Privacy & Policy

Tenaga Switchgear Sdn. Bhd. and its affiliated entities ("TSG"), have long recognized that individuals, and as the case may arise, legal entities, with whom we conduct business value their personal data. Modern information and communication technologies play a fundamental role in the activities of TSG. It is Tenaga Switchgear Sdn. Bhd. 's goal to balance the benefits of e-commerce with the right of individuals, and as the case may arise, of legal entities to prevent the misuse of their personal data. The information that you provide to us or that we acquire about you will always be exclusively used for the purposes listed hereunder to support your customer relationship with Tenaga Switchgear Sdn. Bhd. It will not be given or sold to any outside organization for its use in marketing and solicitation.

The Collection, Processing, Transfer and Use of Personal Data

In some circumstances, Tenaga Switchgear Sdn. Bhd. may request personal information from you, like your name, e-mail address, company name, business address, domain names, telephone or fax numbers, purchase history and ordering information (altogether the "personal data"). Your response to Tenaga Switchgear Sdn. Bhd.'s inquiries are strictly voluntary. Tenaga Switchgear Sdn. Bhd. also collects information about you with respect to the use of this site; this information is collected automatically and requires no action on your part and encompasses information as to whether you visit our site, how often you visit and what parts of the site you visit most often. Tenaga Switchgear Sdn. Bhd. uses your personal data to improve its web-based offerings as well as for other business purposes, such as alerting you to products and services that can assist you in your business, promoting registration on our sites, and assisting you for order processing and after-sales services, by means of e-mail, post, fax or by calling you. We may use your personal data to send you further information about Tenaga Switchgear Sdn. Bhd. products or services (in addition to the specific information which you request or which we need to send to you). We may send this information by e-mail, post, fax, or by calling you. In general, you can visit our website(s) without divulging any personal information. However, there are areas of this site that require this information to complete their customization functions and may not be available to those choosing not to reveal the information requested.

Location of Your Personal Data

As Tenaga Switchgear Sdn. Bhd. operates internationally, we may need to make your personal data available to companies and/or branches within our group which may be located outside your jurisdiction and/or the Malaysia country, notably in countries which do not adduce the same level of protection of personal data as in your jurisdiction and/or the Malaysia country, again for the purposes described here above. In particular, Tenaga Switchgear Sdn. Bhd. will transfer all or part of such records to its group's headquarters located in Malaysia. In any case, Tenaga Switchgear Sdn. Bhd. will use its best efforts to ensure that data transferred outside your jurisdiction and/or the Malaysia country will remain subject to the same security and confidentiality regime as the one they would have been subject to if located within your jurisdiction and/or Malaysia country. If you are opposed to the transfer of your personal data please refer to the Section below, Your Rights & Your Consent.

Disclosure to Third Parties

Tenaga Switchgear Sdn. Bhd. may disclose aggregate statistics about its site(s) visitors, customers and sales in order to describe its services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying or identifiable information. Tenaga Switchgear Sdn. Bhd. may disclose personal data if required to do so by law or if it believes that such action is necessary to protect and defend the rights, property or personal safety of Tenaga Switchgear Sdn. Bhd. or its employees, its site(s) or visitors thereof.

Use of Cookies

Tenaga Switchgear Sdn. Bhd. does not at present, but may in the future use "cookies" on its sites to enhance their functionality. A "cookie" is a small piece of information sent by a website server and stored by your browser on your hard drive, which may assist in enhancing the quality of a website's operation. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that.

Links to Other Web Sites

This site contains links to sites not operated by Tenaga Switchgear Sdn. Bhd., Tenaga Switchgear Sdn. Bhd. is not responsible for the data protection policies or the content of such sites.

Your Rights & your Consent

You may at any time review or ask for the rectification of your personal data held by Tenaga Switchgear Sdn. Bhd. as well as object, at no charge, to any further use of the same personal data, such as for direct marketing purposes, or transfer of same, by contacting us at:
Lot 3, Jalan Teknologi 3/6 Seksyen 3,
Taman Sains Selangor 1, Kota Damansara,
47810 Petaling Jaya Selangor Darul Ehsan.
By using Tenaga Switchgear Sdn. Bhd.'s website(s), and providing your personal data to Tenaga Switchgear Sdn. Bhd. and/or generating personal data through such website(s), you consent to the processing and transfer outside your jurisdiction and/or Malaysia country of your personal data as set out in this data protection statement. Tenaga Switchgear Sdn. Bhd reserves the right to change, modify or update this statement at any time. In such event, a notice will be posted for one month on the website. If you do not accept the change, modification or update, you may object to any further use of your personal data by contacting us at Tenaga Switchgear Sdn. Bhd Lot 3, Jalan Teknologi 3/6 Seksyen 3, Taman Sains Selangor 1, Kota Damansara, 47810 Petaling Jaya Selangor Darul Ehsan, Malaysia. Or via e-mail at sales@mytsg.com.my/switch@mytsg.com.my If you have any questions about this data protection statement, the data processing practices of Tenaga Switchgear Sdn. Bhd., or your dealings with one of Tenaga Switchgear Sdn. Bhd.'s websites, you can contact us at switch@mytsg.com.my

Safety & Environment Requirement for Contractors

1. PURPOSE

1.1 This procedure highlights the safe working practices required for all contractors working at TSG or site . It is intended to improve safety performance and to ensure the safety of contract employees as well as the employees at TSG or site.
1.2 It is fully recognized that contractors have the primary responsibility for executing on-site safety for their own activities. Each contractor is responsible for ensuring that its employees,and the employees of any subcontractors, comply with all applicable local, state and federal regulations, and the policies of TSG. All work performed shall comply with the requirements of the Occupational Safety and Health Act And Regulations ( Act 514), without exception.

2. SCOPE

2.1 The safety practices shall be followed whenever performing work at TSG or site.
2.2 The contractor shall require that all subcontractors observe the safety practices in the same manner as the contractor.
2.3 All contractors shall designate a Supervisor who shall have the primary responsibility for ensuring that these safety practices and procedures are followed.
2.4 The Supervisor, or designated authority, shall perform frequent and regular safety inspections of the job site, materials, and equipment.

3. SAFE WORKING PRACTICES and PERSONAL PROTECTION

3.1 Safety glasses meeting the safety requirements must be worn at all times when there is an eye hazard from exposure to flying particles, liquid chemicals, acids or caustic liquids, or potentially injurious light radiation. Safety glasses are required to be worn while working in TSG areas. Activities requiring eye protection include:
welding, cutting, burning, using pneumatic impact tools, grinding, buffing, using handtools, applying or removing insulation, and painting.
3.2 Hearing protective devices must be worn when working in areas that require hearing protection based on noise level monitoring or when performing a task that produces high noise levels. Areas where hearing protection is required are marked with appropriate signs.
3.3 Appropriate hand protection shall be worn to protect against chemical contact , severe cuts or lacerations, punctures, or harmful temperature extremes. Chemical resistant gloves must be rated/compatible for the specific chemical being used.
3.4 Safety helmet or Bump Caps, meeting the safety requirements, are required whenever there is a potential for injury to the head from falling objects or striking a low overhead structure. When working with overhead crane, wearing safety helmet is compulsory and bump caps isnot allowed. Green line in production area is free from wearing safety helmet. Foot protection, meeting the safety requirements shall be worn when there is a danger of foot injuries due to falling or rolling objects or objects piercing the sole ( production area, logistic and stor and when doing contruction work in TSG premise.
3.5 Respiratory protection, must be appropriate for the hazard and must be maintained, cleaned and stored properly. All persons wearing respirators must be medically approved to do so and fit-tested. (refer to MSDS/CSDS for more information type of respiratory to use).
3.6 Horseplay is not tolerated. Smoking is allowed in designated areas only.
3.7 Drinking of, or possession of, alcoholic beverages, or possession of illicit drugs or firearms while on the property of this facility, during working or non-working hours, is strictly forbidden.
3.8 Entry into confined spaces may only be performed by authorized personnel, following the confined space requirements of OSHA. Prior to entry, atmospheric monitoring shall be conducted, and an entry permit shall be completed to verify safe entry conditions.
3.9 All safety equipment, safety showers, eye wash fountains, fire extinguishers, emergency exits, and walkways must be kept clear at all times.
3.10 All project areas shall be kept clean and free of debris and rubbish in order to prevent accidents and fires.

4. CHEMICAL SAFETY AND HAZARD COMMUNICATION

4.1 Contractor to provide the Material Safety Data Sheet (MSDS) for hazardous chemicals use at TSG to OSHU before start any work where in which contract employees may be exposed, come in contact, or directly handle. The contractor shall inform his employees of the hazards of the chemicals.
4.2 The contractor is responsible for maintaining MSDSs for all hazardous chemicals used by the contractor or subcontractor.
4.3 When handling corrosive materials or irritants, rubber chemical gloves, goggles and/or face shields shall be used.
4.4 All compressed gas cylinders shall be secured from falling at all times and capped when not in use.
4.5 At no time shall gasoline be used as a cleaning agent.
4.6 Flammable liquids/gases and solvents shall be handled in approved safety cans with flash back arrestors and tight closing lids.

5. FALL PROTECTION

5.1 All ladders used at TSG shall be heavy duty industrial type ladders. The use of aluminium ladders for electrical work is prohibited. Ladders shall be secured at the base by safety feet or equivalent and tied off at the top when there is a chance of displacement from workplace activities or traffic. All portable ladders used to gain access to an upper landing surface shall extend at least 3 feet above the landing or secured at the top and a grasping device provided.
All straight and extension ladders shall have approved safety feet and be equipped with a 10 foot by 1/2 inch rope spliced to the next to the top rung. Ladders with split or broken rails, treads, rungs, or with feet missing or otherwise damaged or considered unsafe must be removed from the job. Step ladders shall not be used as straight ladders.
The height of the ladder must be sufficient to keep from working from the top of the ladder or the top three rungs of an extension ladder. The ladder shall be positioned so that the base is set out from the vertical a distance equal to onefourth of the ladder working length.
5.2 During overhead work, ground work, or work inside a production area, all areas must be barricade , and a warning sign shall be placed on the floor. All areas involving overhead work or work inside an occupied area that poses a hazard to other personnel shall be barricade and/or warning signs placed to limit access to the area.
5.3 All excavations and trenches shall comply with the OSHA Trenching and Shoring
requirements, which require guarding by a sloping system, shoring system, support system or equivalent. In addition, these areas shall be barricade and, at night, alerted with proper warning lights.
5.4 Each scaffold must be inspected, approved and tagged by the Competent Person. Scaffold Competent Person must provide the Contractor with the appropriate scaffold tag at the scaffolding already inspected. Colour coded tags represent the following:
a. Red tag = scaffold is not approved for use
b. Yellow tag = read tag instructions/identify special warnings on tag
c. Green = scaffold has been approved for use
5.4.1 Each platform on all working levels of scaffolds shall be fully planked or decked between the front uprights and the guardrail supports.
5.4.2 Vertical ties/braces shall not exceed a 4:1 ratio with the minimum base width of the scaffolding. Horizontal increments for ties shall not exceed 30 feet.
5.4.3 Supported scaffold poles, legs, posts, frames and uprights shall bear on base plates, mudsills or other adequate firm foundation. Footings shall be level, sound, rigid and capable of supporting the loaded scaffold without settling or displacement.
5.4.4 An approved ladder or equivalent safe access shall be provided on all scaffolding systems. Additional fall protection shall be required if the interval distance between the scaffolding base and the lower level is 35 feet or greater.
5.4.5 Guardrail systems consisting of a top rail, mid rail and toe-board shall be installed on all open sides and ends of supported scaffolding that is at or above a height of six (6) feet. Contractor shall install netting from toe-board up to the top of anticipated material storage height.
5.4.6 All cross bracing must be installed in accordance with the manufacturer’s instructions.
5.4.7 When wire rope clips are used on suspension scaffolds, U-bolt clips shall not be used at the point of suspension for any scaffold hoist.
5.4.8 An insulated thimble shall be used to attach each suspension wire rope to its hanging support.
5.4.9 The suspension wire rope shall be covered with insulating material extending at least four (4) feet above the hoist.
5.4.10 The tail line shall be insulated to prevent contact with the platform. Each hoist shall be covered with insulated protective covers.
5.4.11 In addition to a work lead attachment required by the welding process, a grounding conductor shall be connected from the scaffold to the structure.
5.4.12 All employees shall receive training as required by OSHA scaffold standard and shall provide documentation on training per request.
5.4.13 Full body harness shall be worn with a lifeline securely attached to an appropriate anchorage. Free fall distance when using a full body harness must be limited to 6 feet or less.
5.5 Hoses, welding leads, electrical drop cords, etc. shall be kept out of personnel traffic areas when possible. Otherwise, they shall be adequately protected from damage and presenting a tripping hazard by suspension, signs, barricades and/or burying.

6. ELECTRICAL SAFETY PRACTICES

6.1 The Contractor shall apply PTW from TSG charge man before start any electrical work (repair and maintenance or new installation). The Contractor Supervisor shall ensure that electrical or mechanical equipment is properly locked and tagged out before employees begin work.
6.2 All electric hand tools shall be grounded unless it is recognized by UL as having a double insulated rating. Frayed or defective electrical cords shall not be used.
6.3 All extension cords and power tools shall be used with appropriate Residual Current Device (RCD) protection that is tested regularly.

7. WELDING, CUTTING, BURNING OPERATIONS

7.1 Adequate fire protection and other safety precautions must be addressed before any hot work is executed. 7.2 Shields, curtains, or flame retardant tarpaulins shall be used to shield personnel and equipment from welding operations. When welding, cutting, or burning, a standby employee shall stand as a fire watch , and all sparks must be contained to the area of operation.
7.3 The Contractor shall ensure that fire extinguishers are provided at all welding, cutting, and burning operations.

8. HEAVY EQUIPMENT OPERATION

8.1 Only qualified personnel (TSG Staff) may operate the facility forklift trucks or similar material handling or earthmoving equipment.
8.2 Only approved personnel work platforms shall be used with forklifts or similar lifts. The platform must have standard guard rails or equivalent means of fall protection and be secured to the lift. Proper communication (visual or otherwise) must be maintained between the personnel on the platform and the lift operator at all times. The vehicle shall not be moved with the platform in the raised position.
8.3 All personnel in skyl lifts shall wear a full body harness and lifeline that is anchored to the platform cage as a means
of fall protection in addition to the protection provided by the platform cage guard rails.

9. ENVIRONMENTAL RESPONSIBILITIES

9.1 No hazardous or environmentally damaging materials can be poured down process or storm drains.
9.2 It is the responsibility of the Contractor to dispose of hazardous materials that are used by the Contractor (e.g.,
paints, solvents) during their work operations at the facility in accordance with regulatory requirements (DOE).

10. GENERAL WORK PROCEDURES

10.1 Contractors must provide all tools necessary to perform the assigned tasks.
10.2 All tools and equipment must registered and submit one copy to OSHU before start any work at TSG or site.
10.3 All tools and equipment must comply with act and regulation in Malaysia.

11. JOB SAFETY ANALYSIS / HIRAC

11.1 All contractor must submit JSA/HIRAC when requested by OSHU before start any work at TSG or site.

12. SAFETY BRIEFING

12.1 All contractor or and employees must attend safety briefing conducted by OSHU or JKKP before start any work.

Declaration of Supplier:

We hereby declare the following:
1. We have received a copy of the “Safety & Environmental Requirement” (hereinafter referred to as the agreements with TSG, to comply with its principles and requirements.
2. We agree that this declaration is subject to the substantive law in Malaysia without reference to any of its conflict of law rules.

Code of Practice

OVERVIEW

TSG is committed to providing reliable and quality product in High Voltage Switchgear industry. We are also committed to maintaining the highest degree of integrity and in a social and environmentally responsible manner in all our dealings with potential, current and past clients.

OBJECTIVE

This Supplier Code of Practice defines the basic requirements placed on TSG’s suppliers of goods and services. TSG expectation is that the supplier will lawfully conduct their business with the same standards of integrity and ethical behavior and comply with TSG’s code. The supplier declares as herewith;

Compliance with Law

Compliance (including our agents, suppliers or sub-contractors) with all applicable legal laws which includes any rule regulation and by-laws and shall indemnity and hold TSG safe and harmless against all claims, demands, losses, fines and penalties which in any way result from us failure to comply with such applicable law.

Confidentiality

Committed to maintaining the highest degree of integrity in all dealings with TSG, both in terms of commercial confidentiality and the protection of all information received in the course of providing the business services concerned. We extend the same standards to all our vendors, suppliers and associates.

Quality assurance

Maintain the quality of our product through constant ongoing review with TSG’s team, of all aims, activities, outcomes and the costeffectiveness. We encourage regular review meetings and provide regular progress reports. Further details are available on request. We are providing the best value to TSG, our commitment to providing our excellent goods and services. We consider the safety and quality of our products to be of paramount importance and to comply with government, TSG and company safety requirements and specifications at all times.

Supply Chain

Use reasonable efforts to promote among our suppliers compliance with this Code of Conduct and we committed to comply with the principles of non-discrimination with regards to supplier selection and treatment.

Foreign workers employment

Always ensure and enforce that no illegal foreign workers are employed at anytime whatsoever.

Prohibition of Child Labor

No employment workers under the age of 15, in those countries subject to the developing country exception of ILO Convention 138, to employ no workers under the age of 14.

Contracts

Contract will usually be in the form of a proposal, including objectives, activities, costs, timescales and deliverables. The quality of our service and the value of our support provide the only true basis for continuity. We always try to meet TSG contractual requirements, and particularly for situations where an external funding provider requires more official parameters and controls.

Professional Conduct

Conduct all of our activities professionally and with integrity. We take great care to be completely objective in our judgement and any recommendations that we give, so that issues are never influenced by anything other than the best and proper interests of our clients.

Labor and Human Right

Committed to observing fair labor practices and treating our employees with dignity and respect. We will ensure our supply partners to make the same commitments in their business practices by having controls and measures in place that:

• Verify the employment eligibility and compliance to relevant act / law;
• Respect the right of employees;
• Ensure compliance with applicable wage and hour laws;
• Prohibit discrimination, harassment, forced labor, and child labor.

Equality and discrimination

Always strive to be fair and objective in our advice and actions, and we are never influenced in our decisions, actions or recommendations by issues of gender, race, creed, color, age or personal disability.

Payment

Flexible as possible in the way that our services are charged. We make no attempt to charge interest on late payments, so we expect payments to be made when agreed.

Environment, Health and Safety

Environment, Health and Safety Committed to conducting business in a safe, environmentally responsible manner. We expect our supply partners to operate in a manner that:

• Complies with all applicable environmental, health, and safety laws, regulations, and standards;
• Strives to manage responsibly the impacts of their operations on the environment and the operations
• Makes continuous efforts to achieve a workplace that is free from work-related injuries and illnesses.

Anti-Bribery Policy

TENAGA NASIONAL BERHAD

                                        Tenaga Nasional Berhad 129 Jalan Bangsar,

                                                               P.O. Box 11003

50732 Kuala Lumpur, Malaysia

TITLE:

ANTI-BRIBERY POLICY

Document Number: TCIMS-001

Contents

1. Background................................................................................................................... 3
2. Objective...................................................................................................................... 3
3. Scope........................................................................................................................... 3
4. References.................................................................................................................... 3
5. Definitions.................................................................................................................... 4
6. Policy owner.................................................................................................................. 6
7. Policy........................................................................................................................... 6
8. Sanctions for non-compliance........................................................................................ 11
9. Waiver........................................................................................................................ 11
10. Review & Inspection..................................................................................................... 11

1.  Background

The main item of legislation relevant to TNB in the context of anti-bribery is the Malaysian Anti- Corruption Commission Act 2009 (“MACCA”). Specific offences under the Act include accepting gratification, corruptly procuring a withdrawal of tender, bribery of an officer of a public body, bribery of a foreign public official, and using office or position for gratification. Upon conviction of bribery- related offences, TNB as a company may receive a significant fine and suffer lasting damage to its finances and reputation. In addition, the company’s directors and personnel may face fines, imprisonment or both. This matter is therefore to be taken with the utmost seriousness by all parties involved in conducting the business of TNB. Having a clear and unambiguous policy statement on TNB’s position regarding bribery forms the cornerstone of an effective integrity management system.

This anti-bribery policy has been developed as part of the much larger TNB Corporate Integrity Management System (TCIMS) and should be read in conjunction with its supporting documents. If multiple documents speak on the same subject, then the most stringent provision always applies.

2.  Objective

This policy sets out TNB’s overall position on bribery in all its forms.

3.  Scope

This policy is applicable to TNB, the BOD and TNB Personnel along with its Controlled Organisations, their BODs and personnel (together, TNB or the TNB Group); also the BODs and personnel of Business Associates when they are acting on TNB’s behalf.

4.  References

a)      ISO 37001:2016

1. 2. TNB Code of Ethics
   3. TCIMS Glossary of Terms
   4. TNB Conflicts of Interest policy
   5. TNB Gifts, Hospitality and Related Benefits Policy
   6. TNB Integrity Pact Policy
   7. TNB Whistleblowing Policy
   8. TCIMS Monitoring and Review Procedure

5.  Definitions

The following definitions are included in this policy. For additional definitions, see the TCIMS Glossary.

6.  Policy owner

The ID is the owner of this policy.

7.  Policy
   1. Anti-Bribery Policy
      1. Our policy is that bribery in all its forms related to TNB’s activities is prohibited.
      2. Bribery may take the form of anything of value, such as money, goods, services, property, privilege, employment position or preferential treatment. TNB Personnel and its Business Associates shall not therefore, whether directly or indirectly, offer, give, receive or solicit any item of value, in the attempt to illicitly influence the decisions or actions of a person a position of trust within an organisation, either for the intended benefit of TNB or the persons involved in the transaction.
      3. The anti-bribery policy applies equally to its business dealings with commercial (‘private sector’) and government (‘public sector’) entities, and includes interactions with their directors, personnel, agents and other appointed representatives at all levels. Even the possible appearance of bribery is to be avoided, in particular when dealing with government officials.
      4. The anti-bribery policy applies to all countries worldwide, without exception and without regard to regional customs, local practices or competitive conditions.
      5. Therefore, TNB does not permit Facilitation Payments even when they are customary under the circumstances.
      6. TNB holds a ‘No Gifts’ Policy. However, there are certain exceptions. Gifts and hospitality are acceptable provided they (1) are limited, customary and lawful under the circumstances; and

(2) do not have, or are perceived to have (by either the giver or the receiver), any effect on actions or decisions. Specifically, with respect to gifts and hospitality, (a) there should be no expectation of any specific favour or improper advantages from the intended recipients; (b) the independent business judgment of the intended recipients must not be affected; (c) there

must not be any corrupt / criminal intent involved; and (d) the giving out of the gift and hospitality must be done in an open and transparent manner. Further details are set out in the Gifts, Hospitality and Related Benefits Policy.

1. 1. 7. It is TNB’s policy that no employee or external party will suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes or other illicit behaviour, even if such refusal may result in the company losing business or experiencing a delay in business operations.
      8. TNB recognises the value of integrity in its personnel and directors. Personal integrity should be considered as a part of TNB’s approach to recruitment, training, performance evaluation, remuneration, and promotion.
      1. TNB does not offer employment to prospective personnel in return for their having improperly favoured TNB in a previous role.
   2. Recognition of local and international legislation
      1. TNB is committed to observing the laws and regulations which govern our operations in every country where we do business.
      2. Basic Prohibition: TNB is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including but not limited to the Malaysian Penal Code (revised 1977) (and its amendments), the Malaysian Anti-Corruption Commission Act 2009, (and its amendments), the Companies Act 2016 (Malaysia), the US Foreign Corrupt Practices Act 1977 (amended 1998), and the UK Bribery Act 2010. These laws prohibit bribery and mandate that companies establish and maintain accurate books and records and sufficient internal controls.
   3. Business Associates
      1. TNB may be held legally responsible for the actions of Business Associates acting on its behalf (commonly called a ‘Third Party’). As such, care must be taken to ensure that such entities do not attempt to engage in bribery. If concerns about a Business Associate persist, TNB must not engage or use the services of the entity.
      2. TNB must ensure that all Business Associates acting on behalf of TNB contractually agree to comply with this policy, particularly the Basic Prohibition in 7.2, and other relevant TNB policies, which sets out TNB’s general position on integrity and business ethics.
      3. Due diligence should also be carried out with regards to any Business Associate intending to act on the company’s behalf as an agent or in other representative roles, to ensure that the entity does not commit an act of bribery in the course of its work with TNB. Due diligence should be based on a bribery risk assessment. Due diligence may include a search through relevant databases, checking for relationships with public officials, and documenting the reasons for choosing one particular Business Associate over another. The results of the due diligence process must be documented, retained for at least seven years and produced on request by the custodian of the process.

1. 4. Responsibilities of TNB Personnel
      1. This policy is applicable to all TNB Personnel (including the directors of TNB and its Controlled Organisations), and it seeks to impose specific responsibilities and obligations that are properly reflected in employment contracts, evaluations, incentives and promotional procedures and enforced through standard disciplinary measures.
      2. With respect to directors of TNB and its Controlled Organisations, their specific roles include the following:
         1. Promote good corporate governance practices relating to anti-bribery;
         2. Demonstrate support for the implementation and enforcement of this policy;
         3. Demonstrate model behaviour and lead by example by complying with this policy;
         4. Be watchful and alert for signs of possible misconduct or inappropriate behaviour which may relate to bribery;
         5. Not condone improper practices and to take stern actions when required;
         6. Promote the use of whistleblowing mechanisms within TNB and give assurance on the protection of whistleblowers.
      3. All TNB Personnel are responsible for understanding and complying with this policy. In particular, the role of all TNB Personnel includes the following:
         1. Be familiar with applicable requirements and directives of the policy and communicate them to subordinates;
         2. Promptly record all transactions and payments accurately and in reasonable detail;
         3. Always raise suspicious transactions to immediate superiors for guidance on next course of action;
         4. Ask the ID if any questions about this policy arise or if there is a lack of clarity about the required action in a particular situation;
         5. Be alert to indications or evidence of possible violations of this policy;
         6. Promptly report violations or suspected violations through appropriate channels;
         7. Participate in integrity and anti-bribery training as determined by the position.
      4. TNB Personnel in a supervisory position have a particular responsibility to ensure that the TCIMS requirements are applied and complied with within their department or function and to monitor compliance with the policy. They also must ensure that subordinates in ‘Exposed Positions’ attend relevant training.
      5. When dealing with external providers offering goods and services to the company, TNB Personnel shall not:
         1. express unexplained or unjustifiable preference for certain parties;
         2. exert improper influence to obtain personal benefits from them.
      6. When dealing with external parties in a position to make a decision to TNB’s benefit (such as a Government official or client), TNB Personnel shall not:

1. 4. 1. 1. offer, promise or make any attempt at dishonestly influencing the person’s decision by directly or indirectly offer or make promise of corrupt payments, in cash or in kind;
         2. be involved in any discussions regarding business or employment opportunities, for their own personal benefit or for the benefit of the external party;
         3. otherwise abuse the decision-making and other delegated powers given by the senior management, in order to illicitly secure an outcome which would be to the commercial advantage to themselves and/or the company.
   5. Staff declarations
      1. All new TNB Personnel must sign an acknowledgement at the beginning of their employment that they have read and understand this policy and the TNB Code of Ethics for TNB’s general position on integrity and business ethics.
      2. All TNB Personnel shall sign an Integrity Pledge on a regular basis.
      3. All TNB Personnel shall declare any Conflicts of Interest, as stated in the Conflicts of Interest Policy.
   6. Anti-bribery compliance function
      1. TNB shall establish and maintain an anti-bribery compliance function, the Integrity Department (ID) to oversee the management of the TCIMS.
      2. The ID shall be recognised as an independent authority within the company structure, equipped to act effectively against bribery, with the Chief Integrity Development Officer (CIDO) reporting directly to the Chairman of the BIC.
      3. TNB shall conduct regular risk assessments to identify the bribery risks affecting the business, set the company’s anti-bribery objectives, and assess the effectiveness of the controls in achieving those objectives. This process will ensure the TCIMS is appropriate for the purpose of the organisation and inform further improvements of the system.
      4. The ID shall be resourced and staffed to a level in keeping with the size of TNB, the risk given the business activities of TNB and the scope of the TCIMS. The BIC shall ensure that appropriate resources are provided for effective operation of the TCIMS and that the ID is staffed with persons who have the appropriate competence, status, authority and independence.
      5. The ID shall provide advice and guidance to personnel on the anti-bribery management system and issues relating to bribery.
      6. The ID shall take steps to ensure that appropriate monitoring, measurement, analysis and evaluation of the TCIMS is performed.
      7. The ID shall report on the performance of the TCIMS to the BIC and ISC regularly, including results of any investigations and audits.
      8. The ID shall have clear terms of reference with a scope of work covering the TCIMS and directly related matters.

0. 7. Training
      1. TNB shall endeavour to conduct a training and awareness programme for all TNB Personnel on the company’s position regarding anti-bribery, integrity and ethics.
      2. TNB shall provide appropriate integrity training for all TNB Personnel who are any or all of the following:
1. new to the company;
2. promoted to a management position or a position involving budget control for the first time;
3. appointed to or currently holding a position where bribery is considered a medium or high risk.
   7. 3. Training should be repeated on a regular basis, in accordance with the level of bribery risk related to the position.
      4. All personnel in ‘Exposed Positions’ should complete tailored anti-bribery training within 3 months of taking the position.
      5. TNB shall maintain records to identify which TNB Personnel have received training, and produce, communicate and update the training schedule in conjunction with ID to ensure the training policy is adhered to.
   8. Reporting of policy violations
      1. TNB shall establish and maintain suitable reporting (‘whistleblowing’) channels for receiving information regarding violations of this policy, and other matters of integrity provided in good faith by TNB Personnel and/or external parties.
      2. Personnel who, in the course of their activities relating to their employment at TNB, encounter actual or suspected violations of this policy are required to report their concerns using one of the reporting channels.
      3. Reports made in good faith shall be addressed in a timely manner and without incurring fear of reprisal regardless of the outcome of any investigation.
      4. Retaliation in any form against TNB Personnel where the person has, in good faith, reported a violation or possible violation of this policy is strictly prohibited. Any TNB Personnel found to have deliberately acted against the interests of a person who has in good faith reported a violation or possible violation of this policy shall be subjected to disciplinary proceedings including demotion, suspension, dismissal or other actions (including legal action) which TNB may choose to take.
      5. See the Whistleblowing Policy for further information.
   9. Non-compliance
      1. ID shall conduct regular audits to ensure compliance to this policy in accordance with the TCIMS Monitoring and Review Procedure. Such audits may be conducted internally by TNB or externally by designated Business Associates. Audit documentation should include performance improvement action plans.

1. 9. 2. Non-compliance as identified by the audit and any risk areas identified through this and other means shall be reported to the ISC in a timely manner in accordance with the level of risk identified.
   10. Continuous improvement
       1. In maintaining the TCIMS, TNB is committed to satisfy ISO 37001:2016 anti-bribery management system requirements.
       2. TNB shall monitor the legal and regulatory regimes where it operates, and identify any changes to TNB’s business environment and risks in order to identify opportunities for improvements to the TCIMS. A report shall be submitted to the BIC on a regular basis for the BIC to take appropriate action.
       3. The BIC shall conduct regular assessments (at least every two years) of the TCIMS, to ensure its scope, policies, procedures and controls match the bribery and other bribery-related risks faced by TNB.
       4. TNB endeavours to impact the business environment where it operates. This may include extending its integrity programme to non-Controlled Organisations, suppliers and contractors, seeking to work with companies who have a similar commitment and supporting initiatives in the private and public sectors which are likely to improve the integrity of its operating environment.

8.  Sanctions for non-compliance

TNB regards bribery as a serious matter and will apply sanctions in the event of violations of this policy. For TNB Personnel, non-compliance may lead to disciplinary action, up to and including termination of employment. Further legal action may also be taken in the event that TNB’s interests have been harmed by the results on non-compliance by individuals and organisations.

9.  Waiver

Any deviation or waiver from this policy must be approved either by the ISC or BIC.

10.  Review & Inspection

The Integrity Department will review the suitability of this policy from time to time, in accordance with the TCIMS Monitoring and Review Procedure.