Anti Bribery and Anti Money Laundering Policy

Anti-Bribery / Corruption Policy

Qube Apps Solutions Sdn Bhd is committed to high standards of ethical, moral and legal business conduct.

The purpose of this policy is to set out:

  1. 1. Our minimum expectations for complying with anti-bribery laws; and
  2. 2. The obligation of every Qube Apps’s business unit is to adopt and implement an effective anti-bribery compliance program.


Scope & Compliances:

  1. 1. QAS believes that corruption prevents fair market competition and threatened our socio-economic healthy development, economy, and enterprises.
  2. 2. QAS upholds the principles of business ethic, integrity and complies with all applicable laws and regulations in all its business operations. The Company does not tolerate any corruption.
  3. 3. Our systems are designed to deter and prevent any acts of corruption. It is our policy that any employee or any other person/entity who acts on behalf of QAS must not, directly or indirectly, offer bribes to any official or any other person/entity in order to gain business advantages.
  4. 4. If, for the same purpose, any supplier, agent, consultant or business partner (‘Partners’) of QAS offer bribes to any QAS employee, the employee must reject the bribe and report the case to the Company.
  5. 5. In our cooperation with Partners, via contractual covenants and our procedures and processes, QAS requires all of its Partners to comply with QAS’s Anti-corruption statement and also to restrict their business behaviors to avoid unethical behaviors.


Anti-Money Laundering

Bank Negara Malaysia (‘BNM’) is the competent authority under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (‘AMLA’) that leads national efforts, formulates regime and policies and receives and analyses suspicious transaction reports (’STR’).

Its scope covers designated non-financial businesses and professions (‘DNFBPs’) and Non-bank financial institutions (‘NBFIs’).


The following are DNFBPs and NFBIs under the AMLA:

  1. 1. Lawyers;
  2. 2. Accountants;
  3. 3. Trust companies;
  4. 4. Company secretaries;
  5. 5. Dealers in precious metals or precious stones (goldsmiths, jewelers, etc);
  6. 6. Registered estate agents,
  7. 7. Licensed casino;
  8. 8. Licensed gaming outlets;
  9. 9. Moneylenders;
  10. 10. Pawnbrokers; and
  11. 11. Leasing and factoring business.




This Policy is to ensure that all cases of suspected wrongdoing are reported and managed in a timely and appropriate manner. In all cases involving suspected fraud you should contact HOD immediately.


Policy Statement

  1. 1.0Whoever we may deal with, and wherever we may operate, we are committed to doing so lawfully, ethically and with integrity. It is the responsibility of each and every one of us to ensure that we fulfil this commitment in our daily working lives.
  2. 2. However, from time to time there may be situations where the right course of action is unclear, or there may be situations where you suspect or know that something is improper, unethical or inappropriate.
  3. 3. We have both a legal and moral duty to take appropriate measures to identify such situations and attempt to remedy them.
  4. 4. It is sometimes difficult to know whether to speak up about something that concerns us. Often people are reluctant to get involved but this could result in serious consequences for QAS and its employees.
  5. 5. That is why we have put in place this Whistle Blowing Policy – so that you can talk to someone confidentially so that we can help.


The aim of this policy is to:

  • 1. ensure all employees feel supported in speaking up in confidence and reporting matters they suspect may involve anything, improper, unethical or inappropriate;
  • 2. encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organisation;
  • 3. provide clear procedures for the reporting of such matters;
  • 4. manage all disclosures in a timely, consistent and professional manner; and
  • 5. provide assurance that all disclosures will be taken seriously, treated as confidential and managed without fear of retaliation.
  • 6. improper, unethical or inappropriate behaviour within the organisation is unacceptable and this statement is endorsed and supported at the highest level.
  • 7. This policy does not form part of your contract of employment.
  • 8. This is a non – exhaustive list of examples:
  1. a. a criminal offence;
  2. b. fraud;
  3. c. a failure to comply with a legal obligation;
  4. d. a miscarriage of justice;
  5. e. a danger to the health and safety of any individual;
  6. f. damage to the environment; and
  7. g. a deliberate concealment of information tending to show any of the above. 



We request that, where possible, you include the information below:

  1. 1. an outline of the known or suspected wrongdoing;
  2. 2. details, to the best of your knowledge, about when, where and how it occurred;
  3. 3. a list of the names of those suspected of being involved (both within QAS and externally);
  4. 4. a list of the names of anyone who may have relevant information;
  5. 5. details of how you came to know about the suspected activities;
  6. 6. what, if any, do you estimate to be the value of the loss to QAS or other parties;
  7. 7. what, if any, breaches of internal controls, policy, procedure or other requirements you believe took place;

What happens following speaking up?

  1. 1. The HOD will acknowledge receipt of your concern within 3 working days to discuss the next steps with you.
  2. 2. If you attend any meetings as part of this process, you may choose to be accompanied to this meeting by a work colleague, or a Qualified Legal Professional.
  3. 3. May involve other internal departments. For example, in a case of suspected fraud, the Head of Internal Audit will be informed.
  4. 4. Please be assured that these matters will always be kept confidential and where possible, the details of the person or persons reporting the incident will be removed.


  1. 1. We will decide how to respond in a responsible and appropriate manner under this policy. The purpose of this investigation is:
    1. a. to establish if a wrongdoing has occurred, and if so to what extent; and
    2. b. to minimise the risk of further wrongdoing, to prevent any further loss of assets, damage to reputation and to protect all sources of evidence.
  1. 2. Most investigations will be managed internally but we may appoint an external investigator or investigating team if we think it appropriate.

Disciplinary action

If during the course of the investigation it is discovered that the matter has not been reported in good faith, this will be subject to investigation under the disciplinary procedure.

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