Anti-Corruption Policy

1. 3E Accounting Limited, its associate companies and subsidiaries (collectively known as the “the Group”) are committed to conduct our business with utmost integrity and with the highest ethical standards. We will devise and improve our processes continuously to prevent direct or indirect bribery in order to safeguard and uphold our values.
2. We adopt a zero-tolerance policy towards any forms of corruption and bribery in our business. We are committed to ensure that our officers and employees observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake ourselves to not engage in any corrupt or improper practices.
3. We prohibit our officers and employees to:-
   • give, promise to give or offer a payment, gift or hospitality with the expectation or hope that an unfair business advantage will be received, or to reward an unfair business advantage already given;
   • give, promise to give or offer a payment, gift or hospitality to any officials or employees of any government or other public body or agency or any individual or entity with whom they deal with in the course of the employment to ‘facilitate’ or expedite a routine procedure;
   • accept any payment, gift or hospitality from any individual or entity with whom they deal with in the course of the employment in order to secure or reward an improper benefit or improper performance of a function, activity or to procure an unfair business advantage;
   • threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under this policy; or
   • engage in any activity that might lead to a breach of this policy or perceived breach of this policy.
4. We recognize that the exchange of business courtesies such as modest gifts including but not limited to meals, invitations to attend promotional events particularly during festive periods is customary and legitimate to create goodwill and strengthen business and commercial relationships. Such courtesies are not prohibited provided that they are not lavish in light of the accepted business practices of the relevant businesses that the Group operates in and is not intended to improperly influence the decisions of the person involved.
5. We have implemented clear guidelines with regard to the declaration of conflict of interest and the receipt of corporate gifts and any other benefits from our business partners which our employees are obliged to adhere to. Our officers and employees are obliged to make such declaration and keep a written record in accordance with our guidelines set out in the Employee Handbook.
6. We have implemented an internal reporting structure, procedures and channels that are secure and accessible for our employees to raise concerns and report violations or suspicious activity.
7. If our employees are established to have been involved in prohibited practices, they may be subjected to disciplinary actions including immediate dismissal of employment and/ or referral to the relevant law enforcement authorities.
8. We are also committed to ensure that our business partners share our zero- tolerance policy against corruption and bribery. We will avoid engaging in business dealings with those known or reasonably suspected to be engaging in corruption and bribery.
9. We will monitor the effectiveness and review the implementation of this policy on a regular basis to ensure its adequacy and effectiveness in preventing corruption and policy.