CODE OF CONDUCT
& ANTI-CORRUPTION POLICY

WeBorrow Sdn. Bhd. (trading as "Carbon AI")

1. Purpose

This policy outlines the ethical standards and anti-corruption commitments expected from all employees, partners, suppliers and representatives of WeBorrow Sdn. Bhd. (trading as "Carbon AI"). It supports compliance with the Malaysian Anti-Corruption Commission (MACC) Act 2009, Section 17A, ISO 37001 principles and the Malaysian Code on Corporate Governance.

2. Scope

This policy applies to:

  • Directors and employees
  • Contractors, interns and consultants
  • Vendors, suppliers and business partners
  • Any individual acting on behalf of the company

3. Core Principles of Conduct

All representatives of the company must uphold:

  • Integrity, honesty and transparency
  • Compliance with all applicable laws and regulations
  • Professional and respectful behaviour
  • Confidentiality of customer and company information
  • Responsible use of company systems, data and AI tools
  • Avoidance and disclosure of conflicts of interest

4. Zero Tolerance for Corruption

We strictly prohibit:

  • Bribery in any form
  • Kickbacks, improper commissions or facilitation payments
  • Offering, giving, requesting or accepting anything of value to influence decisions
  • Any corrupt activity by employees or third parties acting on our behalf

5. Gifts, Hospitality and Entertainment

Employees may not offer or accept gifts or hospitality that:

  • Influence or appear to influence business decisions
  • Create a sense of obligation
  • Breach partner or regulatory policies

Any gift above a nominal value must be declared to management.

6. Third-Party Integrity Due Diligence

We conduct reasonable checks on vendors, suppliers and partners to ensure they uphold ethical business practices and do not engage in bribery or corruption.

7. Whistleblowing and Reporting

Any suspected misconduct, unethical behaviour or corruption may be reported confidentially to the management team. All disclosures will be reviewed fairly and handled without fear of retaliation.

8. Compliance and Training

Employees are briefed on this policy during onboarding and may receive periodic reminders or training. Violations may result in disciplinary action, termination or reporting to authorities.

9. Leadership Commitment

The leadership of WeBorrow Sdn. Bhd. (trading as "Carbon AI") is committed to maintaining a culture of integrity and a zero-tolerance approach to bribery and corruption.