Anti-Bribery & Corruption Policy

1. Introduction

Malaysian Global Innovation & Creative Centre Berhad (“MaGIC”) has a zero-tolerance approach to bribery and corruption. MaGIC is committed to combating bribery and corruption in all our dealings and is resolved in upholding integrity, ensuring ethical business conduct and professionalism wherever MaGIC operates.

Any employee or director or person associated with MaGIC who is engaged in any corrupt practices shall be subjected to disciplinary action in accordance with MaGIC’s policies, procedures, directives and guidelines or terms of contract and agreements.


2. Objective

The objective of this Policy is to set out the responsibilities of MaGIC in observing and upholding MaGIC’s position on combatting bribery and corruption, as well as to provide information and guidance to those working for MaGIC on how to recognize and deal with bribery and corruption issues that may arise in the course of business.

3. Scope

This Policy is applicable to ALL employees and directors of MaGIC. MaGIC also expects that person associated performing work or services with, for or on behalf of MaGIC shall comply with the relevant parts of the Policy when performing such work or services.

4. Definitions

In this Policy, unless the context otherwise requires, the following terms shall have the meanings respectively assigned to them:

4.1    “bribery” means the act of SOLICITING, GIVING, OFFERING, ACCEPTING OR RECEIVING GRATIFICATION, directly or indirectly, to/from a person in authority either in the form of money, services or valuable goods as an inducement or reward to do or not to do an act in relation to the person’s principal affairs. Bribery and corruption are closely related. However, “corruption” has a wider definition (as set out below);

4.2   “person associated” refers to external parties with whom MaGIC has or plans to establish some form of business relationship. This includes, and is not limited to, partners, programme participants, contractors, sub-contractors, suppliers, vendors, consultants, agents, representatives, intermediaries, and others performing work or services with, for or on behalf of MaGIC;

4.3   “corruption” includes:
(a)  any action which would be considered as an offence of giving or receiving gratification under the MACC Act 2009;
(b)  any acts of extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering; and
(c) all deeds or behaviours that are defined as “corrupt act” under the relevant laws of each jurisdiction where MaGIC operates;

4.4   “directors” means the directors of the companies under MaGIC, and includes all independent and non-independent directors;

4.5   “employee” means any individual who is in the employment of MaGIC, whether on permanent or temporary employment basis or on secondment;

4.6   “MACC Act” refers to the Malaysian Anti-Corruption Commission Act 2009 (Act 694)and shall include all subsequent revisions and amendments thereto;

4.7   “Organizational Anti-Corruption Plan” (OACP) refers to a mandatory initiative under the National Anti-Corruption Plan (NACP) to ensure an organisation achieves the NACP’s strategic objective of Greater Corporate Entities Resilience Against theThreat of Corruption. OACP is formulated with the aim of assisting and helping an organisation in combating bribery and corruption. It also outlines the appropriate resources and reasonable timeline towards achieving the strategic objectives.

4.8 “Policy” refers to this Anti-Bribery and Corruption Policy;

4.9 “MaGIC” is the organisation name referred to Malaysian Global Innovation &Creativity Centre Berhad.


5. Our Principle
5.1 MaGIC conducts all business in an honest and ethical manner. MaGIC takes a zero-tolerance approach to bribery and corruption and is committed to act professionally,fairly and uphold integrity in all relationships and business dealings wherever MaGICoperates. MaGIC implements and enforces effective control systems to counterbribery and corruption. 5.2 MaGIC is committed to adhere strictly to the relevant laws in relation to bribery andcorruption including but not limited to the MACC Act, the Penal Code (Act 574) andthe Anti-Money Laundering and Anti-Terrorism Financing and Proceeds of UnlawfulActivities Act 2001. 5.3 MaGIC is committed to develop and maintain a detailed OACP to ensure that itspolicy of zero tolerance is fully adhered to and implemented across all sections ofthe organization.

6. Bribery & Corruption
All forms of bribery and corruption are strictly prohibited. MaGIC will not tolerate any formof bribery or corruption. The participation or engagement of an employee or a director,whether directly or indirectly, in any act of bribery or corruption could result in disciplinaryaction being taken and, ultimately, termination and dismissal. 4 This Policy also applies to business dealings with person associated with MaGIC. Whereany person associated with MaGIC is found to be, or suspected by MaGIC to be, involvedin any act of bribery or corruption, MaGIC shall reassess its relationship with such personassociated and take all such actions it deems necessary to uphold its commitment againstbribery and corruption, which may include the suspension or termination of any furtherdealings with such person associated with MaGIC. Acts of corruption under the MACC Act are punishable by imprisonment for a term of upto twenty (20) years and a fine of RM10,000.00 or not less than five (5) times the value ofthe gratification whichever is higher. Based on the MACC Act, if a person associated with a commercial organisation commitsan act of corruption with the intent to obtain or retain business or a business advantage forthe said commercial organisation, the commercial organization and its directors and key management personnel may be held LIABLE for not preventing the corrupt acts fromhappening. Upon conviction, the penalty for the offence shall if convicted be liable to a fineof not less than ten (10) times the sum of gratification involved, or RM1 million, whicheveris higher, or an imprisonment term of up to twenty (20) years, or both. Below are some forms of bribery and corruption:

6.1  Gratification,
This refers to the act to please or to satisfy. Gratification may come in the form ofmoney, donation, gift, loan, fee, reward, valuable security, property or interest inproperty of any description whether movable or immovable, finance benefit, or anyother similar advantage as stated in the MACC Act. 6.2  Political Contributions A political contribution is a contribution or donation made to a politician or a politicalcampaign or a political party. Political contributions can be a form of bribery if it isused to induce a party to engage in improper or unlawful conduct. 6.3  Facilitation Payments A facilitation payment is an unofficial payment in cash or in-kind (e.g. liquor,cigarettes, etc.) made to Government Officials or any other entity intended to‘facilitate’, secure or expedite the performance of a routine action (e.g. clearingcustoms, processing visas, scheduling inspections, etc.). 6.4  Conflict of Interest This refers to a form of conflict between employee’s or director’s own interest andthe interest of the employer. A conflict of interest will arise where an employee’s ordirector’s ability to perform his or her duties may be adversely affected by an outsideappointment, relationship or activity whereby the employee or director can usehis/her position/power for the benefit of himself/herself or for his/her relative orassociate. It is the duty of the employee or director to report any actual, potential orperceived Conflict of Interest (COI). 6.5  Kickback A kickback is a form of negotiated bribery in which a commission is paid to the bribe-taker in exchange for services rendered. Generally, the remuneration (money,money in kind, promise, goods, or services handed over) is negotiated ahead oftime.
6.6  Forgery of Document and False Claim Any person or agent who intends to deceive or mislead the principal with thesubmitted documents that contain statement, which is fictitious, false or erroneousor defective in any material form commits an offence under the MACC Act. 6.7  Abuse of Power This refers to an act whereby any employee or director uses his position or the officein making decision or acting for the benefit of himself, his relative or associate.

7. Gifts, Entertainment and Hospitality
7.1 Please refer to MaGIC’s Gifts and Entertainment Policy. Giving and receiving of allsuch gifts and entertainment must be exercised with good judgement, be for genuinepurposes without the intention of creating any improper advantage, given in the ordinary course of business and comply with MaGIC’s Gifts and EntertainmentPolicy. 7.2 Hospitality may be offered and accepted as part of business networking as well asa measure of goodwill towards the recipients. All acts of hospitality must:
7.2.1  be made in good faith and exercised with good judgement; 7.2.2  not influence/implicate business decisions or trigger any prohibitions under law; and
7.2.3  be in line with MaGIC’s Code of Conduct and all other policies of MaGIC.

7.3 Each department/ unit shall ensure that all employees and directors are aware andadhere to the MaGIC’s Code of Conduct & Gifts and Entertainment Policy.

8. Political Contributions
8.1  MaGIC does not make or offer contributions whether monetary or in-kind to anypolitical party, political party officials or candidates for public offices. However,MaGIC may make contributions which are permissible under applicable law, subjectto the approval of the MaGIC Board of Directors (Board) or MaGIC Chief ExecutiveOfficer (CEO). 8.2  MaGIC does not prohibit an employee or director from participating in politicalactivity outside of office hours. Employee or director is free to contribute to anypolitical party solely on their own goodwill and such contribution shall not bereimbursed by MaGIC.

9. Facilitation Payment and Kickbacks
9.1  It is prohibited to offer, promise, make, request and accept facilitation payments orkickbacks of any kind. 9.2  Employees are expected to notify their immediate superior when encountered withany requests for a facilitation payment or kickbacks. 6 9.3 Each department/unit shall ensure that:
9.3.1  all payments to be made to third parties must be made in good faith andcomply with all applicable laws and regulations; 9.3.2  payments to government officials or authorities must be made inaccordance to official rates published by the government, for which thepayment is made into a government account and for which a receipt isgiven; and 9.3.3  a report is to be escalated to the Senior Manager, Integrity & RiskManagement if the employee is requested or collaborated to pay anyfacilitation payment or kickback.

9.4 Payment that is made in the belief that life, health and safety may be in imminentdanger is not a facilitation payment. However, such incident must be reportedimmediately to the Senior Manager, Integrity & Risk Management.

10.Prevention and Mitigation of Bribery and Corruption Risk

10.1 Eachdepartment/unitshallensurethat: 10.1.1  any potential bribery and corruption risk in their operation is being identifiedand assessed; 10.1.2  adequate procedures/controls to prevent and mitigate the bribery andcorruption risk are in place; and 10.1.3  employees that may be exposed to bribery and corruption in their workenvironment must be identified and periodically rotated as well as attendregular anti bribery and corruption training.

11. Due Diligence

11.1 Department/unit are required to establish key considerations or criteria forconducting due diligence on any relevant parties or personnel (such as employees,agents, vendors, contractors, partners and consultants) prior entering intoformalised relationship. Method may include background checks on the person orentity, a documented verification process or conducting interviews with the personto be appointed to key role where corruption risk has been identified.

12. Disclosure of Conflict of Interest (COI)

12.1  Allemployeesanddirectorsshallhavethedutytodeclareanyoftheirinterestarisingfrom their internal or external appointments, relationships or activity. COI can arisewhen employees and directors have interest that makes it difficult to perform theirspecific role objectively. 12.2  Eachdepartment/unitshallensurethat:
12.2.1  Employee adhere to MaGIC’s Code of Conduct; 12.2.2  employees are aware of the need to declare any actual, perceived or potential interest in the COI form to People & Capability Development; 12.2.3  line managers are required to record actions taken to mitigate the conflict reported by their employees; 12.2.4  any actual, perceived or potential interest that cannot be resolved in that manner is to be escalated to the Senior Manager, Integrity & RiskManagement;
12.2.5  CEO is required to declare any actual, perceived or potential conflicts to theChairman of the Board; 12.2.6  Directors are required to declare any actual, perceived or potential conflictsto the Chairman of the Board; and 12.2.7  Chairman of the Board is required to declare any actual, perceived orpotential conflicts to the Chairman of the Board Audit Committee.

1. Introduction
Malaysian Global Innovation & Creative Centre Berhad (“MaGIC”) has a zero-tolerance approach to bribery and corruption. MaGIC is committed to combating bribery and  corruption in all our dealings and is resolved in upholding integrity, ensuring ethical  business conduct and professionalism wherever MaGIC operates.  
Any employee or director or person associated with MaGIC who is engaged in any corrupt  practices shall be subjected to disciplinary action in accordance with MaGIC’s policies,  procedures, directives and guidelines or terms of contract and agreements.

2. Objective
The objective of this Policy is to set out the responsibilities of MaGIC in observing and  upholding MaGIC’s position on combatting bribery and corruption, as well as to provide  information and guidance to those working for MaGIC on how to recognize and deal with  bribery and corruption issues that may arise in the course of business.

3. Scope
This Policy is applicable to ALL employees and directors of MaGIC. MaGIC also expects  that person associated performing work or services with, for or on behalf of MaGIC shall comply with the relevant parts of the Policy when performing such work or services.  

4. Definitions
In this Policy, unless the context otherwise requires, the following terms shall have the  meanings respectively assigned to them:

4.1 “bribery” means the act of SOLICITING, GIVING, OFFERING, ACCEPTING OR  RECEIVING GRATIFICATION, directly or indirectly, to/from a person in authority  either in the form of money, services or valuable goods as an inducement or reward  to do or not to do an act in relation to the person’s principal affairs. Bribery and  corruption are closely related. However, “corruption” has a wider definition (as set  out below);  

4.2 “person associated” refers to external parties with whom MaGIC has or plans to  establish some form of business relationship. This includes, and is not limited to, partners, programme participants, contractors, sub-contractors, suppliers, vendors,  advisors, consultants, agents, representatives, intermediaries, and others performing work or services with, for or on behalf of MaGIC;

4.3 “corruption” includes:

(a) any action which would be considered as an offence of giving or receiving  gratification under the MACC Act 2009;

(b) any acts of extortion, collusion, breach of trust, abuse of power, trading under  influence, embezzlement, fraud or money laundering; and

(c) all deeds or behaviours that are defined as “corrupt act” under the relevant  laws of each jurisdiction where MaGIC operates;

4.4 “directors” means the directors of the companies under MaGIC, and includes all  independent and non-independent directors;

4.5 “employee” means any individual who is in the employment of MaGIC, whether on  permanent or temporary employment basis or on secondment;

4.6 “MACC Act” refers to the Malaysian Anti-Corruption Commission Act 2009 (Act 694) and shall include all subsequent revisions and amendments thereto;

4.7 “Organizational Anti-Corruption Plan” (OACP) refers to a mandatory initiative under  the National Anti-Corruption Plan (NACP) to ensure an organisation achieves the  NACP’s strategic objective of Greater Corporate Entities Resilience Against the  Threat of Corruption. OACP is formulated with the aim of assisting and helping an  organisation in combating bribery and corruption. It also outlines the appropriate  resources and reasonable timeline towards achieving the strategic objectives.

4.8 “Policy” refers to this Anti-Bribery and Corruption Policy;

4.9 “MaGIC” is the organisation name referred to Malaysian Global Innovation &  Creativity Centre Berhad.

5. Our Principle
5.1 MaGIC conducts all business in an honest and ethical manner. MaGIC takes a zero tolerance approach to bribery and corruption and is committed to act professionally,  fairly and uphold integrity in all relationships and business dealings wherever MaGIC operates. MaGIC implements and enforces effective control systems to counter  bribery and corruption.

5.2 MaGIC is committed to adhere strictly to the relevant laws in relation to bribery and  corruption including but not limited to the MACC Act, the Penal Code (Act 574) and  the Anti-Money Laundering and Anti-Terrorism Financing and Proceeds of Unlawful  Activities Act 2001.

5.3 MaGIC is committed to develop and maintain a detailed OACP to ensure that its  policy of zero tolerance is fully adhered to and implemented across all sections of  the organization.

6. Bribery & Corruption
All forms of bribery and corruption are strictly prohibited. MaGIC will not tolerate any form of bribery or corruption. The participation or engagement of an employee or a director,  whether directly or indirectly, in any act of bribery or corruption could result in disciplinary  action being taken and, ultimately, termination and dismissal.

This Policy also applies to business dealings with person associated with MaGIC. Where  any person associated with MaGIC is found to be, or suspected by MaGIC to be, involved  in any act of bribery or corruption, MaGIC shall reassess its relationship with such person associated and take all such actions it deems necessary to uphold its commitment against  bribery and corruption, which may include the suspension or termination of any further dealings with such person associated with MaGIC.

Acts of corruption under the MACC Act are punishable by imprisonment for a term of up  to twenty (20) years and a fine of RM10,000.00 or not less than five (5) times the value of  the gratification whichever is higher.

Based on the MACC Act, if a person associated with a commercial organisation commits an act of corruption with the intent to obtain or retain business or a business advantage for  the said commercial organisation, the commercial organization and its directors and key  management personnel may be held LIABLE for not preventing the corrupt acts from  happening. Upon conviction, the penalty for the offence shall if convicted be liable to a fine  of not less than ten (10) times the sum of gratification involved, or RM1 million, whichever  is higher, or an imprisonment term of up to twenty (20) years, or both.  
Below are some forms of bribery and corruption:

6.1 Gratification,
This refers to the act to please or to satisfy. Gratification may come in the form of  money, donation, gift, loan, fee, reward, valuable security, property or interest in  property of any description whether movable or immovable, finance benefit, or any  other similar advantage as stated in the MACC Act.  

6.2 Political Contributions
A political contribution is a contribution or donation made to a politician or a political  campaign or a political party. Political contributions can be a form of bribery if it is  used to induce a party to engage in improper or unlawful conduct.  

6.3 Facilitation Payments
A facilitation payment is an unofficial payment in cash or in-kind (e.g. liquor,  cigarettes, etc.) made to Government Officials or any other entity intended to  ‘facilitate’, secure or expedite the performance of a routine action (e.g. clearing  customs, processing visas, scheduling inspections, etc.).

6.4 Conflict of Interest
This refers to a form of conflict between employee’s or director’s own interest and  the interest of the employer. A conflict of interest will arise where an employee’s or  director’s ability to perform his or her duties may be adversely affected by an outside  appointment, relationship or activity whereby the employee or director can use  his/her position/power for the benefit of himself/herself or for his/her relative or  associate. It is the duty of the employee or director to report any actual, potential or  perceived Conflict of Interest (COI).

6.5 Kickback
A kickback is a form of negotiated bribery in which a commission is paid to the bribe taker in exchange for services rendered. Generally, the remuneration (money,  money in kind, promise, goods, or services handed over) is negotiated ahead of  time.

6.6 Forgery of Document and False Claim
Any person or agent who intends to deceive or mislead the principal with the  submitted documents that contain statement, which is fictitious, false or erroneous  or defective in any material form commits an offence under the MACC Act.  

6.7 Abuse of Power
This refers to an act whereby any employee or director uses his position or the office  in making decision or acting for the benefit of himself, his relative or associate.

7. Gifts, Entertainment and Hospitality
7.1 Please refer to MaGIC’s Gifts and Entertainment Policy. Giving and receiving of all  such gifts and entertainment must be exercised with good judgement, be for genuine  purposes without the intention of creating any improper advantage, given in the  ordinary course of business and comply with MaGIC’s Gifts and Entertainment  Policy.

7.2 Hospitality may be offered and accepted as part of business networking as well as  a measure of goodwill towards the recipients. All acts of hospitality must: 7.2.1 be made in good faith and exercised with good judgement;

7.2.2 not influence/implicate business decisions or trigger any prohibitions under  law; and

7.2.3 be in line with MaGIC’s Code of Conduct and all other policies of MaGIC.

7.3 Each department/ unit shall ensure that all employees and directors are aware and  adhere to the MaGIC’s Code of Conduct & Gifts and Entertainment Policy.

8. Political Contributions
8.1 MaGIC does not make or offer contributions whether monetary or in-kind to any  political party, political party officials or candidates for public offices. However,  MaGIC may make contributions which are permissible under applicable law, subject  to the approval of the MaGIC Board of Directors (Board) or MaGIC Chief Executive  Officer (CEO).

8.2 MaGIC does not prohibit an employee or director from participating in political  activity outside of office hours. Employee or director is free to contribute to any  political party solely on their own goodwill and such contribution shall not be  reimbursed by MaGIC.

9. Facilitation Payment and Kickbacks
9.1 It is prohibited to offer, promise, make, request and accept facilitation payments or  kickbacks of any kind.

9.2 Employees are expected to notify their immediate superior when encountered with  any requests for a facilitation payment or kickbacks.

9.3 Each department/unit shall ensure that:

9.3.1 all payments to be made to third parties must be made in good faith and  comply with all applicable laws and regulations;

9.3.2 payments to government officials or authorities must be made in  accordance to official rates published by the government, for which the  payment is made into a government account and for which a receipt is  given; and

9.3.3 a report is to be escalated to the Senior Manager, Integrity & Risk  Management if the employee is requested or collaborated to pay any facilitation payment or kickback.  

9.4 Payment that is made in the belief that life, health and safety may be in imminent  danger is not a facilitation payment. However, such incident must be reported  immediately to the Senior Manager, Integrity & Risk Management.

10. Prevention and Mitigation of Bribery and Corruption Risk
10.1 Each department/unit shall ensure that:

10.1.1 any potential bribery and corruption risk in their operation is being identified and assessed;

10.1.2 adequate procedures/controls to prevent and mitigate the bribery and  corruption risk are in place; and

10.1.3 employees that may be exposed to bribery and corruption in their work  environment must be identified and periodically rotated as well as attend regular anti bribery and corruption training.  

11. Due Diligence
11.1 Department/unit are required to establish key considerations or criteria for  conducting due diligence on any relevant parties or personnel (such as employees,  agents, vendors, contractors, partners and consultants) prior entering into  formalised relationship. Method may include background checks on the person or
entity, a documented verification process or conducting interviews with the person  to be appointed to key role where corruption risk has been identified.  

12. Disclosure of Conflict of Interest (COI)  
12.1 All employees and directors shall have the duty to declare any of their interest arising  from their internal or external appointments, relationships or activity. COI can arise  when employees and directors have interest that makes it difficult to perform their  specific role objectively.  

12.2 Each department/ unit shall ensure that:

12.2.1 Employee adhere to MaGIC’s Code of Conduct;

12.2.2 employees are aware of the need to declare any actual, perceived or  potential interest in the COI form to People & Capability Development;

12.2.3 line managers are required to record actions taken to mitigate the conflict  reported by their employees;

12.2.4 any actual, perceived or potential interest that cannot be resolved in that  manner is to be escalated to the Senior Manager, Integrity & Risk  Management;

12.2.5 CEO is required to declare any actual, perceived or potential conflicts to the  Chairman of the Board;  

12.2.6 Directors are required to declare any actual, perceived or potential conflicts  to the Chairman of the Board; and

12.2.7 Chairman of the Board is required to declare any actual, perceived or  potential conflicts to the Chairman of the Board Audit Committee.  

13. Record keeping
13.1 MaGIC shall keep financial records and have adequate internal controls in place  which will be kept as evidence to proof the business reasons for making payments  to third parties.

13.2 All employees and directors are to ensure all expenses claims relating to hospitality,  gifts or entertainment incurred to third parties are submitted in accordance with the  Limit of Authority (LOA).

13.3 All accounts, invoices, memoranda and other documents and records relating to  dealings with third parties, such as customers, suppliers, contractors, agents and  business partners, should be prepared and maintained with accuracy and  completeness. No accounts must be kept “off-book” to facilitate or conceal improper  payments.

13.4 All financial records must be retained and must not be destroyed as required by  prevailing laws.

14. Reporting Corrupt Practices
14.1 Any employee or director or person associated who knows of, or suspects, a  violation of this policy or any other policies, procedures, guidelines, code of conduct,  rules and regulations that related to:

• Giving/offering bribery;
• Accepting/soliciting bribery;
• Using office for gratification/abuse of power;
• Forgery of claim/false declaration;
• Facilitation payment/kickbacks;
• Conflict of interest;
• Gift, entertainment and hospitality;
• Improper/unlawful political contribution; or
• Any form of misconduct and non-compliance that is serious in nature and/or have  grave repercussion
is required to whistle blow or report the concerns through the mechanism set out  under MaGIC’s Whistle Blowing Policy & Procedure.

14.2 All bribery and corruption cases, including suspected attempts to commit bribery or  corruption, must be reported to the to the Whistle Blowing channel or to Senior  Manager, Integrity & Risk Management:
E-mail : wecare@mymagic.my

14.3 If the report of concern involves the Senior Manager, Integrity & Risk Management or any members of the Integrity & Risk Management unit the report can be  channelled to the CEO.

14.4 No individual will be discriminated against or suffer any sort of manner of retaliation  for raising genuine concerns or reporting in good faith any violations or suspected  violations of this Policy. All reports will be treated in strict confidentially.

14.5 MaGIC will report to the relevant authority such as the Malaysian Anti-Corruption  Commission (MACC) or Polis Diraja Malaysia (PDRM) if there is reasonable belief  that such act of bribery and corruption has been committed.  

15. Responsibility
The Board has oversight of this Policy and the Chief Executive Officer (CEO), Senior Vice  President, Vice President, Senior Manager and all employees are responsible for ensuring  compliance with this Policy.  

16. Training & Communication
16.1 All employees, directors and person associated with the organization are required  to be familiar with and comply with this Policy.

16.2 All employees and directors operating in areas that are perceived as high risk will  receive regular, relevant training on how to implement and adhere to this Policy.  

16.3 MaGIC’s zero-tolerance approach to corruption and bribery shall be communicated  to all person associated with the organization at the outset of business relationships and as appropriate thereafter.

17. Monitoring & Review
17.1 All employees and directors are responsible for the implementation of this Policy and  ensure that any suspected danger or wrongdoing is to be disclosed.

17.2 The Policy shall be reviewed periodically to assess its effectiveness, and in any  event, at least once every three (3) years.

17.3 Internal control systems and procedures will be subjected to regular audits as an  assurance that adequate procedures are in place for combating bribery and  corruption.