ONEASIA HOLDINGS LIMITEDMANAGEMENT POLICY AND MANUAL
Policy #: OA-CP-008-OPS

Title: Anti-Bribery Policy for Vendor

ContentsI.

Purpose ........................................................................................................................ 2

II. Scope ........................................................................................................................... 2III.

Commitments ............................................................................................................ 2IV.

Guidelines ................................................................................................................. 2V.

Acknowledgement ..................................................................................................... 3

Document Version
Version Number

Revision Date

Document Owner

01

21st November 2022

Operations Manager

PolicyPage 1 of 3

ONEASIA HOLDINGS LIMITEDMANAGEMENT POLICY AND MANUAL
Policy #: OA-CP-008-OPS

I.

Title: Anti-Bribery Policy for Vendor

PurposeThis Policy explains the anti-bribery obligations that the external parties (the “Vendor”) must comply with when
doing business with any companies of OneAsia Holdings Limited (the “Group”).

II.

Scope
This Policy is applicable to any Vendor, including contractors, suppliers, consultants, agencies, service providers
or anyone who has direct business relationship with or perform services for any subsidiary of the Group.

III.

Commitments
The Group has determined that we do not and will not, pay bribes or offer improper inducements to anyone forany purpose, nor do we or will we, accept bribes or improper inducements.
The Vendor shall comply with the Group’s Anti-Bribery Policies, and local, regional or country anti-bribery laws
and regulations, regardless of local business practices or social customs.

IV.

Guidelines
1. Follow code of conduct
1) As a party doing business with the Group, you shall comply with this Policy.
2) The Group expects its business to be conducted with uncompromising integrity and professionalism.
This expectation applies to Group employees and Vendor when conducting business or providing
services on the Group’s behalf. Vendor shall read, understand and comply with the Group’s Policy in allrespects.

2. No facilitation payments
A facilitation payment is a financial payment that may constitute a bribe and is made with the intention ofexpediting an administrative process. It is a payment made to a public or government official that is meant
to be an incentive for the official to smooth or expedite certain actions or process to the benefit of the party
making the payment.
The Group will NOT accept the offering of any facilitation payments and prohibits all Vendor from making
any facilitation payments directly or indirectly on behalf of the Group.

3. Due Diligence
In the process of Vendor registration, the Group shall conduct due diligence checks. Vendor will be required
to provide relevant documents including but not limited to valid business registration documents. We will
also take reasonable risk management measures in respect of persons who perform or will perform services
for or on behalf of the Group for the purpose of identifying and mitigating bribery risks.

4. Raise Concerns
Vendor is encouraged to raise any query or concerns and is obliged to report violations or suspectedviolations of this Policy or the anti-bribery and anti-corruption laws to our Anti-Bribery Committee atABCommittee@legangroup.com. You may refer to Appendix A Whistleblowing Report Template for raisingenquiry/concern.

5. Whistle Blowers Protection
PolicyPage 2 of 3

ONEASIA HOLDINGS LIMITEDMANAGEMENT POLICY AND MANUAL
Policy #: OA-CP-008-OPS

Title: Anti-Bribery Policy for Vendor

1) The Group encourages openness and will support anyone who is acting in good faith, even if theconcern/report turns out to be unsubstantiated.
2) The Top Management is committed in ensuring all whistle blowers an entrusted, reliable, fair andconfidential handling of his/her reports.
3) However, if a whistleblower makes false report maliciously, with an ulterior motive, or for personaladvantage, the Group reserves the right to take appropriate actions against anyone to recover any
loss or damage as a result of the false report.
4) The Group will keep the Whistleblower’s identity confidential and only disclose to relevant parties
on a need-to-know basis. However, if the report leads to an investigation by regulators orauthorities, it may become necessary for the Whistleblower to provide evidence or be interviewed
by the relevant regulators or authorities. The Whistleblower will be advised in advance if his/heridentity may become apparent or needs to be disclosed to any external parties outside the Group.
In order not to jeopardize the investigation, the Whistleblower is also required to keep confidential
the fact that he/she has filed a report as well as the nature of concerns and the identities of thoseinvolved.
5) The whistleblowers shall have the right to access or change their own personal data provided to theCommittee. If you wish to exercise these rights, requests shall be made in written and email to theCommittee.

V.

Appendix
A. Whistleblowing Report Template

VI.

Acknowledgement
We acknowledge that we have read, understood and agreed with the policy.

_____________________(Company Name & Chop)______________________
Date:

If you have any questions or concerns, you may visit our website or contact Anti-Bribery Committee for moreinformation.

PolicyPage 3 of 3