Anti-bribery & Corruption Policy

1. Our Commitment

At Roundtable Media Sdn Bhd, we uphold the highest standards of integrity, transparency, and accountability in all our business dealings. We maintain a zero-tolerance stance toward bribery and corruption and expect every person acting on our behalf to share that commitment.

2. Scope

This policy applies to:

  • All employees (full-time, part-time, temporary, interns)

  • Directors, officers, and managers

  • Contractors, consultants, agents, suppliers, vendors, and any third party representing or acting for us

3. Definitions

  • Bribery: Offering, giving, receiving or soliciting anything of value to influence a decision improperly

  • Corruption: Misuse of power or position for personal or corporate gain

  • Facilitation payments: Small payments to expedite routine government actions (e.g., permits, licenses) — prohibited

  • Kickbacks: Return of funds or benefits as a reward for a transaction or favourable treatment

4. Prohibited Conduct

Under this policy, no one acting on behalf of Roundtable Media shall:

  • Offer, promise, give, or receive bribes (directly or indirectly)

  • Engage in facilitation payments or kickbacks

  • Use third parties (agents, intermediaries, consultants) to circumvent these rules

  • Accept or give gifts, hospitality, or benefits if they improperly influence decisions

5. Gifts, Hospitality & Entertainment

We recognise that customary, modest gifts or hospitality may be part of building business relationships. However:

  • They must be reasonable, made in good faith, and never intended to influence a business outcome

  • Cash or cash equivalents (like vouchers) are forbidden

  • All offers or receipts must be declared to management and recorded in our Gifts & Hospitality Register

  • We reserve the right to refuse or return any gift or hospitality that violates this policy

6. Political & Charitable Contributions

  • We do not make political donations or contributions to political parties, candidates, or campaigns

  • Charitable donations or sponsorships are allowed only for legitimate purposes and must never be used to secure an improper business advantage

7. Roles & Responsibilities

Employees / Representatives must:

  • Be aware of and follow this policy

  • Avoid conflicts of interest or situations that may appear improper

  • Report any suspicious or improper conduct

Management / Leadership must:

  • Promote a culture of compliance and ethical behaviour

  • Oversee and maintain relevant registers (gifts, hospitality)

  • Investigate reported incidents and take appropriate actions

8. Reporting Mechanism

If you become aware of (or suspect) any instance of bribery or corruption linked to Roundtable Media, you can report it via our confidential channel:

📧 hello@roundtablestudios.space

All reports will be treated confidentially and investigated promptly. We strictly prohibit retaliation against anyone who reports in good faith.

9. Record-Keeping & Documentation

We will maintain clear, accurate, and timely records of:

  • Gifts, hospitality, and entertainment

  • Payments to third parties

  • Charitable donations / sponsorships

  • Any investigations, actions, or resolutions

These records must be available for audit or regulatory review.

10. Consequences of Breach

Breaching this policy may lead to serious disciplinary action, up to termination of employment or contract.

In addition, we may terminate business relationships with partners or suppliers who violate it, and cooperate with relevant authorities as required.

11. Policy Review & Updates

This policy will be reviewed at least annually or whenever necessary (e.g., due to changes in law or business operations) to ensure it remains effective and relevant.

Roundtable Media Sdn Bhd

“Do what is right, not what is easy.”

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