1. Policy Statement

LifeCare Group of Companies are committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery and corruption are prevented. We have a zero-tolerance approach to bribery and corruption, and we are committed to acting professionally, fairly, and with integrity in all business dealings and relationships.

2. Purpose

The purpose of this policy is to:

• • Set out our responsibilities, and those working for us, in observing and upholding our position on bribery and corruption.
  • Provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues.

3. Scope

This policy applies to all employees, directors, officers, agents, consultants, contractors, and any other people or bodies associated with all companies under Life Care Group of Companies, including third parties.

4. Definition of Bribery and Corruption

Bribery is offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust. Corruption is the abuse of entrusted power for private gain.

5. Policy Details

• • Prohibition of Bribery and Corruption: Life Care Group of Companies prohibits the offering, giving, receiving, or soliciting of any bribe or corrupt practice. This applies to both public officials and private individuals/entities.
  • Gifts and Hospitality: Employees must not accept or offer gifts, hospitality, or entertainment that could influence or be perceived to influence their decisions.
  • Facilitation Payments: Life Care Group of Companies do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
  • Donations: Life Care Group of Companies do not make contributions to political parties. Charitable donations are acceptable but must be legal and ethical under local laws and practices.

6. Responsibilities

• • Employees: Must ensure that they read, understand, and comply with this policy. The prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of all employees.
  • Management: Must ensure that all employees are aware of and understand this policy and their responsibilities under it.

7. Monitoring and Review

• • Regular Audits: Internal audits will be conducted periodically to ensure compliance with this policy.
  • Annual Review: The policy will be reviewed annually by the compliance team to ensure its effectiveness and updated as necessary.
  • Risk Assessments: Regular risk assessments will be conducted to identify potential areas of corruption and bribery risks.

8. Reporting and Whistleblowing

• • Reporting Procedure: Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Reports should be made to Dr Alex Leong, Director via email alexleong@lifecare.com.my
  • To report any incidents of bribery, please use the Bribery & Non-Compliance Reporting Form.
  • Confidentiality: All reports will be treated in confidence and every effort will be made not to reveal the identity of the whistleblower unless required by law.
  • Protection: LifeCare Group of Companies are committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption or because of reporting in good faith their suspicion.

9. Training and Communication

• • Training: All employees will receive regular, relevant training on how to implement and adhere to this policy.
  • Communication: This policy will be communicated to all new and existing employees, agents, contractors, and business partners.

10. Consequences of Non-Compliance

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment, and any other legal action as deemed necessary.

11. Contact Information

For any questions or further information on this policy, please contact:

Dr Alex Leong

Email: alexleong@lifecare.com.my

Phone: +603-2241 3610

This policy is endorsed by DR ONG KEE LIANG, FOUNDER AND GROUP MANAGING DIRECTOR, and is effective from January 2024.