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Anti-bribery Policy

Swap Holdings Sdn Bhd and its group of companies (“SWAP”) are committed to follow a system that is fair, transparent and free from any influence or prejudiced dealings prior to and during the course of conducting business. SWAP strictly prohibits all forms of bribery and corruption. It is pertinent that all external parties (“External Parties”) dealing with SWAP shall comply with all applicable laws in relation to anti-bribery and corruption. The purpose of this Policy is to provide a guideline to everyone connected to SWAP and External Parties to ensure compliance of the relevant laws relating to anti-bribery and corruption.


SWAP strictly prohibits the offering and receiving of gifts to or from External Parties.

Bribery is the offering, promising, giving, authorizing or accepting of any undue pecuniary or other advantage to, by or for any person in order to obtain or retain a business related or other improper advantage or influence e.g. in connection with procurement contract awards and for commercial advantage.

Gifts are only permitted in the following situations:

  1. Offering Gifts To SWAP
    1. Corporate gifts & souvenirs during official business events or functions of External Party; or
    2. Corporate gifts & souvenirs offered during official events or functions organised by SWAP.
  2. Gifts Provided By SWAP
    1. Corporate gifts & souvenirs during official events or functions organised by SWAP;or
    2. Corporate gifts & souvenirs during official External Party’s events or functions;
  3. Token gifts of nominal value with SWAPS’ brandas part of brand building or promotional activities.
  4. Gifts received in conjunction with any festivity not exceeding RM250.00 only.


SWAP strictly prohibits the offering or agree to give or offer, facilitation payments to Public Officials for any undue pecuniary or other advantage to, by or for any person in order to obtain or retain a business related or other improper advantage .Public Official is defined broadly, to include:-

“Any elected Public official (e.g., a legislator or a member of a Government ministry); any employee or individual acting for or on behalf of a Public Official, agency, or government entities performing a governmental function”.


This Policy does not prohibit corporate hospitality, meals and refreshments and entertainment (“Corporate Hospitality”) which are fair and reasonable, bona fide, in accordance with the proper corporate authority limit and common industry practice such as to foster goodwill and strengthen working relationships with stakeholders. All such Corporate Hospitality must not be luxurious and excessive, inappropriately frequent with the intention of procuring a favourable business benefits and advantage from the stakeholders or recipient


Conflicts of interest should be disclosed and, wherever possible, avoided because they can affect an individual’s judgment in the performance of his/her duties and responsibilities. External Parties should closely monitor and regulate actual or potential conflicts of interests, or the appearance thereof, of their directors, officers, employees and agents and should not take advantage of conflicts of interests.


SWAP may make donations provided that such donations and contributions are bona fide and in compliance with corporate authority limits and applicable laws and regulations.


SWAP shall provide the necessary training and create awareness of this Policy to all its stakeholders, directors and employees. Third Party shall undertake periodic reviews and assessments to understand bribery and corruption risks and to ensure that they have adequate procedures in place to address such risks and that the procedures are kept up to date and remain efficient and effective.


SWAP’s appointed committee shall review this Policy regularly to ensure it is updated in accordance with the relevant applicable laws.


All enquiries with respect to this Policy and/or complaints can be addressed to the appointed Integrity Officer at integrity_officer@swap-asia.com