Last updated: June 2026
Pertama Partners ("Pertama," "we," "our," or "us") is committed to conducting business with honesty, integrity, and the highest ethical standards. We adopt a zero-tolerance approach to bribery and corruption in all of its forms, in every jurisdiction where we operate, including Singapore and Malaysia. This Program sets out our commitment and the controls we maintain to prevent, detect, and respond to bribery and corruption.
The purpose of this Program is to:
This Program applies across the Pertama Partners group, comprising Pertama Partners AI Solutions Pte. Ltd. (Singapore, UEN 202619329D) and Pertama Partners AI Solutions Sdn. Bhd. (Malaysia, registration no. 202601017482, formerly 1679579-A) (together, "Pertama"). It applies to all directors, officers, employees, interns, and contractors across our Singapore and Malaysian operations. It also extends, so far as relevant, to third parties who perform services for or on behalf of Pertama ("associated persons"), including agents, consultants, subcontractors, resellers, channel partners, and joint-venture partners. Associated persons are expected to apply standards consistent with this Program when acting for us.
We comply with all anti-corruption laws applicable to our business. These include, but are not limited to:
Under Section 17A of the MACC Act, a commercial organisation can be held liable where a person associated with it commits corruption for the organisation's benefit. A defence is available where the organisation can show it had in place "adequate procedures" designed to prevent such conduct. This Program is structured around the five principles of adequate procedures (often referred to as T.R.U.S.T.) described in Section 12 below.
Bribery is offering, promising, giving, requesting, agreeing to receive, or accepting any financial or other advantage as an inducement or reward for improperly performing a function or activity, or to influence a decision. The advantage (sometimes called "gratification") can be anything of value, whether or not it is money, and whether given directly or through a third party.
Corruption is the abuse of an entrusted position or power for private gain. It includes bribery, kickbacks, secret commissions, extortion, embezzlement, and the misuse of confidential information.
These prohibitions apply equally to dealings with government and public officials and to commercial, private-sector counterparties.
You must never, directly or through any third party:
This Program does not prohibit normal and appropriate hospitality or modest gifts that are reasonable, proportionate, and given or received in good faith. A gift or hospitality is acceptable only if it:
As a guide, any gift or hospitality given or received with a value above RM 250 (or its equivalent, approximately SGD 75) per occasion must be declared to the Compliance Contact and recorded in the gifts and hospitality register, and may require prior approval. Cash and cash equivalents must never be given or accepted, regardless of value. Particular caution is required for any gift or hospitality involving a public official. When in doubt, decline, or seek guidance from the Compliance Contact before proceeding.
Facilitation payments are small, unofficial payments made to secure or speed up a routine government action to which the payer is already entitled. Pertama prohibits facilitation payments of any size, in any jurisdiction, regardless of local practice or custom. If you are asked to make such a payment, you must refuse and report the request to the Compliance Contact. The only exception is a payment made under genuine duress where your personal safety or liberty is at immediate risk, which must be reported as soon as possible afterwards.
Pertama does not make political contributions to obtain or retain business or a business advantage. Charitable donations and sponsorships must be made to bona fide organisations, must never be a disguised bribe or made on the request of a counterparty to influence a decision, and must be properly documented and accounted for.
A conflict of interest arises where personal, family, or financial interests could improperly influence, or appear to influence, business judgement. You must avoid actual, potential, and perceived conflicts of interest, and promptly disclose any such situation to the Compliance Contact so it can be managed transparently.
We can be exposed to liability for the acts of associated persons. To manage this risk, we apply risk-based due diligence before engaging agents, consultants, subcontractors, resellers, and other partners who act for us. Depending on the assessed risk, our measures may include integrity checks, anti-corruption representations and warranties in contracts, the right to audit and terminate for breach, and ongoing monitoring. We expect associated persons to maintain anti-corruption standards consistent with this Program.
All payments, expenses, and transactions must be recorded accurately, completely, and in reasonable detail. No undisclosed or unrecorded accounts may be established for any purpose. False, misleading, or incomplete records are strictly prohibited. We maintain financial and operational controls that are reasonably designed to provide assurance against improper payments and to ensure that transactions are properly authorised.
Our anti-corruption controls are built around five widely recognised principles of adequate procedures:
All directors, officers, employees, and contractors receive anti-corruption training as part of onboarding and at least annually thereafter. The training covers this Program and its key requirements, including the prohibition on bribery, kickbacks, and facilitation payments, the rules on gifts and hospitality, conflicts of interest, dealing with third parties, and how to recognise and report concerns. Completion is recorded and personnel are asked to acknowledge that they have read and understood this Program. This Program is also made available to relevant third parties and associated persons.
If you know of, suspect, or are concerned about any actual or potential breach of this Program, you must report it promptly. You can raise a concern in confidence to the Compliance Contact at michael@pertamapartners.com.
Reports may be made in good faith without fear of retaliation. Pertama will not tolerate any form of retaliation, dismissal, penalty, or detriment against anyone who reports a genuine concern or who refuses to participate in bribery or corruption, even if doing so results in the loss of business. Reports will be treated confidentially and investigated appropriately, and the identity of the person raising the concern will be protected so far as reasonably possible and as permitted by law.
Concerns may be raised, and will be received and addressed, in the appropriate local language, including English, Bahasa Malaysia, and Mandarin, so that no one is prevented from speaking up by language.
Breach of this Program is a serious matter. For our people, it may result in disciplinary action up to and including termination of employment or engagement. For associated persons, it may result in termination of the relevant contract. Bribery and corruption are also criminal offences that can lead to prosecution, fines, and imprisonment for individuals and for the organisation.
We review this Program periodically and update it as our business, our risks, and the law evolve. The most current version is published on this page with the revision date shown above.
This Program is adopted by the Pertama Partners group:
For questions about this Program, to request a copy for your records, or to raise a concern, please contact our Compliance Contact at michael@pertamapartners.com.
