To state Allo’s position on bribery and related matters, and to establish adequate procedures to protect the company against the impact of bribery.
Allo strictly prohibits any forms of bribery in every aspect of our operations. Allo Personnel are required to adhere to the highest level of integrity. Allo holds a ‘No Gifts’ policy, although there are certain exceptions nonetheless Allo Personnel must proceed with caution. Allo Personnel are required to sign an Integrity Pledge and a Conflict of Interest Declaration on annual basis. Business Associates which act on Allo’s behalf must be carefully managed to ensure constant compliance with Allo’s policies. We encourage all forms of reporting to be channelled to Allo in the event of misconduct of Allo Personnel. All disclosers acting in good faith will be protected. Allo is committed to implement its policies, and the Integrity Officer (IO) has been assigned to this task.
For more information, please refer to our full anti-bribery policy here:
CONFLICT OF INTEREST
To establish Allo’s position on Conflicts of Interest, Allo’s expectation that Personnel at all levels should declare any conflicts as they arise, and state the sanctions for non-compliance.
Allo Personnel at all levels are responsible for disclosing and managing conflicts of interest. All potential, perceived, and actual conflicts must be declared in a timely manner and managed in accordance with Allo’s procedures. The primary responsibility for managing the declaration lies with the personnel’s Manager with assistance from the Human Resource Department and the IO. Non-compliance on the above matter may result in severe sentences, depending on the nature of the conflict and its impact on Allo.
To establish secure and confidential reporting channels, ensure whistle-blower protection, and provide guidelines on managing reports to their conclusion in an effective and timely manner. Build and strengthen a culture of transparency and trust both within the organisation and with external stakeholders.
Allo Personnel at all levels are expected to report their concerns pertaining to any conduct they observe in relation to Allo’s activities via the whistleblowing channel established. External parties encountered any misconduct while working with Allo Personnel are also expected to report their concerns through the same channel. The whistleblower shall receive no retaliation for the report that was provided in good faith.
For more information, please refer to our full Whistleblowing Policy here:
GIFTS, HOSPITALITY & RELATED BENEFITS POLICY
To delineate the difference between a gift and a bribe, and provide guidance on the acceptable behaviour for Allo Personnel at all levels with respect to gifts, hospitality and related benefits. Expectations of external parties are also stated.
Allo holds a ‘No Gifts’ policy, however, there are several exceptions which the receiving personnel shall ensure i.e., there will be no Conflict of Interest arises and such action will not influence any decision-making activities. Usual business hospitality is permitted but it shall be limited and shall not be extravagant to the extent that the receiver felt a sense of obligation. Festive hampers are discouraged and to be refused whenever possible. Any form of discounts for Allo Personnel by an External Provider must be transparent. Facilitation payment is strictly prohibited. Charitable contributions, sponsorships and community benefits for external parties must be made according to the TNB Group Corporate Communications Division policy to ensure consistency and uniformity across Allo.
INTEGRITY PACT POLICY
To strengthen the measures employed by Allo to safeguard the tendering and procurement procedures against the effects of bribery.
Integrity Pacts promote corruption-free operations on the part of both Allo and its External Providers during an award or execution of a contract. The implementation of Integrity Pacts yields other benefits such as greater transparency in contracting, and enhancement of public confidence and trust. Tender committee Integrity Pledges set out the expected behaviours from the committee members. The Pledges are to be signed at the start of each tender-related committee meeting by each committee member present. The policy aims to ensure no leakage of information during the pre-contract stage. Allo Personnel are expected to exercise the highest degree of integrity when participating as a tender committee.