QL adopts a zero-tolerance stance towards all forms of bribery and corruption, underpinned by a robust governance framework and clear policies that guide ethical conduct across the Group.

Our approach is anchored on the following key principles, in accordance with our Anti-Bribery and Anti-Corruption (ABAC) Framework as well as Anti-Bribery and Anti-Corruption (ABAC) Policy:

• Strong Governance Framework – Implementation of Anti-Bribery and Corruption (ABC) policies aligned with Malaysian Anti-Corruption Commission (MACC) requirements, supported by Board oversight and management accountability.
• Clear Policies and Standards – Enforcement of the Code of Business Ethics and Conduct
  (COBEC), Anti-Bribery and Corruption Policy, and related procedures governing gifts, hospitality, and conflicts of interest.
• Risk-Based Controls – Ongoing identification, assessment and mitigation of corruption risks across operations, including third-party engagements.
• Awareness and Training – Regular training and communication programmes to strengthen employee awareness and reinforce ethical decision-making.
• Reporting and Whistleblowing Mechanisms – Provision of accessible and confidential channels for reporting misconduct, supported by non-retaliation principles and independent investigation processes.
• Monitoring and Continuous Improvement – Periodic reviews, audits, and enhancements to ensure effectiveness of the anti-corruption framework and compliance with evolving regulatory

The ABAC policy refers bribery, embezzlement, fraud, collusion, theft, money laundering, extortion, breach of trust, abuse of position and trading under influence as corrupt actions or behaviours under the relevant laws of each jurisdiction where the Group operates.

The ABAC policy details structured due diligence process to assess and screen internal and external parties to assess potential risks related to bribery, corruption or other unethical conduct. Assessment will be conducted on Stakeholders to evaluate their exposure to bribery and corruption risks. Based on the identified risk levels, appropriate due diligence procedures are designed and implemented to ensure effective mitigation and compliance.