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In this Anti-Corruption and Anti-Bribery Policy, CLJ Malaysia Sdn Bhd (formerly known as Malaysian Current Law Journal Sdn Bhd) and its associated companies or subsidiaries shall be collectively referred to as “CLJ”. Any reference to “we”, “our” or “us” hereinafter appearing shall be read as referring to CLJ.

Any reference to “you” shall refer to its business associates and/or customers and/or any person who perform services for and on behalf of CLJ and/or any person who have dealings with CLJ.

1. CLJ’s Commitment

1.1 CLJ Malaysia Sdn Bhd (formerly known as Malaysian Current Law Journal Sdn Bhd) and associated companies and subsidiaries (hereinafter collectively known as “CLJ”) are committed to conducting business dealings with integrity. CLJ will not tolerate any practices of corruption and bribery of all forms in CLJ’s day to day operations. In line with its zero-tolerance approach against all forms of corruption and bribery, CLJ takes a strong stance against such acts. This Anti-Corruption and Anti-Bribery Policy (“Policy”) sets out the core principles in CLJ.

1.2 In compliance with the Malaysian Anti-Corruption Commission Act 2009 (including its amendments thereof), CLJ adopts the principles of T.R.U.S.T, namely:

  • Top level commitment of highest level of integrity and ethics and ensuring full compliance and effective implementation of the anti-corruption and bribery policies.

  • Periodical Risk Assessment to identify, analyse, assess and prioritise internal and external corruption risks.

  • Undertake control measures within CLJ.

  • Regular Systematic Review, Monitoring and Enforcement of this Policy.

  • Providing appropriate Training and Communication.

2. Background

2.1 CLJ highlighted Integrity as the first core value in this Policy. Each member of CLJ and its customer shall uphold high levels of personal and professional values in all business interactions and decisions in all its business with CLJ.

2.2 The nature of CLJ’s business requires its employees to engage in business with a wide range of parties, both internal as well as external. This Policy establishes the boundaries on interactions with all parties.

2.3 CLJ expects all its directors, employees, business associates and customers to comply with this Policy in the performance of their services for and on behalf of CLJ and/or in any dealings with CLJ.

2.4 This Policy shall be read in conjunction with the terms and conditions of the Terms of Trade, Terms and Conditions of Use, License Agreement and/or any agreement between you and CLJ and the Malaysian Anti-Corruption Commission Act 2009 and its amendments thereof (“MACCA”). This Policy shall be construed as part and integral part of the Terms of Trade, Terms and Conditions of Use, License Agreement and/or any agreement between CLJ and you. Any breach of the terms of this Policy shall constitute a fundamental breach of the Terms of Trade, Terms and Conditions of Use and License Agreement, and shall be a ground for termination of the Terms of Trade, Terms and Conditions of Use, License Agreement and/or agreement between CLJ and you.

3. Objective

This Policy sets out CLJ’s position on corruption and bribery in all its forms and matters of corruption that might confront CLJ in its day-to-day operations.

4. Scope

This Policy applies to:

(a) all directors, officers, employees, principal, agents and representatives of CLJ, and

(b) CLJ’s business associates and/or customers and/or any person who perform services for and on behalf of CLJ and/or any person who have dealings with CLJ.

5. Zero tolerance approach

5.1 CLJ prohibits both the giving and receiving any gratification or facilitation payments to influence CLJ or any person decisions, action, or omission.

5.2 As part of CLJ’s commitment to combat corruption and bribery, CLJ expects all its business associates and/or customers and/or any service providers and/or any person who have dealings with CLJ to refrain from corruption or bribery, and for any dealings with CLJ to adhere strictly to the terms and conditions set out in this Policy.

5.3 All forms of corruption and bribery are strictly prohibited. All directors, officers, employees, principal, agents and representatives of CLJ, and CLJ’s business associates and/or customers and/or service providers and/or any person who have dealings with CLJ must not participate in any corrupt activity, such as extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering.

5.4 All directors, officers, employees, principal, agents and employees of CLJ, and CLJ’s business associates and/or customers and/or service providers and/or any person who have dealings with CLJ shall not, whether directly or indirectly, offer, give, receive or solicit any item of value, in the attempt to illicitly influence the decisions or actions or omission of a person in a position of trust within an organisation, either for the intended benefit CLJ or the persons involved in the transaction.

5.5 For avoidance of doubt, this Policy applies equally to all business dealings with commercial or private sector, and government, government officials or public sector, and/or any entities, and includes interactions with their directors, officers, employees, principal, agents and representatives at all levels.

5.6 If suspicion of corruption and bribery arises in the dealings with any Business Associate or service provider, CLJ shall seek an alternative service provider of the services/goods.

5.7 CLJ is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including but not limited to MACCA, Malaysian Penal Code (and its amendments) and the Companies Act 2016. These laws prohibit corruption and bribery. In cases of conflict between mandatory law and the principles contained in this Policy, the law shall prevail.

6. Your obligations

6.1 You, for yourself and on behalf of your Affiliated Persons, represents, warrants and covenants that:

(a) You and your Affiliated Persons are solely responsible for complying, and will comply, with Applicable Laws and have not taken and will not take or fail to take any action, which act, or omission would subject CLJ to liability under Applicable Laws;

(b) Neither you nor any of your Affiliated Persons has, offered, paid, given or loaned or promised to pay, give or loan, or will offer, pay, give or loan or promise to pay, give or loan, directly or indirectly, money or any other thing of value to or for the benefit of any kind or gratification to any directors, officers, staff, employees, principal, agents and representatives of CLJ, for the purposes of corruptly (i) influencing any act or decision of such persons, (ii) inducing such persons to do or omit to do any act in violation of his lawful duty, (iii) securing any improper advantage or (iv) inducing such persons to use his influence with any entities or bodies to affect or influence any act or decision of that entities or bodies, in each instance to direct business to you or CLJ; and

(c) Neither you nor any of your Affiliated Persons has, received, accepted, or borrowed or agreed to receive, take or borrow, directly or indirectly, money or any other thing of value to or for the benefit of any kind or gratification, for the purposes of corruptly (i) influencing any of your act or decision or any persons, (ii) inducing you or any persons to do or omit to do any act in violation of the respective lawful duty, (iii) securing any improper advantage or (iv) inducing you or any persons to use its influence with any entities or bodies to affect or influence any act or decision of that entities or bodies.

6.2 You shall assist and cooperate fully with the efforts of CLJ to comply with Applicable Laws.

6.3 In no event will CLJ be obligated to you under or in connection with the Terms of Trade, Terms and Conditions of Use, License Agreement and/or any agreement between CLJ and you to act or refrain from acting if CLJ believes that such act or omission would cause CLJ to be in violation of Applicable Laws. 

6.4 If you or any of its Affiliated Persons breaches any of the representations, warranties or covenants in this Policy, each of which is deemed to be material and continuously made throughout the term of the Terms of Trade, Terms and Conditions of Use, License Agreement and/or any agreement between CLJ and you, then, in addition to any other rights CLJ may have under the Terms of Trade, Terms and Conditions of Use, License Agreement and/or any agreement between CLJ and you, CLJ may:

(a) declare a forfeit of any unpaid amounts owing to you and will be entitled to repayment of any amounts paid or credited to you, in each case, which are prohibited by Applicable Laws; and/or

(b) withhold delivery of any products or services to you without liability to CLJ for any claims, losses or damages related to such decision.

6.5 For purposes of this clause, the following terms have the meanings set forth below:

(a) “Applicable Laws” means the Malaysian anti-corruption laws, and all other laws, regulations, guidelines, orders, decrees or other directives carrying the force of law applicable to any activities engaged in by CLJ and/or you or any of your Affiliated Persons in connection with the Terms of Trade, Terms and Conditions of Use, License Agreement and/or any agreement between CLJ and you, or any other business matters involving CLJ and you, in each case as the same may be amended from time to time;

(b) “Affiliated Persons” means your directors, officers, staff, employees, principal, agents, representatives, or any of your shareholders, partners or owners acting on your behalf or in your interests.


Your continued usage of this Website constitutes your acceptance of these Anti-Corruption and Anti-Bribery Policy, including the subsequent amendments, update and/or modifications at the time of your usage of this Website.

Updated as at 15 December 2023