4.1 Bribes

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal, unethical, or a breach of trust. All directors, employees, and business associates must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor).

4.2 Facilitation Payments

Facilitation payments are strongly prohibited in TFS VIDEO PRODUCTION SDN BHD.

 4.3 Public Officials

When dealing with government officials or related associated persons, due care and attention must be exercised at all times to ensure any giving or receiving of kickbacks or gratuities to/from government officials, whether directly or indirectly, are always avoided.

4.4 Giving and Accepting of Gifts & Hospitality

All directors and employees of TFS VIDEO PRODUCTION SDN BHD are prohibited from offering, soliciting, or receiving any gifts or hospitality in any form, to or from current or potential customers, vendors, agents, and business partners, either directly or indirectly, that may influence the director’s or employee’s judgment in a decision-making process or put the employee in a position of conflict.

4.5 Donations and Sponsorships

TFS VIDEO PRODUCTION SDN BHD prohibits any donations and sponsorships to any political party, political party official, or candidate in the name of TFS VIDEO PRODUCTION SDN BHD. Donations should not give rise to the appearance of impropriety or a violation of any local country legal requirements, including as a channel for money laundering, terrorism financing, or other criminal activities. Due diligence must be conducted on recipients of donations to ascertain that they are of reputable standing. All donations and sponsorships must be reviewed and approved by authorized personnel.

4.6 Recruitment of Employees

TFS VIDEO PRODUCTION SDN BHD practices equal job opportunities. Recruitment is based on merit after a proper due diligence check has been conducted. A prospective employee should not be offered employment in order to obtain or retain an advantage in business.

4.7 Conflict of Interest

All directors and employees must ensure that their personal affairs will not give rise to any conflict of interest or appear to be conflicting with TFS VIDEO PRODUCTION SDN BHD’s interests. Directors and employees must obtain written approval from their respective heads or chairman of the board of directors before undertaking activities that may give rise to a conflict of interest. All directors and employees shall declare their conflict of interest, both on a scheduled basis and ad hoc as soon as they arise.

4.8 Training and Awareness

TFS VIDEO PRODUCTION SDN BHD shall conduct training on how to implement and adhere to this policy for all existing employees and new joiners. Regular updates will be shared with employees whenever there is a change in legislation. It is the employees’ responsibility to ensure that they attend all training provided by TFS VIDEO PRODUCTION SDN BHD.

4.9 Raising Concerns (Whistleblowing)

Directors, employees, and business associates are encouraged to raise their concerns when they become aware of any actual or suspected breach of this Anti-Bribery and Corruption policy to our whistleblowing channel: [www.thefilmsmith.com.my](https://www.thefilmsmith.com.my). All reports will be treated with the utmost confidentiality, and the whistleblower may report anonymously. When required, TFS VIDEO PRODUCTION SDN BHD shall report details of the corruption and bribery incidents to the relevant authorities.

Provided that the disclosure was made in good faith, TFS VIDEO PRODUCTION SDN BHD prohibits retaliation of any kind against any directors, employees, and business associates for reporting an actual or suspected violation of this Anti-Bribery and Corruption policy.

4.10 Compliance and Review of the Policy

The management of TFS VIDEO PRODUCTION SDN BHD is responsible for implementing this policy, while the board of directors is responsible for monitoring compliance with this policy.

All employees are responsible for keeping themselves informed about TFS VIDEO PRODUCTION SDN BHD’s latest policies and processes, particularly this ABC Policy, and ensuring that the highest standards of compliance are followed. Failure to comply with this policy may result in disciplinary action, up to and including dismissal.

This policy will be reviewed at least once every three years to ensure its relevancy and continued compliance with the prevailing law.