EIG ANTI-BRIBERY & CORRUPTION POLICY

INTRODUCTION

The Board of Directors (the “Board”) of Esthetics International Group Berhad (the “Company”), its subsidiaries and associate companies (collectively “EIG” or the “Group”) has established and adopted this Anti-Corruption and Bribery Policy (“Policy”). This Policy is to prevent the occurrence of corruption and bribery practice in relation to the businesses of EIG. EIG strives to conduct its business in a legal and ethical manner. EIG will ensure its businesses or any transactions do not participate in corruption activity for its advantage or benefits.

OBJECTIVES

The objective of this Policy is to:

• set out our responsibilities to comply with laws against bribery and corruption; and
• provide information and guidance to the Board of Directors and employees of EIG on how to recognize and deal with corruption and bribery issues.

RESPONSIBILITY AND IMPLICATIONS

This Policy shall apply to all directors, managers and employees (either permanent, contract or temporary) of EIG in dealing with external parties in the commercial context.

All employees of the Group must refrain from any acts of bribery which takes the form of offering, promising, giving, demanding or receiving anything of value to anyone in the form of bribes, kickbacks and/or any other improper gratification (including gifts, hospitality and entertainment) to improperly influence the outcome of any transaction, whether it is for their own personal benefit or for the benefit of the Group.

EIG strictly does not tolerate any bribes given for purposes of obtaining or retaining business or provides an advantage to the businesses of EIG. EIG does not tolerate any such acts of bribery even in a personal capacity.

Any employee of the Group that breaches any of the Policy may fall within the scope of serious misconduct and may be subjected to disciplinary action, up to and including dismissal, depending on the facts and circumstances of each case.

ANTI-BRIBERY AND CORRUPTION

a) All forms of bribery and corruption are prohibited. EIG upholds a zero tolerance approach. In addition to no bribery, Employees must not participate in any corrupt activity, such as extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering.

b) Bribery may take the form exchange of money, goods, services, property, privilege, employment position or preferential treatment. Employees shall not therefore, whether directly or indirectly, offer, give, receive or solicit any item of value, in the attempt to illicitly influence the decisions or actions of a person in a position of trust within an organisation, either for the intended benefit of the Group or the persons involved in the transaction.

c) This Policy applies equally to its business dealings with commercial (‘private sector’) and government (‘public sector’) entities, and includes interactions with their directors, Employees, agents and other appointed representatives at all levels. Even the perception of bribery is to be avoided.

d) This Policy applies to all countries worldwide, without exception and without regard to regional customs, local practices or competitive conditions.

e) No Employee will suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes or other illicit behaviour, even if such refusal may result in the company losing business or experiencing a delay in business operations.

f) EIG recognises the value of integrity in its Employees and Directors and trust/integrity is a key core value of the Group.

g) EIG does not offer employment to prospective employees in return for previous favour/in exchange of improper favour.

h) Any violation of the Policy by employees of the Group will attract serious repercussions and disciplinary action after due inquiry. Where there is strong evidence of bribery and corruption committed by any employee of the Group, the employee can be dismissed.

i) Employees who are found to have assisted or facilitated the violation of the Policy, whether actively or by way of negligence or omission, will also be deemed to have violated the Policy and committed a misconduct that is liable for dismissal from their employment with the Group.

GIFTS, HOSPITALITY AND ENTERTAINMENT

All persons who are subject to this Policy shall NOT:

a) offer, give, or promise to give a bribe or anything which may be viewed as a bribe to secure or award an improper business advantage, or to reward the recipient for a decision already made;

b) request or receive a bribe or anything which may be viewed as a bribe from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them, or to reward for a decision already made; and/or

c) engage in any activity that might lead to a breach of this Policy.

No gifts in cash or cash equivalent shall be given to any public officials under any circumstances and any non-cash gifts, entertainment and hospitality given to public officials must be first approved by the Group Managing Director & CEO or Executive Directors and recorded in the Register maintained by the Finance Department.

All persons who are subject to this Policy shall not accept or receive any Gift, Hospitality and/or Entertainment from a third party or stakeholder of the Group except if it is made from gestures that are construed to be legitimate contribution and provided that the Gifts, Hospitality and/or Entertainment are consistent with the customary business practice, not lavish in nature, presented in good faith and cannot be interpreted as inducements to trade. Further details are set out in the Code of Conduct and Human Resource Handbook under “Gifts, Entertainment and Hospitality “.

FACILITATION PAYMENTS

The Group adopts a strict stance that disallows facilitation payments. Employees should ensure that these facilitation payments are not paid.

SPONSORSHIPS, DONATIONS AND CHARITABLE CONTRIBUTIONS

Sponsorships, contributions or charitable donations made by EIG to community projects or charities is permissible depending on the circumstances and made in good faith directly to an official entity, and subject to approval from the Executive Directors and relevant Business Unit Head.

REPORTING FOR VIOLATIONS OF POLICY & WHISTLEBLOWER RIGHTS

Where there are reasonable grounds and genuine reasons to suspect that there is a violation of the Policy, employees of the Group are required to report the particulars of such suspicions to the Group’s dedicated channel for reporting, which includes via email to whistleblower@estheticsgroup.com or to the Director of Corporate Affairs. Confidentiality of all matters raised and the identity of the whistleblower are protected and any such reports will be read and addressed by a dedicated compliance team.

Any reports made for violation of the Policy will be treated very seriously and accordingly. Employees are similarly responsible to ensure that they exercise sound judgment that it is a genuine threat and violation of the Policy, they have evidence to support their allegations of any violations of the Policy, are available to provide evidence in any inquiry of such violations, and are not frivolous reports with the motive to scandalise.

EIG ensures that there will be no retaliation or repercussions on the employee for making genuine reports on violation of the Policy. Any genuine reports made will be kept strictly confidential and only informed to persons on a need-to-know basis to safeguard the interests of the Group and also to ensure that any processes undertaken will not be compromised.

COMMUNICATION AND TRAINING

The Group will on a continuing basis provide regular training on this Policy, and on anti-corruption and bribery laws and on how to implement and comply with this Policy, for all new and existing employees.

Our zero-tolerance approach to corruption and bribery must be communicated to all business partners i.e. clients, customers, outsourcing providers, contractors, consultants, suppliers, vendors, advisers, agents, distributors, representatives, intermediaries and investors at the outset of our business relationship with them and as appropriate thereafter.

This Policy is a public document. All EIG employees and business partners must read and understand EIG’s position on anti-bribery and anti-corruption or shall always refer to this Policy published on our Company webpage.

MONITORING AND REVIEW OF THE POLICY

EIG and its Board of Directors will be monitoring compliance of the Policy.

Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering corruption and bribery.