PROLINTAS protects the privacy of all its employees, business partners and consumers. PROLINTAS handles personal data responsibly and in compliance with all applicable privacy laws. This Data Protection (“Policy”) sets out the basis upon which PROLINTAS Group of Companies (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees and job applicants in accordance with the Personal Data Protection Act (“PDPA”).

PROLINTAS has consolidated its policies on gifts, hospitality, charitable donations and sponsorships under a single No Gift Policy to establish a consistent approach to managing these matters across the organisation. This consolidation aims to strengthen anti-bribery controls, promote consistent implementation, facilitate understanding of the applicable requirements and reinforce PROLINTAS’ commitment to integrity and ethical business practices.

3.1 Gift Policy
PROLINTAS recognises that gifts are part of Malaysian culture. In delivering integrity and good governance in conducting business, PROLINTAS explicitly prohibits personal gifts from either party due to its potential or perceived consequences. Nevertheless, corporate gifts are acceptable, subject to compliance with the requirements set out in PROLINTAS’ No Gift Policy.

3.2 Hospitality Policy
Hospitality refers to entertainment provided to external parties for legitimate business purposes and to strengthen professional relationships. All hospitality must be reasonable, appropriate and transparent, with no intention to influence business decisions or create conflicts of interest. PROLINTAS prohibits employees and directors from soliciting or accepting excessive or inappropriate hospitality, particularly from parties involved in tender or competitive bidding exercises. Repeated or continuous hospitality involving the same individuals or organisations is also prohibited.

3.3 Sponsorship Policy
Sponsorship refers to financial or in-kind contributions made in exchange for agreed business benefits. All sponsorships must be transparent, supported by a legitimate business purpose, and subject to background checks. Employees are prohibited from requesting or receiving sponsorships, and sponsorships for political purposes are strictly prohibited. All sponsorships must comply with PROLINTAS’ No Gift Policy.

3.4 Charitable Donation Policy
Charitable donations in the form of cash, assets, goods or services to charitable organisations or non-profit entities are permitted for legitimate purposes, subject to compliance with PROLINTAS’ No Gift Policy. However, PROLINTAS employees are strictly prohibited from soliciting or receiving donations.

PROLINTAS is committed to strengthening its governance standards and creating value for its stakeholders through a comprehensive set of policies that promote accountability, transparency and ethical business practices. The ABC Policy establishes PROLINTAS’ position on bribery and corruption and serves as a key component of its corporate integrity framework.

The ABC Policy covers the following key areas:

4.1 Conflict of Interest Policy
A conflict of interest arises when personal interests influence, may influence, or are perceived to influence an individual’s decisions or responsibilities in their dealings with PROLINTAS. All personnel are expected to disclose any actual, potential or perceived conflicts of interest, act with integrity and transparency, and avoid using their positions or business relationships for personal gain or undue advantage.

4.2 Facilitation Payments Policy
Facilitation payments are unofficial payments or benefits made to an individual to secure or expedite routine official or administrative actions to which the payer is otherwise entitled. PROLINTAS strictly prohibits facilitation payments in all its business dealings as part of its commitment to integrity, ethical conduct and anti-bribery practices.

4.3 Support Requests Policy
A support request refers to a request by an influential individual or organisation seeking special privileges or preferential treatment for an individual or organisation, such as recommending a particular vendor for a contract or business opportunity, regardless of its suitability. Such requests may be made through any communication channel. PROLINTAS does not condone the misuse of influence or position for personal gain or to obtain undue advantages for others and is committed to ensuring that all business decisions are made fairly, transparently and on their merits.

4.4 Anti-Money Laundering, Anti-Terrorism Financing, And Proceeds of Unlawful Activities (AMLA) Policy
PROLINTAS strictly prohibits money laundering and terrorism financing and is committed to conducting its business in compliance with applicable laws and regulations. All employees and business associates are expected to uphold these standards and avoid any involvement in activities involving proceeds of unlawful activities.

4.5 Political Contributions Policy
PROLINTAS prohibits political contributions, whether made directly or indirectly, in cash or in kind, to political parties, individuals or organisations for political purposes. This includes contributions disguised as sponsorships, charitable donations or other forms of support. PROLINTAS is committed to maintaining political neutrality and preventing the misuse of company resources for political purposes.

4.6 Integrity Pact and Declaration Policy
Integrity pact is an agreement between the entity offering the contract and the company / companies bidding for it, that all parties will abstain from bribery, collusion and other corrupt practices in the period leading up to the award and during the contracting period. The purpose of this policy is to provide guidance to its users on the appropriate procedures when implementing integrity pacts in procurement and contracting.

4.7 Due Diligence
Due diligence is the process of assessing the legal, financial and corporate standing of prospective and existing contractors, suppliers, business partners and other third parties to ensure their suitability and capability to fulfil their contractual obligations with PROLINTAS.

The existence of conflict of interest poses a significant threat to the high integrity standard that PROLINTAS Group of Companies upholds. PROLINTAS Group of Companies’ personnel should avoid any conflict of interest situation or the perception of such conflicts to protect both the company and the personnel’s reputation. Personnel are prohibited from misusing their position or authority in the company to pursue their private interests.

A facilitation payment is a certain type of payment made to a public or government official that acts as an incentive for the official to complete some action or process expeditiously, to the benefit of the party making the payment. This policy is aligned to the PROLINTAS Anti-Bribery policy and provides procedures to eliminate or control facilitation payments and to ensure that the company complies with anti-corruption laws.

PROLINTAS strictly prohibits staff and directors from soliciting hospitality nor are they allowed to accept hospitality that is excessive, inappropriate, illegal or given in response to, in anticipation of, or to influence a favorable business decision, particularly from parties engaged in a tended or competitive bidding exercise such as contractors, vendors, suppliers and etc.

This code sets out the above standards, which PROLINTAS expects from all suppliers to conform to, as part of their engagement conditions. By signing the S-COC declaration form, the supplier agrees to the terms and principles of the policy. S-COC shall form a part of any contract entered into PROLINTAS with the supplier.

PROLINTAS Group of Companies will engage suppliers to assist in the delivery of services to its customer (supplier or suppliers which shall include the supplier’s staff, agent and representative). And it is important that those suppliers adhere to the standards of behavior and conduct that PROLINTAS expects of its own staff, personnel, management and director (member of PROLINTAS).