TRXC’s Anti-Bribery and Anti-Corruption Policy

The Anti-Bribery and Anti-Corruption (“ABAC”) Policy was developed with reference to the requirements of the Guidelines on Adequate Procedures issued by the Prime Minister’s Department.

This Policy intends to foster a business environment free from bribery and corruption, as well as enhancing integrity and accountability.

Objectives of the ABAC Policy:

  • A set of guiding principles to assist TRXC personnel on ethical business conduct,
  • Define TRXC’s expectations on its personnel with regards to bribery and corruption matters, and
  • Implement controls and parameters with regards to dealing with bribery and corruption risk.

TRXC adopts a “zero-tolerance approach” towards all forms of bribery and corruption and is committed to conducting its activities free from any form of bribery and corruption or any acts which are contrary to its ethics and integrity.

TRXC recognizes the value of Integrity in that all members of the Board of Directors, employees and business associates must uphold the highest standard of integrity and accountability in discharging their duties and to ensure that all TRXC’s business activities are conducted in compliance with all applicable legal and regulatory requirements on ABAC policy, both in letter and spirit.

No personnel will suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes or other illicit behaviour, even if such refusal may result in TRXC losing business or experiencing a delay in business operations.

TRXC is committed to protect its deal integrity in an impartial, transparent and ethical manner.

TRXC awards business contracts and employee contracts purely on a merit basis. Therefore, support letters in all forms will not work as inducement in TRXC’s decision-making process.

No personnel and business associates are allowed to accept, give or promise any form of facilitation payment.

Due diligence will be the primer to TRXC relationship with its employees, contractors, consultants, business partners and agents. It will also be performed on any impending deals between the parties.

TRXC requires declarations concerning actual, potential or perceived conflict of interests to be made by its personnel and business associates, on a periodic basis.

TRXC allows charitable donations and sponsorships for legitimate reasons and as permitted by existing laws and regulations. The donations and sponsorships must not influence any business decision or derive any form of benefits to either any particular person connected to the Company or TRXC itself.

TRXC strictly prohibits the act of offering monetary or any in-kind contributions to support political parties, politicians, candidates and/or political campaigns.

TRXC takes extra precaution when dealing with gifts and hospitality. Giving and accepting gifts and hospitality is disallowed if such an act derives any form of benefit to a business associate or to TRXC itself.

TRXC encourages disclosures of actual or suspected cases involving bribery and corruption in the Company through its Whistleblowing channels. TRXC does not condone the act of discrimination against a whistleblower of any kind for making such a disclosure.

TRXC views any violation of the above principles as extremely serious and will not hesitate to lodge reports to enforcement agencies or terminate any business relationships or employment contracts with said party. A “walk away” clause will be included in any contract to give the right for such termination by TRXC, due to bribery and corruption, at no loss to TRXC.