Anti-Bribery & Anti Corruption
Framework and Policy

Dagang NeXchange Berhad (“DNeX”) and its subsidiaries (collectively known as “DNeX Group or “Group”) is committed for the development and establishment of framework, policies and procedures guiding the conduct of our businesses with honesty, fairness and high ethical standards and not allowing certain types of behavior contrary to commercial integrity which would put the Group’s reputation at risk.

Thus, the Group has established the ABAC that defines the main guidelines for the detection and prevention of fraudulent behaviours. The Group prohibits any type of corruption and bribery such as promising, offering, giving or accepting any incentive or advantage of any nature, directly or indirectly, in order to influence any type of decision that may result in an undue benefit to the Group.

The objectives of the ABAC are:

  • To ensure the policies and guidelines/ practices are oriented towards embedding ABAC stance organisation wide, with guidance from Guideline on Adequate Procedures and requirements of Malaysian Anti-Corruption Commission (“MACC”) Act 2009, introduced via Section 4 of the MACC (Amendment) Act 2018;
  • To ensure adequate and standardised ABAC policies and guidelines are consistently applied throughout the Group by all staff; and
  • To ensure that business operations within the Group are strictly adhering to the ABAC.

All Directors (executive and non-executive), employees and all vendors or agents, customers, business partners, public officials and others who are performing work or services, for and on behalf of DNeX Group shall comply with the rules and guidelines described in this framework and policy and must avoid any behaviour, situation or activity that would breach them.

The key features of the ABAC are:

a. Top management commitment
The roles and responsibility of the Board and all level of employee are clearly outlined in the development of an ethical and high integrity culture within the Group, within which includes clear policies and lines of authority to adequately address corruption risk.

b. Risk assessment
A corruption risk management assessment guided by ISO 37001:2016 Anti-Bribery Management System and GAP is conducted to assess and outline the governance, structure and policies, and integration of risk management into DNeX’s Group operations. Corruption risk assessment of all business unit within the Group have been conducted and a baseline risk profile have been built to capture the potential corruption schemes. Specific mitigation plans have been identified for continuous review and monitoring.

c. Undertake control measures
i. An integrated anti-bribery and anti-corruption plan is established to control such misconduct at a strategic, tactical and operational level. It outlines the actions that need to be taken to prevent, detect and response to potential threat. The plans will be reviewed on a regular basis to take into account any changes in the internal and/ or external environment. Amongst key control plans established are:

  • Gift and corporate hospitality
  • Entertainment
  • Corporate social responsibility
  • Donation and sponsorship
  • Facilitation and extortion payments

ii. In order to guide decision making, the Group has also established guidelines for due diligence exercise in dealing with employees’ recruitment and external parties such as vendors/ agents, customers, business partners and public officials.

iii. Effective detection systems are also vital, as preventative methods may not always be successful. Hence internal reporting system and grievance processes is reviewed and enhanced for internal and external parties to raise concerns or report misconducts.

d. Systematic review, monitoring and enforcement
Responding effectively to suspected cases of fraud, corruption and other compliance breaches is critical. Guidelines have been established which involves a well conducted internal – and if necessary, external investigation to ascertain the facts. The information gained and lessons learned from each case will form part of an on-going review of fraud and corruption prevention controls, to ensure the Group’s reporting procedures on suspected bribery and corruption activities remains comprehensive and effective as possible

e. Training and communication
Annual training and awareness programme on ABAC shall be provided to DNeX’s employees and key stakeholders. The ABAC with regards to its content as well as regulatory requirement affecting the ABAC practices will also be communicated to DNeX’s employees and key stakeholders on regular basis.

Click here for the full DNeX’s ABAC Framework and Policy.


Policy Statement

In line with good corporate governance practices, the Board of Director (“BOD”) and Management of Dagang NeXchange Berhad (“DNeX”) and its subsidiary companies (collectively known as the “DNeX Group” or “Group”) encourage its employees to commit to the highest possible standards of ethical, moral, and legal conduct. Consistent with this commitment, the policy aims to support good management practices and sound corporate governance practices within DNeX Group.


This policy aims to provide a structured mechanism for its employees and any parties (“reporting individual”) to rise or report suspected and/ or known misconduct, wrongdoings, corruption and instances of fraud, waste, and/ or abuse involving the resources of the Group. It provides reassurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.

Scope of Reporting

Any improper conduct including but NOT limited to the following:

  • Regulatory breaches or non-compliance to regulatory requirements;
  • Any form of criminal offences and crime, including fraud and criminal breach of trust;
  • Bribery and corruption;
  • Collusion and money laundering;
  • Breach of DNeX Group’s Code of Conduct, Discretionary Authority Limit and Policies and Procedures;
  • Misuse or abuse of DNeX Group’s funds or assets;
  • Conflict of interest and potential abuse of position for personal gains;
  • Any form of harassment and intimidation;
  • Knowingly directing or advising a person to commit any of the above wrongdoings; and
  • Any action which is intended to conceal any of the above.


The whistleblower’s identity and report will be treated as confidential to the extent possible, consistent with the need to conduct adequate investigation, unless otherwise required by law.

Acting in Good Faith

The Group expects all parties to act in good faith and have reasonable grounds when reporting a Whistleblowing complaint, hence the whistleblower will be protected against victimisation or other adverse treatment. However, malicious rising or unfounded allegations is a disciplinary offence and will be subjected to disciplinary action by DNeX Group in accordance with the Code of Conduct.

Protection from Retaliation

Any employee who shows the act of retaliation against the whistleblower who has reported a violation in good faith will be subjected to disciplinary action by DNeX Group in accordance with the Code of Conduct of DNeX which includes termination of employment.

Whistleblowing Channel

This Policy is administered by Whistleblowing Committee. Disclosure via Whistleblower Report Form (click here) can be made to any of the following dedicated reporting channels: -

  • Email at whistle@dnex.com.my
  • Mail by marking “Private & Confidential” to: -

Chairman of the Audit Committee
c/o:Dagang Nexchange Berhad
Dagang Net Tower, Block 10 (A&B) Corporate Park
Star Central, Lingkaran Cyberpoint Timur, Cyber 12
63000 Cyberjaya, Selangor


Upon the completion of the whistleblowing process and procedures, the whistleblower will be accorded the privilege to be notified on the outcome of disclosure.

Click here to view the full version of DNeX’s Whistleblowing Framework and Policy.