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Anti-Corruption Policy

Last Revised: 8 May 2026

1. WP Media Sdn Bhd against Corruption

WP Media Sdn Bhd maintains a zero-tolerance stance toward bribery and corruption. The Company enforces strict disciplinary measures, including suspension or termination, for employees engaging in corrupt practices and will report suspected violations to the relevant authorities.

2. Introduction

The Malaysian Anti-Corruption Commission Act 2009 (MACC Act) governs anti-corruption compliance in both private and public sectors. Violations carry penalties of up to 20 years imprisonment and fines of at least five times the gratification amount or RM10,000, whichever is higher.

Corporate Liability

Under Section 17A of the MACC Act (in force since 1 June 2020), organisations can face liability if associated individuals offer gratification to obtain or retain business advantages. Directors, controllers, officers, partners, and management personnel involved may be held personally liable. WP Media Sdn Bhd has implemented adequate procedures, in line with the Prime Minister’s Department Guidelines on Adequate Procedures, to prevent corruption by associated persons acting on the Company’s behalf.

Consequences

At the individual level:

At the organisational level:

3. Prohibited Conduct

The following activities are prohibited:

4. Gratification Definition

“Gratification” is broadly defined to include money, gifts, loans, employment contracts, property interests, discounts, commissions, rebates, or services provided with corrupt intent.

5. Common Corruption Risk Areas

Gifts and Hospitality

The Company maintains a strict “no gift” policy. Limited exceptions include:

Any other gift or hospitality expenditure requires approval from the General Manager or Chief Executive Officer.

Events and Entertainment

Employees may participate in business events where there is a legitimate business reason, the costs are reasonable, and the employee has notified their supervisor. Expensive arrangements require management approval.

The Company does not fund third-party travel or accommodation for business events, and vice versa, except under special circumstances and with written approval from the CEO or General Manager.

Facilitation Payments and Kickbacks

Facilitation payments and kickbacks are strictly prohibited. The only exception is payments made under duress to prevent injury or loss of liberty, which must be immediately reported to supervisors.

Sponsorship and Donation

All sponsorships and donations require General Manager approval and must not provide unfair business advantages or serve political purposes.

Purchasing and Procurement

All purchasing decisions must serve the Company’s best interests and be properly documented, specifying deliverables, payment basis, rates, and delivery timelines.

6. Conducting Due Diligence

Prior to engaging third parties, employees must conduct due diligence reviewing:

Any irregularities must be immediately escalated to the General Manager.

7. Whistleblowing

Employees have a legal duty to report suspected corruption violations. Reports should be submitted to:

WP Media Sdn Bhd Unit 2-1, The Podium, Tower 3 UOA Business Park No. 1, Jalan Pengaturcara U1/51A, Seksyen U1 40150 Shah Alam, Selangor Malaysia

Email: hello@walkproduction.com Telephone: +60-12-671-5323

Reporters must identify themselves, with assurances of anonymity and protection against retaliation.