Anti-Bribery and Corruption Policy

United Overseas Bank (Malaysia) Bhd (UOBM) upholds integrity and compliance with legal and regulatory requirements as part and parcel of its business operations. There is a strong tone from the top with the Board overseeing a governance structure that is designed to ensure that the Bank’s business activities are: -

• conducted in a safe and sound manner and in line with the highest standards of professionalism and ethical standards whilst complying with legal and regulatory requirements;
• consistent with the Bank’s overall business strategy, risk appetite and strong risk culture;
• subjected to adequate risk management and internal controls.

In Malaysia, under the Malaysian Anti-Corruption Commission Act 2009 (MACC Act 2009), it is an offence for a person to solicit or receive gratification, offer or give gratification as an inducement to or a reward for doing or forbearing to do any act in relation to any matter or transaction, actual or proposed or likely to take place. This includes matter or transaction the person is carrying out as an agent for his principal in relation to the principal’s affairs or business. 

With Section 17A of the MACC Act 2009 having come into effect on 1 June 2020, it introduces the notion of corporate liability. A commercial organisation commits an offence if a person associated with the commercial organisation corruptly gives, agrees to give, promises or offers to any person any gratification where such corrupt practices are carried out for the commercial organisation’s benefit or advantage. 

UOBM adopts a zero tolerance policy against any form of bribery and corruption, and all other illegal or unethical behaviour. The UOB values - Honourable, Enterprising, United and Committed – are at the heart of our Code of Conduct which lays down the principles of personal and professional behaviour expected of all UOB employees. The Bank takes a strong stance against any behaviour that undermines the strong reputation that it has built. All UOBM employees are expected to be in full compliance with all laws and regulations governing bribery and corruption, including laws with extra territorial jurisdiction effect such as the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act. Where relevant, the same standards apply to those who represent us – from agency staff to vendors and business associates. Any employee or business associate found guilty of bribery or corruption shall be subject to severe disciplinary action, including termination of employment or termination of contract, as appropriate, and may also be subject to prosecution under applicable anti-corruption laws. 

In compliance with Section 17A MACC Act, UOBM has established adequate procedures to combat bribery and corruption by putting in place the following measures: -

• regular communication to promote and maintain a risk-focused culture with the highest ethical standards;
• mandatory training on anti-bribery matters for new and existing employees;
• rules on record keeping;
• rules regarding gift and entertainment;
• rules regarding donations and sponsorship;
• strict prohibition on the promise or payment of bribes/facilitation payments;
• mandatory due diligence checks for business associates/vendors;
• conducting periodic risk assessment across all key business and support units;
• adopting the three lines of defence model i.e. Risk Owner, Risk Oversight and Independent Audit;
• maintaining a repository of frameworks, policies and procedures & guidelines that address/mitigate bribery and corruption risk;
• established a whistleblowing policy that provides an avenue for any individual to report any suspected wrongdoings to the Head of Internal Audit, Chairman of the Audit Committee or Chairman of the Board in good faith and without fear of reprisal.

The Bank remains steadfast in its fight against bribery and corruption by regularly reviewing the above control mechanisms and creating adequate awareness to ensure it remains free from the contagion of corruption.