Personal Data Protection Policy

1.1 It is the policy of Blue Bee Technologies Sdn Bhd ("Company") to conduct all of the Company's business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

1.2 We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which the Company operates in respect of the Company's conduct both in the members' respective local jurisdictions and abroad including the Malaysian Anti-Corruption Commission Act 2009 (“Act”).

1.3 The purpose of this policy is to:

(a)set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

(b)provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

1.4 Bribery and corruption are punishable for individuals (in certain jurisdictions by up to 10 years' imprisonment) and if we are found to have taken part in corruption we could face considerable fines (which in certain jurisdictions are unlimited), and we could be excluded from tendering for public contracts and face damage to our reputation.

 
1.5 In this policy, “third party” means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual workers, agents, sponsors, or any other person associated with the Company, or any of our subsidiaries (direct or indirect) or their employees, wherever located (collectively referred to as “employees” in this policy).

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

4.1 This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.

4.2 Bona fide hospitality and promotional or other business expenditure which seeks to improve the image of the Company, its products and services, or to establish cordial relations, is recognised as an established and important part of doing business. Examples of bona fide hospitality and promotional items would include greetings, hampers or gifts provided during festive periods as well as products involving or demonstrating local/regional expertise.

4.3 The giving or receipt of gifts is not prohibited, if the following requirements are met:

(a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

(b) it complies with applicable local law;

(c) it is given in our name, not in your name;

(d) it is appropriate in the circumstances. For example, in Malaysia and Singapore, it is customary for small gifts to be given at Lunar New Year;

 
(e) it is given openly, not secretly;

 
(f) it does not include cash or a cash equivalent (such as gift certificates or vouchers);

(g) gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of the Company’s management team; and

(h) taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time.

4.4 We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

It is not acceptable for you (or someone on your behalf) to:

(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

(b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure);

(c) accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;

(d) accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

 
(e) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

(f) engage in any activity that might lead to a breach of this policy.

6.1 We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

6.2 If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Company’s management team.

6.3 Kickbacks are typically payments made in return for a business favour or advantage. All employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by any member of the Company.

The following is a list of possible red flag scenarios that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flag scenarios while working for us, you must report them promptly to the Company’s management team:

(a) you become aware that a third party engages in, or has been accused of engaging in, improper business practices;

(b) you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;

(c) a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

(d) a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

(e) a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

(f) a third party requests an unexpected additional fee or commission to "facilitate" a service;

(g) a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

(h) a third party requests that a payment is made to "overlook" potential legal violations;

(i) a third party requests that you provide employment or some other advantage to a friend or relative;

(j) you receive an invoice from a third party that appears to be non-standard or customised;

(k) a third party insists on the use of side letters or refuses to put terms agreed in writing;

(l) you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

(m) a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or

(n) you are offered an unusually generous gift or offered lavish hospitality by a third party.