ANTI-BRIBERY AND CORRUPTION POLICY SUMMARY - Canon Malaysia

Canon Marketing (Malaysia) Sdn. Bhd. (CMM) is committed to conducting business in a virtuous and ethical manner, free from all aspects of bribery and corruption. We have a zero tolerance stance to any form of bribery or corruption which we have communicated to relevant stakeholders. We prohibit our Employees, Directors and Business Associates from soliciting, receiving, procuring, offering, or giving bribes in any form, regardless of whether the conduct is accepted business practice.

CMM has implemented an Anti-Bribery Management System (ABMS) to comply with the adequate procedures requirements in Section 17A of the Malaysian Anti-Corruption Commission Act 2009. We have taken into account the principles of T.R.U.S.T in the Guidelines on Adequate Procedures in establishing the ABMS. The ABMS covers, among others, our anti-bribery and corruption policy, conflicts of interests, giving and receiving gifts, entertainment, hospitality, travel and benefits, donations and sponsorships, various financial and non-financial controls as well as ethicspoint, our confidential whistleblowing line.

To this end, our confidential whistleblowing line www.ethicspoint.com (please key in “Canon” under “organization name”), is open to all persons to raise concerns in good faith, or to give suggestions to improve our ABMS. We encourage the use of ethicspoint, and will take allegations of bribery or corruption seriously.

CMM will take action against any Employee, Director or Business Associate we find to be in breach of applicable laws dealing with bribery and corruption or our policies that directly or indirectly deal with bribery and corruption.

Our ABMS will be reviewed from time to time and may be amended to suit the changing needs of CMM.

Approved by:

Local-Board of Group Management

14 September 2020