Key Risk Consulting Asia (“KRCA” or “the Company”) policy prohibits bribery in any form. It is KRCA’s policy to comply with the letter and the spirit of anti-corruption laws in every jurisdiction in which we do business. KRCA’s Anti-Corruption Policy demonstrates and reflects our commitment to the highest prevailing international anti-corruption standards.
Being domiciled in Malaysia, the Company is subject to the Malaysian Anti-Corruption Commission Act 2009. In so far as we do business with, and on behalf of, companies subject to their home domiciled anti-corruption laws, such as the United States Foreign Corrupt Practices Act (the “FCPA”) and the UK’s Bribery Act 2010, these have broad extra-territorial effect with which we also seek to comply.
In addition, laws implementing the OECD Convention Against Corruption, the United Nations Convention Against Corruption, and additional laws in countries in which the Company operates, governs the conduct of KRCA members in these jurisdictions. Virtually all of these laws prohibit the bribing of “Government Officials”. The UK Bribery Act, and various laws in many jurisdictions (including some U.S. states) also criminalize the bribing of private persons.
This Policy is applicable to the Company and its affiliates worldwide. Where specific conduct may be permitted under this Policy but is prohibited by local law, KRCA members must comply with local law, and KRCA’s Agents are responsible for ensuring that their teams, working under the Company’s direction, or under an engagement agreement comply with this Policy. Where additional guidance is needed, please contact KRCA’s Executive Director (“the Executive Director”).
All members of the Company, and its Agents, are subject to this Policy. It also applies to any third parties acting on the Company’s behalf and for its benefit. All members of the Company are expected to become familiar with and comply with this Policy, to participate in training on an annual basis, and to communicate its tenets when engaging with colleagues, Agents, and third parties