HWG adopts a strict zero-tolerance approach towards all forms of bribery and corruption.

We are committed to conducting our business with integrity, transparency, and in full compliance with applicable laws, including the Malaysian Anti-Corruption Commission Act 2009 (MACC Act), as well as in accordance with all applicable laws.

HWG is committed to implementing and enforcing effective and robust policies and procedures to prevent, detect and respond to bribery and corruption, and to continual improvement of the Anti-Bribery.

Our Commitment

HWG strictly prohibits:

• Offering, promising, giving, or receiving any form of bribe or improper advantage
• Soliciting or accepting any gratification intended to influence business decisions

This applies to all directors, employees, and any third party acting on behalf of HWG, including agents, resource persons, introducers, consultants, and partners.

Gifts, Entertainment & Business Courtesies

Business courtesies must:

• Be reasonable, proportionate, and for legitimate business purposes
• Not influence, or appear to influence, any decision-making process
• Be declared and approved in accordance with internal procedures

Integrity

All personnel must:

• Ensure transparency in all financial arrangements and transactions
• Avoid undisclosed commissions, kickbacks, or side arrangements
• Conduct proper due diligence on investors, partners, and counterparties
• Maintain complete and accurate records to support all transactions

Third-Party Engagement

HWG expects all business partners to:

• Adhere to applicable anti-corruption laws and ethical standards
• Undergo appropriate due diligence prior to engagement
• Avoid any conduct that may expose HWG to bribery or corruption risks

HWG reserves the right to terminate relationships in cases of non-compliance.

Conflict of Interest

All personnel must:

• Avoid situations where personal interests conflict with HWG’s interests
• Declare any actual, potential, or perceived conflicts promptly

Speak Up

HWG encourages employees and stakeholders to report any suspected misconduct or unethical behaviour.

All reports will be treated confidentially, and retaliation against whistleblowers acting in good faith is strictly prohibited.

Governance & Accountability

HWG is committed to implementing adequate procedures to prevent bribery and corruption, including:

• Risk-based assessments across business units
• Internal controls and approval processes
• Training and awareness programmes
• Ongoing monitoring and periodic review

Approved by:
Board of Directors, Holistic Wealth Group