1. OUR COMMITMENT

   Our company, Orissa Wicomm (M) Sdn Bhd, is committed to conducting all its business legally and ethically. We take reasonable and appropriate measures to ensure that our business does not participate in corrupt activities for its advantage or benefit.

   We are bound by and will comply with the laws in Malaysia, including the Malaysian Anti- Corruption Commission (“MACC”) Act 2009 and is constantly upholding all such laws relating to anti-bribery and corruption in its conduct of business.

2. OBJECTIVE OF THIS NOTE

   This note is prepared to inform and communicate our company’s ethical standards and requirements to external stakeholders of our business. These include but not limited to, vendors, agents, contractors or suppliers that work with us, our clients local or abroad or any other person from the general public.

   The policies stated in this note are not intended to be exhaustive, and there may be protocols or procedures that we adhere to when conducting our business. For all intent and purposes, our company shall always observe and ensure compliance with all applicable laws, rules and regulations to which we are bound to observe in the conduct of our business.

3. POLICY STATEMENT

   1. Basic principle:

      Bribery means the offering, promising, giving, receiving or soliciting gratification as an inducement for an action that is illegal, unethical or a breach of trust which represents an offence under the MACC Act 2009. The term “gratification” in the above paragraph has a similar definition as provided in the said Act.

      We at Orissa and any of our appointed intermediaries such as agents, consultants, advisers, contractors or subcontractors not directly appointed by Orissa shall not participate in any acts of bribery to illicitly influence the decision or action of a person in a position of trust for the intended benefit of our company or the person involved in the transaction.

   2. Gifts, Hospitality and Entertainment

      Our company does not prohibit normal gestures of business hospitality and goodwill, so long the giving and receiving of gifts, hospitality and entertainment:

      • Is not made with the intention to influence the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits;

      • Is not made with the suggestion that a return favour is expected;

      • Is made at the right time and does not give rise to the perception of being unethical;

      • Complies with the local law;

      • Is reasonable, modest, infrequent and appropriate to the circumstances; and

      • Is given or received openly, not secretly.

      The above requirements are not meant to be exhaustive. We should always put in the effort to consider whether the gifts, hospitality, and entertainment have or be seen as having an illegitimate purpose.

   3. Public offices or officials

      We do not give anything of value, directly or indirectly, to officials of both foreign and domestic governments or foreign or domestic political candidates to obtain or retain business. We do not promise, offer, or deliver to any foreign or domestic government employee or official any gift, favor, or other gratuities that would be illegal.

      It is our Company’s policy not to provide any form of a contribution to any political organization or governmental official.

   4. Suppliers, vendors and intermediaries

      We expect our supplier, which includes vendors that provide goods, contractors, or sub-contractors, to conduct its business with our company with the highest ethical standards and to comply with applicable laws on bribery, corruption and fraud.

      As part of our due diligence process of appointing suppliers, an expected Code of Conduct detailing our company’s ethical requirements would be provided to all our registered suppliers for their understanding and acknowledgement.

      Suppliers are encouraged to report to our company if any of our employee or business associate, regulator or authority requests any such incentive or payment. The reporting channel can be found in the following section of this note.

4. RAISING OF CONCERNS

   We strongly encourage all, including suppliers, customers or the general public, to report any matter of ethical concerns relating to our company to us.

   Reports of unethical doings or suspected doings can be made through one of the following channels:

   • By mail to the Director
     Address: Suite 1.02, 1st Floor Plaza Hamodal, Lot 15, Jalan 13/2, Seksyen 13, 46200 Petaling Jaya, Selangor, Malaysia

   • By email to the Director
     Email: shobana.kumarasamy@orissawicomm.com

5. NO REPRISAL OR RETALIATION

   We are committed to protecting those from reprisal or retaliation, to the extent of our reasonable authority to do so, for refusing to take part in bribery or corruption, or for reporting concerns in good faith their suspicion of an actual or potential bribery offence has taken place or will take place, even if such actions would be disadvantageous to our business (e.g. loss of contract).

   However, our company reserves the right to revoke this protection if is it found that the person had participated in the illegal act or had made the report not in good faith, maliciously, with ill-intent, falsely, dishonestly or mischievously.

Sincerely,
The Chief Executive Office
Nallen Singhe