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Financial Reports &
              Governance                Other Information         HENGYUAN REFINING COMPANY BERHAD  l  ANNUAL REPORT 2023  75








                HRC’s business integrity management comprises the   b.  BUSINESS INTEGRITY ACTIVITIES
                following key controls:
                                                                       Various  activities  were organised  to  strengthen  the
                a.  ANTI-BRIBERY MANAGEMENT SYSTEMS MANUAL             culture of business integrity in line with HRC’s core
                                                                       values.
                   Business integrity is recognised as one of the main pillars
                   of HRC’s General Business Principles. All employees      In December 2023, the Risk and Integrity Department
                   are expected to exercise integrity regardless of their   organised the annual Business Integrity Week.
                   department or career level as Integrity is one of the     The programme, called  “ICARE for Integrity - Integrity
                   HRC’s core values.                                  Matters” was organised to reinforce the core value
                                                                       of HRC. A talk on  “Integrity and Sustainability” was
                   The HRC Anti-Bribery Management Systems Manual      delivered by the officer from Malaysian Anti-Corruption
                   (ABMS Manual) outlines the procedure, integrity     Commission (MACC). Other talks were organised
                   screening and ethical behaviours expected from      to strengthen ethical decision making in line with
                   the employees and business associates to avoid any     Environmental, Social and Governance (ESG) initiatives.
                   instances of bribery, corruption or receipt of monies   “Integrity Run”, a fun programme had been carried
                   derived from money laundering activities.
                                                                       out during the annual Business Integrity Week to
                   The ABMS Manual was approved by the Board who is    foster integrity at work.
                   committed to ensuring that ethical business practices        These  activities were  organised  to  reinforce  ethical
                   are being adhered to and adequate controls have been   leadership, good governance, accountability and
                   put in place by the Company to mitigate the risk of   individual integrity.
                   bribery and corruption.
                   The ABMS Manual covers areas such as:         6.  COMPLIANCE MANAGEMENT
                   i.  The contracting and procurement process         The  Management  team  led  by  the CEO  is  responsible
                                                                       for ensuring day to day operational compliance within
                   ii.  Offering and receiving gifts and hospitality
                                                                       the Company.
                   iii. Conflicts of interest
                                                                       HRC’s  compliance  management includes compliance
                   iv. Facilitation payments                           to all relevant laws, regulations, rules and guidelines.
                                                                       It also covers risk-based compliance to the Company’s
                   v.  Funding social investment, donation and sponsorship
                                                                       internal policies, procedures, and code of conduct.
                   vi. Political payments and activities
                                                                       In 2023, no major non-compliance was encountered.
                   vii. Recruitment
                                                                 7.  CODE OF CONDUCT
                   The ABMS Manual and its contents have been
                   communicated to all employees via memorandum,       The Code of Conduct (Code) applies to every employee,
                   HRC’s intranet and in-house training. The same has also   officer, and director in HRC as well as contract employees
                   been communicated to all vendors, suppliers, contractors   working for HRC. Contractors and consultants who are
                   and any third parties that have business dealings    agents of, or working on behalf of, or in the name of HRC
                   with HRC.                                        (through outsourcing of services, processes or any business
                                                                    activity), are required to act consistently with the Code
                   Employees and parties having business dealings with
                   HRC have also been requested to sign an integrity     when acting on HRC’s behalf. Contractors and consultants
                   pledge to show their commitment towards ABMS     are  also  made  aware  of  the  Code  as  it  applies  to  their
                   Manual  and  to  disclose  any  confirmed  or  potential   dealings with HRC employees.
                   conflict of interest via HRC’s annual declaration process.
                   Business associates and senior management are subject
                   to integrity due diligence checks from time to time.

                   The  ABMS Manual and  HRC’s  General  Business
                   Principles are accessible to the public on HRC’s corporate
                   website.
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