This policy applies to:

• All directors, officers, and employees of the Company (whether permanent, contract, or temporary)
• All third parties acting on behalf of the Company, including agents, contractors, suppliers, consultants, and business partners

Compliance with this policy is mandatory.

Bribery refers to offering, giving, receiving, or soliciting anything of value (whether directly or indirectly) with the intention of influencing a business decision or securing an improper advantage.

Corruption includes bribery, abuse of power, conflict of interest, and any dishonest conduct for personal or corporate gain.

5.1 General Principle

The Company prohibits employees from soliciting or accepting gifts, entertainment, or benefits that may influence, or be perceived to influence, their judgment or decision-making.

5.2 Permitted Gifts

Employees may accept gifts in kind only under the following conditions:

5.3 Reporting of Gifts

All gifts received, regardless of value, must be reported to the employee’s immediate superior.

The Company reserves the right to exercise discretion on the treatment of such gifts, including:

• Allowing the gift to be retained by the employee
• Requiring the gift to be shared or distributed among employees
• Donating the gift to a charitable organisation

Failure to declare gifts may be treated as a disciplinary matter.

The Company strictly prohibits facilitation payments, regardless of amount, to expedite or secure routine governmental or business actions.

Employees must avoid situations where personal interests conflict, or appear to conflict, with the interests of the Company. Any actual or potential conflict of interest must be declared promptly to management.

8.1 Reporting Channel

The Company encourages employees and external parties to report any suspected or actual bribery, corruption, or unethical conduct.

Reports should be made via email to: lowchinann@msianpestcontrol.com

8.2 Non-Anonymous Reporting

Whistleblowers must provide their personal details when making a report. Anonymous reports will not be accepted. Reports shall contain relevant and detailed information pertaining to the alleged, suspected, or actual corruption practice (e.g. time of incident, parties involved, location, detail of the transactions).

All information provided will be treated with strict confidentiality and used solely for investigation purposes.

8.3 Protection of Whistleblowers

The Company will not tolerate retaliation, harassment, or discrimination against any whistleblower who reports in good faith. Any act of retaliation will result in disciplinary action.

For broader whistle-blowing procedures including investigation panel and acknowledgment timelines, see our Whistle Blowing Policy.

All reported cases will be assessed and investigated fairly and promptly. Where misconduct is proven, appropriate disciplinary action will be taken, which may include:

• Disciplinary sanctions
• Termination of employment or contract
• Reporting to relevant authorities

• Board of Directors: Overall oversight and commitment to this policy
• Management: Implementation, monitoring, and enforcement
• Employees: Compliance with this policy and reporting of any suspected breaches

The Company may provide training and communications to ensure employees understand their obligations under this policy.

This policy shall be reviewed periodically and updated as necessary to ensure continued relevance and compliance with applicable laws.