1. Statement of Policy
CARSOME is firmly committed to conducting all of its business activities with integrity, responsibility, transparency and in full compliance with applicable laws. We believe ethical conduct is fundamental to the trust placed in us by our customers, business partners, regulators, shareholders and the broader community. In support of this commitment, CARSOME adopts a strict zero-tolerance approach toward bribery, corruption, extortion, abuse of power, fraud or any conduct that undermines the principles of fair and honest business dealings. This Policy has been established in alignment with the Malaysian Anti-Corruption Commission Act 2009 (MACC Act), including Section 17A on corporate liability, and applies across all jurisdictions in which CARSOME operates. Compliance with this Policy is mandatory and non-negotiable.
2. Scope of the Policy
This Policy governs the conduct of all individuals and entities associated with CARSOME in any capacity. It applies to every company within the CARSOME Group and covers all levels of the organisation, including the Board of Directors, senior management, permanent and temporary employees, probationary staff, contract personnel, trainees and interns. The Policy also extends to all third parties that engage with CARSOME, whether directly or indirectly, including suppliers, vendors, service providers, contractors, agents, intermediaries, consultants, advisors, outsourced representatives and joint venture partners.
The obligation to comply with this Policy applies equally to interactions involving private sector organisations and public sector bodies, including governmental departments, regulatory authorities and public officials. The expectations set out in this Policy must be upheld regardless of an individual’s seniority, geographic location, job function, or commercial pressures that may arise in the course of business. No person or business partner acting on CARSOME’s behalf is permitted to act contrary to this Policy, and no situation or instruction may be used as justification for engaging in bribery, corruption or unethical conduct.
Compliance with this Policy is a condition of employment for CARSOME personnel and a condition of continued business engagement for external partners. All individuals covered under this Policy are required to conduct themselves in a manner that reflects CARSOME’s values of integrity, transparency and accountability at all times.
3. Prohibition Against Bribery and Corruption
CARSOME strictly prohibits any act of bribery or corruption, whether carried out directly or indirectly, for personal benefit or on behalf of the company. This includes the giving, offering, promising, requesting, accepting or receiving of any form of gratification intended to improperly influence decisions or secure an unfair advantage in business dealings. “Gratification” may take many forms, including money, gifts, entertainment, loans, discounts, donations, favours, job opportunities, confidential information or any other benefit of value.
It is a breach of this Policy for any individual to offer or provide gratification to another party to influence that party’s judgement or actions in relation to business decisions or regulatory outcomes. Likewise, it is a breach for any individual to solicit, receive or agree to receive gratification from others in exchange for granting preferential treatment, providing confidential information, awarding contracts, or taking any action that benefits one party to the detriment of CARSOME or its stakeholders.
CARSOME also prohibits any act intended to mislead, deceive or defraud the organisation, its business partners or the public. This includes the falsification, concealment or manipulation of records, accounts, documentation or reporting for the purpose of obtaining personal gain or obscuring improper conduct. Any attempt to disguise the nature of a payment, decision, relationship or transaction is considered a violation of this Policy.
In dealings involving government ministries, regulatory bodies, enforcement agencies or public officials, the expectation of integrity remains equally strict. Offering, promising, giving or receiving anything of value to influence a government official’s decision constitutes bribery, even if the official did not in fact possess direct authority over the matter. Such conduct is strictly prohibited under this Policy and under anti-corruption laws.
CARSOME employees and representatives who are approached, offered or encouraged to engage in bribery or corruption must report the matter immediately. The failure to report such conduct when it is known or reasonably suspected is considered a breach of this Policy. CARSOME does not require individuals to investigate such matters themselves; the responsibility is simply to escalate the concern through the appropriate reporting channel.
4. Gifts, Hospitality and Entertainment
CARSOME recognises that reasonable and proportionate hospitality may support positive business relationships. However, gifts, entertainment or hospitality must never be used to influence, or appear to influence, business judgment or decision-making. Any exchange of courtesies must be modest in nature, infrequent in occurrence, transparent in intention and always carried out in a professional context. If there is any doubt as to whether a gift or hospitality may create an impression of influence or obligation, the matter must be declined or referred to CARSOME’s Compliance Office for advice. Transparency, documentation and integrity must guide every interaction.
5. Donations, Sponsorships and Social Responsibility Activities
CARSOME supports charitable giving and community development initiatives conducted in good faith and for legitimate social benefit. However, charitable contributions, sponsorships or community support programs must never be used as a disguise for bribery, influence-buying or political support. All proposals for donations or sponsorships must undergo appropriate review, due diligence and approval processes to ensure transparency and compliance with legal requirements. Any contribution must be directed only toward reputable, lawful and verifiable organisations or causes.
6. Political Neutrality
CARSOME does not make political donations in any form, whether monetary or in-kind, to political parties, political candidates, political campaigns or politically affiliated organisations. Employees are free to engage in political activities in their personal capacity, provided that such involvement is separate from their professional role and does not imply CARSOME’s endorsement or support. Employees may not use company resources for political purposes or represent personal political views as those of CARSOME.
7. Anti-Corruption Laws of Other Jurisdictions
CARSOME’s Anti-Bribery and Anti-Corruption Policy is primarily developed in accordance with the laws and regulatory requirements of Malaysia, particularly the Malaysian Anti-Corruption Commission Act 2009. However, CARSOME operates in multiple countries and, as such, all employees, representatives and business partners are required to comply with the applicable anti-corruption laws of the jurisdictions in which they conduct business on behalf of CARSOME. Where local laws impose stricter requirements than those set out in this Policy, the stricter standard must be followed. Conversely, where local customs or business practices may appear more permissive, CARSOME’s standards shall still apply and shall not be compromised under any circumstances. All individuals are responsible for ensuring that their conduct remains compliant
8. Conflicts of Interest
A conflict of interest arises when personal, financial or relational considerations interfere, or could reasonably be perceived to interfere, with an individual’s duty to act in CARSOME’s best interest. Conflicts may occur, for example, when an employee uses their position to favour a family member, friend or business associate in hiring decisions, procurement activities or contract awarding. Conflicts of interest do not always involve wrongdoing but must always be disclosed. All employees and business partners are required to promptly declare any actual, potential or perceived conflicts so that they may be assessed and appropriately managed in a transparent manner.
9. Potential Red Flags
While conducting business activities, individuals may encounter situations that indicate a heightened risk of bribery, corruption or unethical conduct. The presence of any of these warning signs does not automatically mean wrongdoing is occurring, but they must be treated seriously.
10. Reporting and Whistleblowing
CARSOME encourages employees, partners and members of the public to report misconduct or suspected violations of this Policy in good faith. Reports may be made confidentially and will be handled with discretion and sensitivity. CARSOME does not tolerate retaliation, threats or adverse treatment toward any individual who raises concerns in good faith, regardless of the outcome of the investigation.
Whistleblowing Hotline: 03-9212 7988
Submit a confidential report online: https://news.CARSOME.com/whistleblowing
11. Consequences of Non-Compliance
Compliance with this Policy is a condition of employment and continued business engagement with CARSOME. Employees who violate this Policy may be subject to disciplinary action, including warnings, suspension or termination of employment, and may also face criminal prosecution where laws have been breached. Vendors, suppliers and external partners who violate this Policy may have their contracts terminated, be removed from CARSOME’s approved business network and may similarly be reported to regulatory or enforcement authorities. Individuals found guilty of bribery or corruption may face severe penalties, including fines and imprisonment under the MACC Act or other applicable laws. CARSOME will not tolerate retaliation against individuals who refuse to engage in corrupt practices or who report misconduct in good faith.
