About Us

To become a trusted global leader in reinsurance broking and risk management by providing bespoke services to our clients.

1. Purpose

The purpose of this Anti-Fraud, Bribery and Corruption Policy (“AFBC Policy”) is to set out PWS Global Risks Labuan Ltd’s (“PWS” or “the Company”) stance on fraud, bribery and corruption.

1. Scope
   • This policy applies to all employees of PWS working at all levels and grades, including senior management, officers, directors, employees (whether permanent, contractual, or temporary). PWS also expects its third parties’ partner to comply with the Policy when performing work or services.
   • The Compliance Officer will make aware of this ABC Policy to all Directors and staff of the Company. For external parties mentioned in point 1.1 above, it will be made known by the staff that interacts with them.
   • All suspected or actual instances of fraud, bribery and corruption shall be reported under the Whistleblowing Policy. Failure to report could result in disciplinary action.

1. Statement
   • PWS has adopted a ‘zero tolerance’ approach against all forms of fraud, bribery, or corruption. The Company’s Code of Conduct sets out the Company’s core principles in this regard. The Company is committed to conduct its business in accordance with applicable laws and regulations at the highest ethical standards.
   • The Company requires all staff to act honestly and with integrity at all times and must immediately report any incident or suspicion of fraud, bribery, or corruption.  Anyone raising a concern in good faith will not be penalized.
   • The Company will take disciplinary and /or legal action against those found to have perpetrated, be involved in, or assisted with the fraudulent or other improper activities.
   • The Company will investigate fairly and appropriately for all reports of fraud, bribery, and corruption.

1. Conflict of Interest
   • Conflict of interest may arise in situations where Personnel engage in business or other activities outside the Company or have personal interests, whether it benefits themselves or their closely related person(s), i.e. relatives or close associates, which competes or conflicts with the interests of the Company.

• Employees must obtain written approval of their respective heads of companies before undertaking activities which may give rise to conflict of interest. All Personnel shall declare their conflict of interest, both on a scheduled basis, and ad hoc as soon as they arise.

1. Illegal Gratification and Corrupt Practices
   • Solicitation and/or acceptance of Corrupt Payments

An employee shall not solicit or accept gratification of any kind, be it in cash, gift or favour, either directly or indirectly through another person or from any enterprise, in return for doing anything or refraining from doing anything relating to a business transaction involving the Company.

• Making Corrupt Payment / Facilitation Payment

          Facilitation payments are payments made with the purpose of expediting or facilitating the performance by a person performing a routine or administrative duty or function.

• Employees and directors (including their family members) are prohibited from directly or indirectly giving any facilitation payments as this is seen as a form of bribery and corruption.
• Facilitation payments need not involve cash or other financial asset; it can be any sort of advantage with the intention to influence them in their duties.
• Exceptions apply if employees are left with no alternative but to make payments in order to protect against loss of life, limb or liberty. In dangerous situations like this, you are allowed to make payments, but you must immediately report to the Compliance Officer.

1. Commissions
   • An employee is not permitted to accept or pay commissions, or percentage of a commission as part of any payment arising from a commercial transaction other than to those legally entitled to such amounts.
   • Kickbacks and rebates are payments made in exchange for a business advantage and regarded as corruption and should be avoided.

1. Gift or Gratuity
   • PWS has adopted a “No Gift” Policy whereby all employees and directors (including their family members) are prohibited from, directly or indirectly, receiving or providing gifts since it may create an obligation, compromise impartiality, and thereby influence a business decision.
   • The following shall be exempted from the prohibition stated under 7.1 above:-
2. Exchange of gifts at the company to company level (e.g. gifts exchanged between companies as part of an official visit/courtesy call, and thereafter the said gift is treated as the Company’s property);
3. Gifts from the company in relation to the company’s official functions and events (e.g. door gifts offered to all guests attending the company’s function);
4. Gifts from PWS to employees in relation to an internally recognised Company function and event
5. Gifts with nominal or token value that bears a company’s logo (e.g. empty ang pow packets, calendars, diaries, notebooks, notepads, pens and planners).

1. Entertainment
   • Entertainment activities shall be limited to only those individuals who have a legitimate business purpose. PWS will not pay for or reimburse expenses for the said individuals closely related person(s), i.e. spouse(s), family members, relatives or close associates who do not have a legitimate business purpose with The Company.
   • Employees are STRICTLY PROHIBITEDfrom either paying for or participating in any activities which are exorbitant, illegal and immoral such as lavish/ extravagant social functions not related to the PWS’s business activities or entertainment from a business associate (including potential business associate) during the procurement process which may cause PWS to be perceived in an unfavorable or negative manner.

1. Corporate Hospitality
   • Corporate hospitality is generally defined as corporate events or activities (e.g. golf tournaments, concerts, etc.) organised by an organisation which involves employees and third parties for the benefit of that organization.
   • The offering / receiving of corporate hospitality to / from the customers and third parties as part of business networking is acceptable, provided that they are appropriate, with legitimate business purpose, and not perceived as affecting business judgement.

1. Dealing with Public Officials
   • In principle, caution must be exercised when dealing with public officials as it is an offence for a public official to obtain any gift from any person involved in any proceeding or business transaction with him / her.
   • Offering a gratification by corrupt or illegal means to influence a public official or offering gratification for the exercise of personal influence with a public official is also an offence.

1. Donations and Sponsorships (including Political Donations)
   • PWS is committed to the communities in which it does business, including supporting charitable organizations. All donations and sponsorships undertaken which are charitable in nature (“Donations”) must comply with the followings:
     1. No political donations in
     2. Due diligence must be conducted on recipients of donations to ascertain that they are of reputable
     3. All Donation requests must be reviewed by Finance
     4. Proper administration and not to be used for activities involving bribery and corruption

12.         Liability For Acts of Agents

• It is also common in many jurisdictions that the improper acts of agents can create criminal liability for the entities for which those agents work. As such, it is necessary for PWS to ensure that all agents that are engaged for the provision and/or supply of goods and services uphold the principles that are stated in this Policy.
• PWS Employees who deal with clients are responsible for taking reasonable precautions to ensure that the clients conduct business ethically, are aware of PWS’s zero-tolerance approach to bribery and corruption and comply with anti-corruption laws of the respective jurisdictions.

1. Fraud
   • Fraud is defined as knowingly making an untrue or misleading representation with the intention of making a gain for oneself or another, or causing a loss, or risk of loss to another.
   • An employee or a business associate should immediately report a known fraud or suspected fraud that has occurred or is occurring through the Whistleblowing Form. (insert link)

1. Procedural Matters
   • PWS promotes a culture of open and honest communication, especially those related to bribery or corruption matters.
   • Employee and business associate has the responsibility to ensure that suspected bribery and corruption incident are reported promptly. Anyone raising a concern in good faith will not be penalized.
   • Any alleged or suspected improper conduct must be disclosed using the Whistleblowing Form (insert link to form)