Anti-Bribery and Anti-Corruption Policy

Last updated: 14 October 2026

PASSIVE ALTITUDE SDN. BHD. (Registration No. 201701005502 (1219667-X)) ("Passive Altitude", "we", "us") does not tolerate bribery or corruption in any form. This Anti-Bribery and Anti-Corruption Policy ("ABAC Policy") sets out the standards we expect and the procedures we follow to prevent corruption, as part of the adequate procedures required under Section 17A of the Malaysian Anti-Corruption Commission Act 2009 ("MACC Act").

Who this policy applies to

This policy applies to everyone who works for or on behalf of Passive Altitude, including:

• directors, officers and employees, whether permanent, contract, part-time or temporary, and interns;
• agents, consultants, contractors, subcontractors, resellers and other business partners when they act for us or on our behalf;
• suppliers and service providers, who must also follow our expectations set out in this policy.

It applies to all of our business dealings, in Malaysia and in any other country, with both government bodies and private companies.

Our commitment

Our board of directors is responsible for this policy and leads by example. We will:

• never offer, give, request or accept a bribe, directly or through anyone else;
• win and keep business on the strength of our products, services and prices alone;
• keep accurate books and records that reflect every transaction honestly;
• assess our corruption risks, put controls in place, and review them regularly;
• train our people and make sure our business partners know our standards.

What counts as bribery and corruption

A bribe, or "gratification" under the MACC Act, is anything of value offered, promised, given, requested or received to improperly influence a decision or to reward someone for doing so. It can include money, gifts, loans, fees, rewards, commissions, jobs, discounts, favours, entertainment, travel or any other benefit, whether given directly or through a third party.

Corruption also includes abusing a position for personal gain, and helping, hiding or failing to report corrupt conduct.

What is prohibited

• Offering, giving, requesting or accepting any bribe or gratification, to or from anyone, including public officials and employees of private companies.
• Facilitation payments: small unofficial payments to speed up or secure routine government actions such as permits, licences or customs clearance. These are bribes and are not allowed, whatever the amount.
• Using agents, consultants, family members or any other third party to do anything this policy prohibits.
• Recording payments falsely, creating "off-book" accounts, or hiding the real purpose of any transaction.
• Retaliating against anyone who refuses to pay a bribe or who reports a concern in good faith.

If anyone is threatened with harm unless a payment is made, their safety comes first. They should report it to a director immediately afterwards, and the payment will be recorded accurately.

Gifts, entertainment and hospitality

Modest gifts and hospitality can be part of building good business relationships, provided they are reasonable, transparent and never intended to influence a decision.

• Gifts and hospitality given or received must not exceed RM 500 in value per person per occasion.
• Anything above RM 500, or more than one gift from the same party within a short period, needs a director's written approval in advance, or must be politely declined or returned.
• All gifts and hospitality above token value (such as branded stationery or festive food items) must be recorded in our gifts and hospitality register.
• Cash, cash equivalents (vouchers, gift cards, shares) and personal loans must never be given or accepted.
• Nothing should be given or received while a tender, quotation, contract renewal or negotiation with that party is in progress, unless a director has approved it in advance.
• Gifts and hospitality must never be offered to public officials beyond token items of nominal value, and only where local rules permit.

Dealing with public officials

We work with government agencies and government-linked companies. All dealings with public officials must be open, properly documented and for legitimate business purposes only. Employees must not offer any benefit to a public official, or to their family, to influence any decision, approval, permit or procurement.

Donations and sponsorships

• We do not make political contributions on behalf of the company.
• Charitable donations and sponsorships must be made to legitimate organisations, approved by a director, paid by traceable means and recorded accurately.
• No donation or sponsorship may be made to win business or influence a decision.

Business partners and third parties

Before appointing agents, resellers, consultants, subcontractors or suppliers who act for us or on our behalf, we carry out due diligence in proportion to the risk. This includes checking their background, ownership and reputation, and making sure their fees are reasonable for the work done. Where appropriate, our agreements include anti-corruption commitments and give us the right to end the relationship if those commitments are broken.

Conflicts of interest

Employees and directors must declare any personal, family or financial interest that could affect, or appear to affect, their decisions for the company. The declaration must be made to a director before the matter goes ahead, and the person concerned must take no part in the decision.

Books, records and controls

We keep complete and accurate financial records, with appropriate approvals for payments, purchasing and expenses. Records of gifts, hospitality, donations, sponsorships and due diligence are kept for at least seven years.

Reporting a concern

Anyone who suspects bribery or corruption connected to Passive Altitude, or who is asked to take part in it, should report it as soon as possible:

• Email: [email protected] with the subject line "Confidential: ABAC"
• Phone: +603 7890 2655, asking to speak to a director in confidence
• Post: marked "Confidential: ABAC, attention the Directors", PASSIVE ALTITUDE SDN. BHD., A-05-05, Block A, Ativo Plaza, No. 1, Jalan PJU 9/1, Damansara Avenue, Bandar Sri Damansara, 52200 Kuala Lumpur

Reports are reviewed by a director who is not involved in the matter. We handle every report confidentially and investigate it fairly. You can also report corruption directly to the Malaysian Anti-Corruption Commission (MACC).

Protection for people who speak up

We will not dismiss, demote, discipline or otherwise disadvantage anyone who refuses to take part in bribery or corruption, or who reports a genuine concern in good faith, even if the concern turns out to be mistaken. Retaliation against a reporter is itself a serious breach of this policy. Protection under the Whistleblower Protection Act 2010 may also apply.

Consequences of breaching this policy

Breaching this policy may lead to disciplinary action up to and including dismissal. For business partners, it may lead to the end of the relationship. Bribery and corruption are also criminal offences under the MACC Act, which can lead to heavy fines and imprisonment for individuals, and corporate liability for the company under Section 17A.

Training and communication

Every new employee receives this policy when they join, and all employees receive refresher training. We share this policy with our business partners and make it publicly available on our website.

Monitoring and review

Our directors review our corruption risks and this policy at least once a year, and after any significant change in our business or the law. We update our controls where the review shows they can be improved.

Contact

Questions about this policy: [email protected] or +603 7890 2655.