AGTC Genomics Sdn. Bhd. (“AGTC Genomics” or “the Company”) is committed to conducting business with integrity, transparency, accountability and professionalism. We adopt a zero-tolerance approach towards all forms of bribery, corruption, kickbacks, facilitation payments, fraud, money laundering and improper business practices.

This Anti-Bribery and Corruption Policy reflects our commitment to ethical conduct, good governance, regulatory compliance and responsible business practices across all areas of our operations, including clinical genomics, laboratory services, research collaborations, commercial partnerships, procurement, healthcare engagements and public-sector dealings.

The purpose of this policy is to:

• communicate AGTC Genomics’ zero-tolerance position against bribery and corruption;

• provide clear guidance on acceptable and unacceptable conduct;

• support compliance with applicable anti-bribery and anti-corruption laws, including the Malaysian Anti-Corruption Commission Act 2009 and Section 17A corporate liability requirements;

• ensure that gifts, hospitality, donations, sponsorships, procurement, recruitment and third-party relationships are managed with integrity and transparency;

• strengthen AGTC Genomics’ culture of ethics, impartiality, accountability, patient confidentiality, quality assurance and compliance.

This policy applies to all individuals and organisations who work for, represent, act on behalf of, or conduct business with AGTC Genomics, including:

• directors, shareholders, senior management and employees;

• contract staff, interns, consultants, advisors and representatives;

• suppliers, vendors, distributors, agents, contractors and service providers;

• business partners, collaborators, introducers, intermediaries and joint venture partners;

• customers, hospitals, clinics, universities, research institutions, healthcare professionals, public agencies and other external stakeholders.

This policy applies to AGTC Genomics’ business activities in Malaysia and, where applicable, overseas.

AGTC Genomics strictly prohibits any person acting for or on behalf of the Company from offering, promising, giving, requesting, accepting or agreeing to accept any bribe, gratification, kickback, facilitation payment or improper advantage.

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Bribery and corruption are serious offences and may result in disciplinary action, termination of employment or contract, civil liability, criminal prosecution, financial penalties and reputational damage.

All employees and business partners are expected to act honestly, fairly and professionally at all times.

AGTC Genomics adopts a “No Gift” position.

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Employees and associates must not solicit, request, accept, offer or provide gifts, entertainment, hospitality or personal benefits that may influence, or appear to influence, business, clinical, procurement, regulatory or professional decisions.

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Limited and modest business courtesies may only be allowed when they are lawful, appropriate, infrequent, proportionate, transparent, properly documented and not intended to obtain an improper advantage.

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Gifts, entertainment or hospitality must never include cash, cash equivalents, personal loans, personal discounts, vouchers convertible to cash, extravagant travel, personal holidays, benefits for family members, secret payments or anything that may breach the rules of the recipient’s organisation.

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Extra caution must be exercised when dealing with healthcare professionals, procurement officers, regulators, public officials, public hospitals, public universities and government-linked entities.

AGTC Genomics may support legitimate scientific, educational, charitable, community, patient-benefit or corporate responsibility activities where such support is aligned with the Company’s values and approved by the appropriate authority.

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Donations, sponsorships and corporate responsibility contributions must not be used as a disguise for bribery, improper inducement, political influence, procurement advantage, referral inducement, regulatory advantage or personal benefit.

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All such contributions must be lawful, transparent, properly approved, supported by reasonable due diligence, accurately recorded and made only to legitimate organisations or beneficiaries.

As a general policy, AGTC Genomics does not make monetary or in-kind political contributions to political parties, political officials, candidates for political office or organisations established primarily for political purposes.

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AGTC Genomics will not reimburse employees, directors or associates for personal political contributions. Employees may participate in lawful political activities in their personal capacity, provided they do not use the Company’s funds, resources, name, logo, influence or working time without approval.

AGTC Genomics prohibits facilitation payments and kickbacks of any kind.

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Employees and associates must not make, offer, request, accept or approve any payment or benefit intended to speed up routine administrative actions, secure preferential treatment, obtain confidential information, influence procurement or reward improper conduct.

Any request for a facilitation payment or kickback must be refused and reported immediately through the Company’s reporting channels.

Where a payment is demanded under threat to personal safety, the individual should prioritise safety, report the incident as soon as possible and ensure the payment and circumstances are accurately recorded.

AGTC Genomics strongly objects to money laundering and any practice involving proceeds of crime, illegal assets or suspicious transactions.

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Employees involved in finance, procurement, sales, contracts, customer onboarding, grants, collaborations or vendor management must conduct reasonable due diligence to understand the identity, business background, source of funds, destination of payments and legitimacy of transactions.

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Suspicious transactions or unusual payment requests must be escalated to Finance, Compliance or Management before proceeding.

AGTC Genomics expects all third parties to uphold the same standards of integrity, transparency and ethical conduct.

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The Company may conduct risk-based due diligence before appointing or engaging suppliers, distributors, agents, consultants, contractors, service providers, collaborators or other business partners.

Where appropriate, AGTC Genomics may include anti-bribery, audit, termination, confidentiality, data protection and compliance clauses in contracts.

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AGTC Genomics reserves the right to suspend, withhold payment, terminate engagement, report to authorities or take legal action against any third party that breaches this policy or acts in a manner inconsistent with the Company’s ethical standards.

AGTC Genomics recognises that managing bribery and corruption risks is a continuous process.

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The effectiveness of this policy and related procedures shall be reviewed regularly through risk assessment, internal audit, supplier review, management review, incident investigation, corrective and preventive action review or independent review where required.

This policy shall be reviewed at least once every three years, or earlier where there are changes in law, regulatory expectations, business operations, risk profile, accreditation requirements, organisational structure or findings from audits, investigations or management review.