request for such payments must be reported immediately to management.

7. Donations and Sponsorships

Donations and sponsorships must:

  • Comply with applicable laws
  • Be transparently recorded
  • Not be used to conceal improper payments

Political contributions using corporate funds are prohibited unless expressly approved by the relevant Board and permitted by law.

8. Financial and Non-Financial Controls

The IPP Entities maintain internal controls to prevent and detect bribery risks, including:

  • Segregation of duties and approval matrices
  • Due diligence on service providers and professional partners
  • Fit and proper assessments for key personnel
  • Risk-based monitoring processes

Service providers acting on behalf of the IPP Entities may be required to contractually confirm adherence to anti-bribery standards.

9. Governance Oversight

Senior management and the respective Boards are responsible for:

  • Periodic review of anti-bribery controls
  • Conducting corruption risk assessments
  • Ensuring clear reporting lines for compliance oversight
  • Reviewing audit findings and remedial actions

Continuous improvement of integrity frameworks forms part of corporate governance responsibilities.

10. Record Keeping

Accurate and transparent financial and administrative records must be maintained in accordance with applicable laws and internal retention policies.

No undisclosed or unrecorded accounts are permitted.

11. Training and Awareness

The IPP Entities promote awareness of anti-bribery principles through induction and periodic training programmes.

Personnel are expected to understand the legal and disciplinary consequences of non-compliance.

12. Reporting and Whistleblowing

Suspected bribery, corruption, or misconduct may be reported confidentially through designated compliance channels.

Reports made in good faith will be investigated appropriately. Retaliation against whistleblowers is strictly prohibited.

Contact:
Email: governance@ippgw.com
(Or separate entity-specific compliance emails where applicable)

13. Disciplinary Action

Breaches of this Policy may result in disciplinary action, termination of engagement, or referral to regulatory or enforcement authorities where appropriate.

14. Amendments

The IPP Entities reserve the right to amend this Policy. Any material deviation requires approval by the relevant Board.