GUOCOLAND HOTELS PTE. LTD
Anti-Bribery and Corruption Policy

Why do we have this Policy?
Guocoland Hotels Pte. Ltd. (“GLH”) commit to conducting business ethically in compliance with the Malaysian Anti-Corruption Commission Act 2009 and all applicable anti-bribery and corruption laws of every country in which GLH operates.

GLH does not condone any form of bribery and corruption. This Anti-Bribery Corruption Policy (“ABC Policy”), which must be read in conjunction with the Group’s Code of Ethics, serves to provide guidance on how to prevent, deal with and combat bribery and corrupt activities and issues that may arise in the course of business.

Who does this Policy apply to?
This ABC Policy applies to all employees, directors (executive and non-executive) and any person who performs  services for or on behalf of GLH, which includes contractors, subcontractors, consultants, suppliers, agents, intermediaries and representatives of GLH (collectively, “Applicable Persons”).

What must you NOT do?
Anti-bribery and corruption laws make it illegal for any person to:
(a) give, promise or offer to give to any person, whether for the benefit of that person or of another person; or
(b) solicit, receive or agree to receive for himself or for any other person,

any gratification as an inducement, reward to do or forbear from doing anything in respect of any matter or transaction, whether actual, proposed or likely to take place.

Accordingly, you shall not at any time:

•Offer, promise or give anything of value in order to obtain or retain any personal or business advantage.
•Request or accept anything of value that might influence your objectivity in carrying out your employment / business.

“Things of value” that could be perceived as bribery or corruption can take many forms (including monetary, services, donation, employment, discounts or in kind).

The laws on anti-bribery and corruption are very wide and cover activities carried out or merely offered, whether directly or indirectly.

For example, Mr. X is an employee in the Sales Department of one of the hotels owned by GLH and is charged with an offence for making improper payments to an official. Mr. X will be held liable if:

• Carried out, offered, promised or agreed. Mr. X made such improper payments, or merely offered to make such payment even though such payment was subsequently not made; it is enough that the payment was offered.

• Directly or indirectly. The improper payment was made by him directly to the official or through a third party agent.
The above is only an example to emphasise that a mere offer or a bribe made through a third party is sufficient to constitute a breach of the anti-bribery and corruption laws.

There is no difference whether the bribery or corrupt activity is carried out within or from
Malaysia, or otherwise.

What are the penalties?
Engagement in any bribery or corrupt practices or activities will result in severe negative consequences. The Applicable Person may face disciplinary actions by the employers and prosecutions by the relevant authorities which may include fines and imprisonment up to 20 years.

What else should you do?
All Applicable Persons are responsible for refraining from and preventing any instance of bribery or corruption, and for reporting any concern or suspicion so that GLH can identify the risks and conduct investigations as may be necessary. Reports of any concern of suspicion may be made to the Head of Internal Audit and/or Head of Human Resources:

Head of Internal Audit
1 Wallich Street
#31-01 Guoco Tower
Singapore 078881
Email : whistle-blowing@guocoland.com

or

Head of Human Resources
1 Wallich Street
#31-01 Guoco Tower
Singapore 078881
Email : whistle-blowing@guocoland.com

If you have any doubt, you should contact the Head of Internal Audit or Head of Human Resources immediately.

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