DC Anti-Bribery & Corruption Policy

1. Introduction

Data Cohorts is committed to conducting its business with integrity, transparency, and in full compliance with all applicable laws and regulations, including those related to anti-bribery and corruption. This policy outlines our commitment to preventing bribery and corruption in all aspects of our operations and sets forth the standards and procedures that employees, contractors, suppliers, and other stakeholders must adhere to.

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2. Applicability

This policy applies to all employees, contractors, suppliers, consultants, agents, and any other individuals or entities acting on behalf of Data Cohorts.

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3. Prohibited Conduct

a. Bribery: Data Cohorts strictly prohibits the offering, giving, receiving, or solicitation of any form of bribe, kickback, or facilitation payment, whether directly or indirectly, to or from any person or entity, including government officials, private individuals, or business partners.

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b. Conflicts of Interest: Employees must avoid situations where their personal interests conflict with the interests of Data Cohorts. Any potential conflicts of interest must be disclosed promptly to management.

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4. Compliance with Laws

Data Cohorts is committed to complying with all applicable anti-bribery and corruption laws and regulations in Malaysia, including but not limited to:

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• Malaysian Anti-Corruption Commission Act 2009

• Penal Code (Amendment) Act 2013

• Companies Act 2016

• MACC (Amendment) Act 2018

• Whistleblower Protection Act 2010

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5. Gifts, Entertainment, and Hospitality

Employees must exercise caution when giving or receiving gifts, entertainment, or hospitality to or from clients, suppliers, or other parties. Any gifts or hospitality provided or received must be of modest value, transparent, and given or accepted with the sole purpose of maintaining goodwill or business relationships.

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6. Reporting Mechanism

Employees are encouraged to report any suspected instances of bribery or corruption promptly through the appropriate channels, including the designated whistleblowing mechanism established by [Company Name]. Reports will be treated confidentially, and whistleblowers will be protected from retaliation.

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7. Training and Awareness

Data Cohorts will provide regular training and awareness programs to educate employees about the risks of bribery and corruption, their obligations under this policy, and the consequences of non-compliance.

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8. Monitoring and Enforcement

Data Cohorts will monitor compliance with this policy and investigate any suspected violations. Non-compliance may result in disciplinary action, termination of employment, or legal prosecution as per the law.

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9. Review and Update

This policy will be reviewed periodically to ensure its effectiveness and compliance with changes in laws and regulations. Updates will be communicated to all relevant stakeholders.

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10. Conclusion

Data Cohorts is committed to fostering a culture of integrity, honesty, and accountability. By adhering to this anti-bribery and corruption policy, we aim to maintain the trust and confidence of our stakeholders and uphold the highest standards of ethical conduct in all our business activities.