Anti-Bribery & Anti-Corruption (ABAC) Policy

We prohibit all forms of bribery and corruption—direct or indirect—whether offered, promised, given, requested, or received. This includes kickbacks, facilitation payments, and improper advantages to or from any person (public or private).

Scope & Law

• Complies with Malaysian Anti-Corruption Commission Act 2009 (including s.17A corporate liability) and applicable anti-corruption laws where clients are located.
• Our ABAC framework follows the T.R.U.S.T. principles commonly referenced for “adequate procedures”: Top-level commitment, Risk assessment, Undertake control measures, Systematic review/monitoring/enforcement, Training & communication.

Prohibited Conduct

• Bribes, kickbacks, facilitation payments (no “speed money” allowed).
• Offering or accepting anything of value to improperly influence a business or regulatory decision.
• Concealment or misrecording of any such payment.

Controls

• Risk-based screening of higher-risk engagements.
• Prior approval and logging for gifts, hospitality, charitable donations, and sponsorships.
• Clear, accurate books and records; no off-book accounts.

Reporting

Suspicions must be reported via support@lexmesossolutions.com. We enforce non-retaliation in good-faith reports.

Gifts, Hospitality & Expenses

Gifts and hospitality must be modest, infrequent, and legal, never to obtain an improper advantage.

Rules

• Prohibited: cash/cash-equivalents; anything during active tenders/approvals; items likely to influence a decision.
• Nominal gifts (e.g., small corporate merchandise) may be acceptable if modest and declared.
• Hospitality (meals/events) must be reasonable, pre-approved if over internal thresholds, and recorded.
• Public officials: stricter rules; usually not allowed without prior written approval.

Conflict of Interest

Disclose any situation where personal interests could conflict (or appear to conflict) with duties to LexMesos or clients (e.g., family/financial ties with vendors, clients, or officials). Obtain written clearance before proceeding.

Whistleblowing & Non-Retaliation

We provide safe channels to report suspected bribery, fraud, data privacy breaches, harassment, or other misconduct.

Report to: support@lexmesossolutions.com
Reports may be made confidentially. We strictly prohibit retaliation against good-faith whistleblowers.

Third-Party Due Diligence

We assess panel lawyers, vendors, resellers, and other intermediaries proportionate to risk (jurisdiction, service type, government touchpoints). Higher-risk engagements require enhanced checks, contract clauses (ABAC, audit, termination), and periodic monitoring.

AML/CFT Statement

We support efforts against money laundering and terrorism financing. Where relevant to our services:

• We may conduct identity and beneficial-ownership checks;
• We do not facilitate transactions that lack clear economic purpose;
• We escalate and, if necessary, decline engagements that present unacceptable AML/CFT risk;
• We cooperate with lawful requests by competent authorities.

Sanctions & Export Controls

We will not engage, directly or indirectly, in services that breach applicable sanction or export-control laws (e.g., UN, EU, UK, US). Screening may be performed; engagements can be suspended or terminated where restrictions apply.

Record-Keeping

All approvals, gifts/hospitality, donations, third-party vetting, invoices, and related decisions must be accurately recorde and retained per our retention schedule and applicable laws.

Training & Communication

We periodically communicate ABAC and compliance expectations to staff and relevant partners. High-risk roles may require targeted training and annual acknowledgements.

Monitoring, Investigations & Discipline

We review this program periodically. Allegations are investigated fairly and promptly. Proven breaches may result in disciplinary action (up to termination), contract termination, and reporting to authorities where required.

Charitable Donations & Sponsorships

Permitted only with legitimate purpose, transparent approval, and documented recipients. Donations must never be used to improperly influence decisions or to benefit public officials.

Political Contributions

Company funds/resources must not be used for political contributions unless expressly permitted by law and approved in writing by top management. Personal political activity must not be represented as the company’s.

How This Relates to Our Services

• We are not a law firm; if panel-lawyer services are engaged, their professional obligations remain their own.
• Our ABAC and compliance standards apply to our staff and to third parties we contract with.
• We reserve the right to decline or terminate engagements that present unacceptable bribery, corruption, AML/CFT, or sanctions risk.