UEM EDGENTA BERHAD Integrated Annual Report 2025 254 Our ABAC programme is guided by the T.R.U.S.T principles under the Guidelines on Adequate Procedures pursuant to Section 17A(5) of the Malaysian Anti-Corruption Commission Act 2009. These principles provide the foundation for preventing, detecting, and responding to bribery and corruption risks. Reinforcing our commitment to integrity and governance in all business operations, UEM Edgenta has achieved the internationally recognised MS ISO 37001:2016 Anti-Bribery Management System (“ABMS”) certification. This certification demonstrates our commitment to internationally recognised standards and best practices in anti-bribery management. ANTI-BRIBERY AND ANTI-CORRUPTION POLICIES AND PROCEDURES To support ethical business conduct and meet our regulatory obligations, the Group has established a comprehensive framework, policies and procedures aimed at preventing bribery and corruption. These policies and procedures set clear standards of behaviour and accountability across the Group and, where applicable, to our business partners. The following measures form the foundation of our integrity: • Code of Conduct (“COC”) for Directors and Employees UEM Edgenta’s Code of Conduct (“COC”) for Directors and Employees articulates our commitment to maintaining trust and integrity across all levels of the organisation. It sets out the ethical principles and standards of behaviour expected of all directors and employees across the Group, forming the foundation of our integrity. The COC outlines the principles and values that shape how we conduct ourselves with colleagues, clients, business partners, and the broader community. During the financial year 2025, the COC was reviewed and updated to strengthen our governance and alignment with best practices. • Code of Conduct for Business Partners (“COCBP”) UEM Edgenta’s Code of Conduct for Business Partners (“COCBP”) sets out the standards of integrity, ethical behaviour, and compliance expected of our suppliers, contractors, consultants, agents, and other business partners. It establishes clear requirements for adherence to applicable laws and regulations, anti-bribery and anti-corruption principles, and responsible business practices in all engagements with the Group. By requiring our Business Partners to align with these standards, we reinforce a shared commitment to transparency, accountability, and ethical conduct throughout our value chain. In addition, the Group performs integrity and anti-corruption due diligence on prospective business partners, including suppliers, contractors, consultants and agents, prior to entering into business relationships. The due diligence process assesses potential risks relating to bribery, corruption, conflicts of interest and other unethical conduct, and ensures that business partners commit to complying with the Group’s Code of Conduct for Business Partners and Anti-Bribery and Anti-Corruption (“ABAC”) policies. This is further formalised through the Business Partners Letter of Declaration, which requires the Business Partner to acknowledge and commit to the Group’s integrity and antibribery policies as part of the onboarding and contracting process. • Compliance Framework The compliance framework establishes a structured and systematic approach to managing regulatory compliance obligations and mitigating compliance risks or issues, to ensure alignment with the Group’s compliance objective. The Framework defines the governance structure, roles and responsibilities for overseeing compliance matters, and set out the policies, processes, and monitoring mechanisms that form the foundation of UEM Edgenta’s compliance management system, fostering accountability and a culture of integrity in all aspects of our operations. • Conflict of Interest (“COI”) Policy The Conflict of Interest (“COI”) Policy provides clear guidance on identifying, managing, and resolving actual, potential, or perceived conflicts of interest involving Directors and employees. This Policy is designed to safeguard UEM Edgenta’s interests by ensuring that decisions and actions are made with integrity, transparency, and ethical conduct and to ensure that any actual, potential, or perceived conflicts of interest are identified and managed effectively. By effectively managing conflicts of interest, we reinforce trust, accountability, and fairness in all our business dealings. • Conflict of Interest (“COI”) Declaration Procedure The Conflict of Interest (“COI”) Declaration Procedure provides a structured process for employees to declare actual, potential, or perceived conflicts of interest in alignment with the Conflict of Interest (“COI”) Policy. This procedure outlines the steps for identifying, disclosing, and addressing conflicts of interest to ensure they are managed effectively and transparently. By adhering to this procedure, we reinforce our commitment to ethical conduct, accountability, and the protection of the Group’s integrity in all business activities. CORPORATE INTEGRITY AND ETHICAL BUSINESS CONDUCT
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