INTRODUCTION

In line with the standards and guidance imposed under the Malaysian Anti-Corruption Commission Act 2009 (MACC) and Guidelines on Adequate Procedures issued pursuant to the MACC Act 2009, we wish to remind all Iconix Co-Living Sdn Bhd ("the Company") employees and associated persons as well as suppliers to Iconix are obliged to comply with the said rules and requirements.

Iconix's Anti-Bribery and Corruption Policy (ABCP) is formulated to ensure that the company conducts its business in conformance to the highest level of integrity and ethics, and that all employees, suppliers, partners and its agents comply with the relevant laws and regulations on anti-bribery and corruption. The policy represents our stance of zero tolerance for bribery and corruption and serves to protect the institution from financial and reputational loss resulting from regulatory and/or enforcement, censure and action.

POLICY STATEMENT

All ICONIX employees and associated persons are required to comply fully with this Anti-Bribery and Corruption Policy, the Malaysian Anti-Corruption Act 2009 and other applicable anti-corruption laws. The basic rules are these:

• ICONIX employees and associated persons shall not offer, give, solicit, or receive bribes or kickbacks in order to secure improper advantage.
• ICONIX employees and associated persons must fully, fairly and accurately characterize and record all transactions and expenditures in the books, records and documents of the company or relevant institution.
• Prohibited activities may not be taken directly or indirectly through third parties such as agents, consultants, contractors, partners or vendors of the Company.

“Facilitation or grease payments” facilitate a normal administrative/bureaucratic function, such as to expedite processing paperwork are strictly not allowed under the Anti-Bribery Policy and they are prohibited by this policy.

Bribery and corruption are not only against the Company values; they are illegal and can expose both the employee and Company to fines, penalties, including imprisonment and reputational damage. At Iconix, bribery and corruption is never permitted. We will not seek to influence others, either directly or indirectly, by offering, paying or receiving bribes or kickbacks, or by any other means that is considered unethical, illegal or harmful to our reputation for honesty and integrity. Employees and representatives of the Company are expected to decline any opportunity which would place our ethical principles and reputation at risk. While certain laws apply only to bribes to government officials (domestic and foreign); this Policy applies to non-government business partners as well.

THIRD PARTIES

A third party includes, but is not limited to consultants, agents, representatives, contractors and advisors. All third parties representing the Company are expected to comply with our Anti-Bribery and Corruption Policy.

Accordingly, this Policy applies to activities conducted with or through an agent, consultant, joint venture, or other business partner. the Company's personnel who manage, supervise, or oversee the activities of third parties working with the Company should ensure that such persons or entities understand and fully comply with this Policy. The most important step we can take to protect ourselves from liability for improper payments made by third parties is to choose carefully our partners, including agents and consultants, and monitor their conduct.

POLICY VIOLATIONS

Compliance with this Policy and with the laws of Malaysia is a condition of employment and business relationship with Iconix. Failure to comply with this Anti-Bribery and Corruption Policy and the Guidelines established under this Policy, the Code of Conduct and Ethics or applicable laws is grounds for disciplinary action, including termination of employment and possible Legal Action.

In the event of any breach of this policy, regardless of whether enforcement action is pursued against the Company, or the success of any attempted bribery, Iconix employees and associated individuals implicated in such violations shall be subject to prosecution, substantial criminal fines, and imprisonment.

DEFINITIONS

Bribery is the offer, promise, giving, demanding or accepting of an advantage as an inducement for an action which is illegal, unethical, a breach of trust or the improper performance of a contract — that the briber would not receive in the absence of the bribe. Inducement can be anything of value to the person who is being influenced which can take the form of gifts, hospitality, fees, rewards, jobs, internships, examination grades, favours or other advantages. It does not matter whether the bribe is given or received directly or through a third party or whether it is for the benefit of the recipient or some other person.

Corruption is the misuse of entrusted power for personal gain.

Government Officials include any officer or employee of any governmental entity at any level;

• any private person acting in an official capacity for or on behalf of any governmental entity (such as a consultant retained by a government agency);
• officers and employees of companies or institutions in which the state has a majority ownership interest or over which the state exercises control, including public schools, colleges, land office, municipal councils;
• candidates for political office, and political parties and their officials; and
• officers, employees, or official representatives of public international organizations, such as the World Bank, United Nations, and International Monetary Fund.

Kickback is an illicit payment made to someone in return for facilitating a transaction or appointment or to gain an improper advantage

WHO IS COVERED BY THE POLICY

This policy applies to all Company Directors, individuals working at Iconix including employees (whether permanent, or by way of contract, full time or part-time), consultants, contractors, suppliers, trainees and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy) and all third parties acting on behalf of Iconix. This policy applies to conduct both within and outside of Malaysia.

WHAT IS NOT ACCEPTABLE

It is not acceptable for you (or someone on your behalf) to:

• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that either a personal or business advantage will be received, or to reward either a personal or business advantage already given;
• give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;
• accept payment from a third party that you know or suspect is offered with the expectation that it will obtain either a personal or business advantage for them;
• accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that either a personal or business advantage will be provided by Iconix in return;
• threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy

1. (A) No Bribery

   ICONIX personnel or associated persons should never be involved in offering, promising, authorizing, making, receiving or otherwise furthering a payment of money of transfer of anything of value to or from any person for an improper purpose or to gain an improper advantage.

   The giving or receipt of gifts is allowed, if the following requirements are met:

   • it is made with the intention of NOT influencing a third party to obtain or retain business or an advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
   • if it does NOT include cash or a cash equivalent (such as gift certificates, vouchers or tickets);
   • if it is appropriate in the circumstances. For example, in Malaysia it is customary for small gifts to be given during the various festive season;
   • if taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time reference should be made to the Company's Code of Conduct for the monetary threshuld;

   Gifts should not be offered to, or accepted from, government officials (this includes public school teachers/counsellors/staff) or representatives of any government offices, or politicians or political parties, without the prior approval of the Company's legal counsel. Any such gifts must be registered regardless of value.

2. (B) Facilitation Payments and Kickbacks

   ICONIX personnel or associated persons should not make, and should not accept, facilitation payments or "kickbacks" of any kind to obtain a favourable outcome. Facilitation payments are typically small, unofficial payments made to secure or expedite a deal or to gain some improper advantage.

   If you are asked to make a payment on the Company's behalf, you should always be mindful of what the payment is for and if it forms part of the official service rendered by the other party and is being offered to the public at large. You should always ask for an official receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Compliance Officer.

   Similarly, if you were offered or received any benefits in monetary form or in kind, directly or indirectly you should be cautious as to the intention of the offerings. The gifts should not form, influence or be seen as influencing the judgement and/or your engagement in any act that may directly or indirectly assist the giver in attaining a favourable or desired outcome e.g. awarding of jobs and contracts, expediting a move in/administrative paperwork, expediting approvals, exchange of information regarding tenants/unit availability/owners etc.

   All Iconix employees and associated persons must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by Iconix or employees of Iconix.

3. (C) Responding to Solicitation and Extortion

   If a government official or other person requests/solicits a bribe or other improper payment or transaction, Iconix employee and associated persons should diplomatically but clearly advise the requestor that it is against the Company's policy to make such payments, and decline to make or promise to make the payment. The solicitation should be promptly reported to the Iconix's company director.

   The only exception to this rule is where the request is a demand that is accompanied by a credible threat to personal safety or safe passage. In such cases, which are equivalent to extortion, Iconix personnel may make the requested payment to avoid the threat, but must promptly report the demand as provided above. A threat of property damage or harm to business does not fall within the scope of this exception.

ACCURATE BOOKS AND RECORDS AND FINANCIAL CONTROLS

Iconix personnel must maintain complete and accurate records with respect to all transactions and expenditures undertaken on behalf of the Company or its subsidiaries.

• special care must be exercised when transactions involve payments or other benefits to government officials
• accurately record all payments to public officials and commercial partners
• reject and report any requests for false invoices or payment of expenses that are unusual, excessive or inadequately described and/or inadequately supported.
• must not request from third parties nor issue out false invoices
• must not make misleading, incomplete or false entries in the Company's books and records for any reason

SEEKING ADVICE AND REPORTING VIOLATIONS

In upholding the Company's zero tolerance policy towards all forms of bribery and corruption, Iconix seeks your co-operation in maintaining the same high standards in all our business dealings. In the event that you are made aware of any instances of corrupt acts when dealing with Iconix, please report the matter through our confidential reporting channel at [email protected].

The Company shall not allow any person to suffer harm or abuse of any kind because he or she has raised the concern honestly and in good faith. Any retaliation against a concerned person shall be a violation of this policy.