FIMM’s ANTI-BRIBERY AND CORRUPTION POLICY

The Federation of Investment Managers Malaysia (FIMM) adopts a zero-tolerance approach to any form of bribery and corruption. FIMM is committed to the prevention and eradication of bribery and corruption practices and will take appropriate measures on parties who in their dealing with FIMM or when acting on FIMM’s behalf are found to not comply with this commitment.

The following set of terms apply generally to all parties who are dealing with or acting on behalf of FIMM:

(1) All parties are not allowed to offer or provide, directly or through any intermediaries, benefits of any kind including, but not limited to, cash or cash equivalents, coupons or discounts on goods/services, paid holidays, hiring or internship, or favour or advantage of any form, whether material or immaterial, to any representative of FIMM for the purpose of:-

(a) influencing them to act contrary to FIMM’s interest; or
(b) obtaining favourable advantage or reward by FIMM with respect to the terms, conditions, price, performance or procurement of an agreement.

(2) All parties are not allowed to collude or instigate other parties to compromise in all dealings with or related to FIMM.

(3) Should there be any real or suspected incident of corruption involving FIMM’s Directors, personnel, service provider, vendor and/ or sub-contractor (if applicable) when dealing with FIMM’s matters, this is to be reported to the:-

The Compliance Officer
Federation of Investment Managers Malaysia
19-06-1, 6th Floor 
Wisma Tune 
19, Lorong Dungun
Damansara Heights 
50490 Kuala Lumpur, Malaysia

(4) Gifts

Gifts as a show of goodwill and hospitality are allowed PROVIDED THAT:

(i) they are not solicited and do not affect, or are perceived to affect, the business judgment when dealing with FIMM; and
(ii) they satisfy the following conditions;

      • they are not in cash or cash equivalent;
      • they are reasonable, proportionate, customary and lawful under the circumstances;
      • they do not have or are perceived to have (by either the giver or the recipient) any improper influence on the actions or decisions of the receiving party;
      • there must be no expectation of any specific favour or improper advantage from the intended recipient;
      • they must not exceed the threshold of RM300 set out in FIMM’s Anti-Bribery and Corruption Policy and Procedures;
      • they do not give rise to an actual, potential or perceived conflict of interest by FIMM; and
      • the receiving and giving of the corporate gift must be done in an open environment and in a transparent manner.

(5) Political donations/contributions

FIMM strictly prohibits any giving or receiving donations/contributions to or from any political organisation or political candidate.

(6) Facilitation payments

FIMM strictly prohibits the practice of accepting and/or soliciting Facilitation Payments of any kind.

 

In addition to the above general terms, all service providers and vendors are required to comply with the following terms for all dealings with FIMM:

(i) Service providers and vendors are required to take all measures to prevent corrupt practices in their dealings with FIMM or when acting on FIMM’s behalf.
(ii) Service providers and vendors are required to make conflict of interest declarations on the following:

      • That FIMM’s directors, employees and/ or any of their Close Associate[1] does not have ownership or interest in the service provider/vendor’s company or business; and
      • That FIMM’s directors, employees and any of their Close Associate does not derive, nor are they promised, gratification (financial or otherwise) in relation to the service provider or vendor’s participation in any procurement of goods/services for/on behalf of FIMM.

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[1]Close Associates” mean—

  1. family members such as biological or non-biological parents, siblings, children or 
spouse(s) or a spouse’s parents;
  2. financially dependent individuals such as salaried persons;
  3. proxies;
  4. business partners or associates, including joint venture partners;