i. INTRODUCTION
The Behn Meyer Group is committed to doing business ethically, which means free from bribery and corruption and in total compliance with the law. Therefore, the company adopts a zero-tolerance policy towards bribery and corrupt activities in all its shapes and forms. To this end, this Anti-Bribery and Corruption Policy has been drafted as a guide for our global group of companies.
This policy shall apply to all employees, directors as well as current and future business associates of the Behn Meyer Group and their representatives, even outside of working hours.
Applicable Local Law
This is a general policy that applies across the Behn Meyer Group. However, as the laws on bribery and corruption may vary from country to country, the policy incorporating the enacted laws of each country is available separately. Where there is any conflict between this policy and any local law or policy, the latter shall prevail.
For the comprehensive policy of each country:
Malaysia
https://www.behnmeyer.com/behn-meyer-abc-policy-my
Indonesia
https://www.behnmeyer.com/behn-meyer-abc-policy-id
Singapore
https://www.behnmeyer.com/behn-meyer-abc-policy-sg
Vietnam
https://www.behnmeyer.com/behn-meyer-abc-policy-vn
Thailand
https://www.behnmeyer.com/behn-meyer-abc-policy-th
ii. PURPOSE
iii. PENALTY FOR NON-COMPLIANCE
Any employee or director of the Behn Meyer Group who violates this policy or helps someone else violate it may be subject to disciplinary action, which may include dismissal and civil action for any losses incurred by the company.
If a business associate is found to be in violation of the same, the business relationship may be terminated, and civil action may be taken for any losses incurred by Behn Meyer.
The Behn Meyer Group may also report any violations of the law to the authorities.
iv. COMPLIANCE COMMITTEE
v. MAINTAINING PROPER RECORDS
Everyone has the responsibility to keep a paper trail (or paperwork) of the things described in this policy, especially where decisions are made and money is involved. This includes financial and non-financial activities, policies and procedures, agreements, declarations or undertakings, meeting minutes, operational data, plans, analyses, spreadsheets and forecasts. Financial transactions, in particular, must be properly and accurately recorded and all book entries supported with proper documentation.
When requested by the Compliance Committee or by the company’s central depository, they must be able to present this paperwork within a reasonable timeframe. The respective heads of departments have the additional responsibility to conduct periodic checks to ensure that records have been kept in a proper manner.
Confidential or sensitive paperwork must be kept in a confidential and secure place that is only accessible to designated employees. If any paperwork is to be destroyed, it must first be approved by the head of department, and then destroyed in a lawful way.
vi. REVIEW & REVISIONS
The Compliance Committee will review and update this policy at least once every 3 years to ensure it is effective, relevant and up to date. Everyone is expected to comply with any future changes that are made to this policy.
vii. QUERIES & FEEDBACK
Any queries regarding this policy or suggestions for improvement may be sent to the following e-mail address:
Malaysia
antibribery@behnmeyer.com.my (Compliance Committee)
Indonesia
antibribery@behnmeyer.co.id
Philippines
antibribery@behnmeyer.com.ph
Singapore
antibribery@behnmeyer.com.sg
Vietnam
antibribery@behnmeyer.com.vn
*The contact details for other countries will be listed here as they are made available.
The Behn Meyer Group does not allow for any form of bribery or corrupt activities.
What is bribery? Anything that is offered in order to influence a decision, whether in person or through a third party, is considered a bribe.
All employees, directors and business associates under the Behn Meyer Group are prohibited from engaging in any form of bribery. Our business associates must also be clear of any convictions or suspicions involving bribery, corruption or fraud, and further ensure that they have their own methods of dealing with bribery and corruption within their companies and dealings. If any of their representatives is found to have been convicted or subject to investigation, enquiry or enforcement, they must make a declaration to the Compliance Committee immediately.
The Behn Meyer Group will not punish anyone who refuses to pay or receive bribes or engage in corrupt activities, even if it results in us losing business.
All employees, directors and business associates of the Behn Meyer Group must act in Behn Meyer’s best interest rather than their own interest or the interests of a third party (such as a family member) when they represent Behn Meyer.
What is a conflict of interest? A conflict of interest is a situation in which one’s personal relationship may cause the appearance that biased or unfair treatment may be given out due to the nature of that relationship, leading to the undermining of the company’s interest or the company being placed in a disadvantageous position.
The Behn Meyer Group prohibits any employee or director from engaging in any activity that may come into conflict with the company’s business interests, negatively affect its reputation or relationship with others, or interfere with the individual’s duties as an employee or director of the Behn Meyer Group. All employees and directors must not use their positions, influence, company assets or resources for their personal gain or the improper benefit of others.
Examples
While it is not possible to list every situation that represents a conflict of interest, the following can be used as a guide:
Indonesia
whistleblower@behnmeyer.co.id
Singapore
whistleblower@behnmeyer.com.sg
Full policy available for download: