Anti-Bribery and Anti-Corruption Policy

1Introduction

EXICASH SDN BHD ("EXICASH", "we", "us", or "our") is committed to conducting business with integrity, transparency, fairness, and accountability.

This Anti-Bribery Policy / Anti-Corruption Policy ("Policy") sets out EXICASH's position on bribery, corruption, improper benefits, conflicts of interest, facilitation payments, gifts, entertainment, commissions, referral fees, partner incentives, donations, sponsorships, merchant onboarding, and dealings with licensed payment partners, merchants, referral partners, technology partners, suppliers, service providers, government officials, and other third parties.

EXICASH provides technology, integration, dashboard, API, payment link, QR payment integration, reconciliation, reporting, fraud monitoring tools, white-label frontend, onboarding assistance, and technical support.

Regulated payment processing, acquiring, settlement, payout, refund processing, chargeback handling, transaction reversal, transaction holding, and related regulated payment services are provided by licensed or registered third-party payment partners where applicable.

This Policy should be read together with EXICASH's Terms of Service, Privacy Policy, Partner / Third-Party Payment Provider Disclosure, Data Processing Agreement / Data Protection Addendum, Information Security Policy / Security Statement, AML/CFT & Sanctions Compliance Statement, Referral Partner Agreement, and any other policies issued by EXICASH from time to time.

2Purpose of This Policy

The purpose of this Policy is to:

• prevent bribery, corruption, kickbacks, secret commissions, and improper business conduct;
• provide clear guidance on acceptable and unacceptable conduct;
• protect EXICASH, merchants, consumers, licensed payment partners, referral partners, employees, and stakeholders from legal, financial, operational, regulatory, and reputational risks;
• promote ethical dealings with merchants, banks, acquirers, payment gateways, e-money issuers, wallet providers, BNPL providers, technology partners, suppliers, service providers, referral partners, and public authorities;
• support compliance with the Malaysian Anti-Corruption Commission Act 2009 and other applicable anti-bribery and anti-corruption laws;
• support EXICASH's internal controls and adequate procedures against bribery and corruption.

EXICASH adopts a zero-tolerance approach towards bribery and corruption.

3Scope

This Policy applies to:

• directors, officers, managers, employees, interns, temporary staff, representatives, and authorised personnel of EXICASH;
• contractors, consultants, agents, freelancers, developers, and persons acting on behalf of EXICASH;
• referral partners, business introducers, commission agents, resellers, marketing partners, and business development partners;
• merchants, merchant applicants, authorised users, directors, shareholders, beneficial owners, and representatives of merchants;
• licensed payment partners, banks, acquirers, payment gateways, e-money issuers, wallet providers, BNPL providers, payout providers, and other regulated or third-party payment providers;
• suppliers, vendors, technology providers, cloud providers, professional advisers, and service providers;
• any person or organisation that conducts business with, for, or on behalf of EXICASH.

All persons covered by this Policy are expected to understand and comply with it.

4Definitions

For the purpose of this Policy:

"Bribery" means offering, promising, giving, requesting, agreeing to receive, or accepting anything of value with the intention of improperly influencing a decision, action, approval, service, business outcome, onboarding decision, referral, payment method approval, support action, partner decision, or official function.

"Corruption" means the misuse of entrusted power, authority, position, business relationship, system access, confidential information, partner relationship, or decision-making authority for improper personal, business, or third-party gain.

"Gratification" or "anything of value" may include money, gifts, loans, fees, rewards, discounts, rebates, commissions, referral fees, vouchers, entertainment, meals, travel, employment opportunities, donations, sponsorships, services, favours, contracts, confidential information, merchant approvals, onboarding assistance, fee reductions, transaction benefits, or any other benefit, whether tangible or intangible.

"Facilitation Payment" means an unofficial payment or benefit given to speed up, secure, influence, or bypass a routine action, approval, review, onboarding, verification, payment method activation, regulatory process, government process, bank process, acquirer process, or administrative function.

"Government Official" includes any officer, employee, representative, or agent of a government department, ministry, regulator, local authority, public body, state-owned entity, court, law enforcement agency, customs authority, tax authority, political party, public international organisation, or any person acting in an official public capacity.

"Licensed Payment Partner" means any licensed bank, registered merchant acquirer, e-money issuer, payment gateway, financial institution, card processor, e-wallet provider, BNPL provider, payout provider, payment network, or other regulated payment partner involved in payment processing, acquiring, settlement, refund, chargeback, payout, risk review, or related regulated services.

"Merchant" means a company, sole proprietor, partnership, association, NGO, organisation, or other accepted entity that applies for or uses EXICASH services.

"Referral Partner" means any person or organisation that refers, introduces, recommends, markets, or brings potential merchants, partners, or business opportunities to EXICASH, whether or not referral fees, commissions, incentives, or rewards are payable.

"Conflict of Interest" means a situation where personal, family, financial, business, or other interests may interfere, or appear to interfere, with a person's duty to act in the best interests of EXICASH.

"Close Personal Relationship" includes family members, spouses, partners, close friends, relatives, in-laws, business partners, or any other personal relationship that may affect independent judgment.

5General Policy Statement

EXICASH strictly prohibits bribery and corruption in any form.

No person covered by this Policy may directly or indirectly:

• offer, promise, give, request, receive, or accept any bribe or improper benefit;
• use commissions, referral fees, MDR markups, onboarding support, discounts, gifts, hospitality, confidential information, merchant approvals, payment method activation, technical support, or partner relationships to improperly influence a decision;
• make or accept facilitation payments;
• falsify onboarding documents, KYB/KYC records, invoices, referral records, commission records, transaction records, partner submissions, or compliance records;
• improperly influence a licensed payment partner, bank, acquirer, payment gateway, e-money issuer, wallet provider, BNPL provider, merchant, referral partner, or government official;
• conceal or fail to report suspected bribery, corruption, fraud, conflict of interest, kickbacks, or improper conduct.

This applies whether the conduct involves EXICASH employees, merchants, referral partners, licensed payment partners, private companies, government officials, or any other third party.

6Merchant Onboarding and Approval Integrity

Merchant onboarding must be conducted honestly, fairly, and transparently.

No person may offer, request, receive, or accept any improper benefit to:

• approve a merchant application;
• speed up onboarding;
• bypass KYB/KYC checks;
• conceal a prohibited or restricted business;
• hide beneficial ownership;
• alter or manipulate merchant documents;
• submit false information to a licensed payment partner;
• influence payment method approval;
• influence risk review;
• secure preferential treatment for a merchant;
• avoid suspension, termination, or investigation.

Merchants must not offer money, gifts, commissions, favours, entertainment, referral rewards, employment opportunities, or any other benefit to EXICASH personnel, referral partners, or licensed payment partners to influence onboarding or approval.

EXICASH may reject, suspend, or terminate any merchant where bribery, corruption, fraud, document falsification, or improper influence is suspected.

7Licensed Payment Partner Dealings

EXICASH works with licensed or registered payment partners, banks, acquirers, payment gateways, e-money issuers, wallet providers, BNPL providers, payout providers, and other third-party payment providers.

All dealings with Licensed Payment Partners must be conducted ethically and transparently.

No person may offer, promise, give, request, receive, or accept any improper benefit to influence:

• merchant approval;
• payment method approval;
• settlement decision;
• payout decision;
• refund handling;
• chargeback handling;
• risk review;
• transaction monitoring;
• account suspension;
• partner pricing;
• commission arrangement;
• technical certification;
• partner onboarding;
• partner continuation;
• investigation outcome;
• compliance review.

EXICASH may cooperate with Licensed Payment Partners in investigating bribery, corruption, fraud, suspicious activity, prohibited business activity, or misconduct.

8Referral Fees, Commissions, and Incentives

EXICASH may pay referral fees, commissions, incentives, or rewards to approved referral partners according to a written agreement, approved referral programme, invoice, or other documented arrangement.

All referral fees, commissions, incentives, or rewards must be:

• lawful;
• transparent;
• commercially reasonable;
• properly documented;
• supported by genuine referral activity;
• approved by EXICASH;
• paid through proper channels;
• recorded accurately;
• subject to tax and accounting requirements where applicable.

Referral fees, commissions, incentives, or rewards must not be used to:

• bribe a merchant;
• bribe an employee of a merchant;
• bribe a Licensed Payment Partner;
• bribe a government official;
• conceal the true source of referral;
• reward the submission of false documents;
• induce approval of a prohibited or restricted merchant;
• influence onboarding, compliance, settlement, refund, chargeback, or risk decisions;
• bypass EXICASH's AML/CFT, sanctions, fraud, or prohibited business controls.

EXICASH may withhold, cancel, claw back, suspend, or refuse referral fees or commissions if the referral involves fraud, bribery, corruption, prohibited business activity, false information, suspicious activity, merchant rejection, merchant termination, chargeback abuse, regulatory concern, or breach of EXICASH policies.

9MDR Markups, Fees, Discounts, and Commercial Benefits

MDR markups, technology fees, monthly subscription fees, API usage fees, integration fees, discounts, waivers, rebates, and other commercial benefits must be approved, documented, and applied fairly.

No person may misuse pricing authority to:

• provide unauthorised discounts;
• give secret rebates;
• conceal kickbacks;
• favour a merchant due to personal relationship;
• reward improper conduct;
• receive personal benefit;
• bypass approval processes;
• misstate fees to merchants or partners;
• create false invoices or payment records.

Merchants, referral partners, and employees must not request or accept secret rebates, side payments, unofficial discounts, personal commissions, or hidden benefits.

10Gifts, Entertainment, Hospitality, and Travel

Reasonable business gifts, meals, hospitality, or promotional items may sometimes be acceptable as part of normal business relationships. However, they must never be used to improperly influence a decision or obtain unfair advantage.

Any gift, entertainment, hospitality, or travel must:

• be reasonable, modest, and proportionate;
• be given or received openly and transparently;
• be for a legitimate business purpose;
• not be requested or demanded;
• not involve cash or cash equivalents;
• not be intended to influence onboarding, merchant approval, partner approval, pricing, payment method activation, risk review, support priority, dispute outcome, settlement decision, refund, chargeback, or business award;
• not create a conflict of interest;
• not violate any law, contract, partner requirement, or company policy;
• not damage EXICASH's reputation if publicly disclosed.

Cash, cash equivalents, secret commissions, personal rebates, excessive entertainment, luxury travel, hidden benefits, and improper favours are strictly prohibited.

11Facilitation Payments

EXICASH prohibits facilitation payments.

No person may make unofficial payments or provide benefits to speed up, secure, influence, or bypass routine actions, including:

• company registration matters;
• licence or permit matters;
• bank or acquirer processing;
• merchant approval;
• payment method activation;
• KYB/KYC review;
• government processing;
• regulatory review;
• tax or customs matters;
• inspection or enforcement action;
• partner approval;
• technical certification;
• settlement or payout release.

If a facilitation payment is requested, the request must be refused and reported to EXICASH as soon as possible.

12Dealings with Government Officials

Extra care must be taken when dealing with government officials, regulators, public authorities, tax authorities, law enforcement agencies, local authorities, public bodies, or state-owned entities.

No person covered by this Policy may offer, promise, give, request, or accept any gratification involving a government official for the purpose of:

• obtaining or retaining business;
• securing a licence, approval, registration, permit, or inspection outcome;
• influencing regulatory or enforcement decisions;
• avoiding penalties or legal obligations;
• obtaining confidential information;
• influencing a public procurement or official decision;
• obtaining an improper advantage for EXICASH, a merchant, a referral partner, or any other party.

Gifts, hospitality, travel, donations, sponsorships, or benefits involving government officials must not be provided unless lawful, reasonable, properly documented, and approved by EXICASH.

13Donations, Sponsorships, and Charitable Contributions

EXICASH may support legitimate donations, sponsorships, or charitable activities where appropriate.

However, donations, sponsorships, or charitable contributions must not be used to:

• obtain improper business advantage;
• influence a merchant, referral partner, Licensed Payment Partner, supplier, government official, regulator, or business decision;
• conceal bribery or corruption;
• provide personal benefit to an employee, merchant, referral partner, government official, or related party;
• pressure EXICASH into approving merchants, reducing fees, prioritising support, or providing benefits;
• bypass AML/CFT, sanctions, fraud, or prohibited business controls.

Political donations, whether in cash or in kind, must not be made on behalf of EXICASH unless expressly approved by the company and permitted by applicable law.

14Conflicts of Interest

All persons covered by this Policy must avoid actual, potential, or perceived conflicts of interest.

A conflict of interest may arise where:

• an EXICASH employee has a financial interest in a merchant, referral partner, supplier, or service provider;
• an employee is involved in onboarding or approving a merchant connected to a family member, close friend, or personal business partner;
• a referral partner has a hidden ownership interest in a referred merchant;
• a merchant is introduced by a person who has undisclosed influence over EXICASH personnel;
• an employee receives personal benefits from a Licensed Payment Partner, merchant, supplier, or referral partner;
• personal relationships influence pricing, onboarding, support priority, risk review, partner communication, or business decisions;
• confidential EXICASH information is used for personal gain;
• an employee or representative works for a competitor, merchant, referral partner, or supplier without disclosure.

Any actual, potential, or perceived conflict of interest must be disclosed to EXICASH as soon as possible.

EXICASH may require the affected person to abstain from decision-making, transfer responsibilities, terminate the conflict, or take other appropriate action.

15Supplier, Vendor, and Service Provider Conduct

EXICASH expects suppliers, vendors, technology providers, contractors, consultants, professional advisers, cloud providers, verification providers, fraud monitoring providers, and other service providers to conduct business ethically and comply with applicable anti-bribery and anti-corruption laws.

Service providers must not offer bribes, kickbacks, secret commissions, personal rebates, excessive gifts, or improper benefits to obtain or retain business with EXICASH.

EXICASH may terminate or suspend business dealings with any service provider that violates this Policy or is involved in bribery, corruption, fraud, false claims, unethical conduct, or serious misconduct.

16Accurate Records and Internal Controls

EXICASH is committed to maintaining accurate records and proper internal controls.

All transactions, invoices, referral fees, commissions, MDR markups, discounts, waivers, payments, expenses, donations, sponsorships, merchant onboarding records, partner submissions, support records, and business records must be recorded honestly, accurately, and completely.

No person may:

• create false or misleading records;
• hide improper payments;
• split invoices or transactions to avoid approval limits;
• falsify referral records;
• falsify merchant onboarding documents;
• alter KYB/KYC information;
• misstate merchant business activities;
• conceal conflicts of interest;
• approve unsupported claims;
• misclassify payments, commissions, discounts, or benefits;
• destroy or conceal records to hide misconduct.

Accurate records are important for legal compliance, financial reporting, audit, partner trust, fraud prevention, and corporate integrity.

17Red Flags

The following are examples of red flags that may indicate bribery, corruption, fraud, conflict of interest, or improper conduct:

• a merchant offers money, gifts, or favours to speed up onboarding;
• a referral partner requests commission for a merchant they did not genuinely refer;
• a referral partner asks EXICASH to ignore missing or suspicious documents;
• a merchant asks EXICASH to submit false information to a Licensed Payment Partner;
• a person requests payment to a personal bank account instead of a company account;
• invoices are vague, inflated, duplicated, unsupported, or inconsistent;
• a person asks EXICASH not to record or disclose a transaction;
• a merchant, supplier, or partner refuses to agree to anti-bribery terms;
• a government official requests unofficial payment to approve, release, or speed up a matter;
• an employee has an undisclosed relationship with a merchant, referral partner, supplier, or Licensed Payment Partner;
• a merchant requests special approval despite being prohibited or high-risk;
• a person requests secret discounts, side payments, or hidden rebates;
• a partner requests cash, gifts, or entertainment in exchange for favourable treatment;
• a business structure is unusually complex and lacks transparency;
• beneficial ownership is hidden or inconsistent;
• documents appear altered, incomplete, or suspicious;
• referral or commission arrangements are not properly documented.

If any red flag is identified, it must be reported promptly.

18Reporting and Whistleblowing

Any person who becomes aware of actual, suspected, attempted, or potential bribery, corruption, fraud, conflict of interest, facilitation payment, kickback, false claim, or breach of this Policy should report it as soon as possible.

Reports may be made to:

EXICASH SDN BHD Email: support@exicash.com Address: 16-19, Menara Mutiara Sentral, No. 2, Jalan Desa Aman 1, Cheras Business Centre, 56000 Kuala Lumpur, Malaysia

Reports should include as much detail as possible, such as names, dates, merchant names, referral details, invoice numbers, payment references, screenshots, documents, messages, emails, call notes, transaction references, or any other evidence.

Reports may be made in good faith even if the concern later turns out to be mistaken.

19Confidentiality and Non-Retaliation

EXICASH will treat reports of suspected bribery, corruption, fraud, conflict of interest, or misconduct seriously and confidentially to the extent reasonably possible.

EXICASH does not tolerate retaliation against any person who makes a report in good faith or assists in an investigation.

Retaliation may include dismissal, demotion, threats, harassment, discrimination, intimidation, reduced work opportunities, unfair treatment, termination of referral relationship, or other adverse action.

Any person who retaliates against a good-faith reporter may face disciplinary action, termination of business relationship, or legal action where appropriate.

20Investigation

EXICASH may investigate any suspected breach of this Policy.

Employees, contractors, merchants, referral partners, suppliers, service providers, and business partners are expected to cooperate honestly with investigations and provide relevant information or evidence when requested.

EXICASH may take appropriate action based on investigation findings, including:

• corrective action;
• warning;
• suspension;
• termination;
• withholding or clawback of referral fees or commissions;
• cancellation of merchant onboarding;
• suspension of API or dashboard access;
• termination of merchant or partner relationship;
• reporting to Licensed Payment Partners;
• reporting to authorities where appropriate;
• recovery of losses;
• legal proceedings.

21Consequences of Non-Compliance

Breach of this Policy may result in serious consequences.

For employees and internal personnel, consequences may include:

• warning;
• suspension;
• disciplinary action;
• termination of employment or engagement;
• recovery of losses;
• reporting to law enforcement authorities;
• civil or criminal proceedings.

For merchants, referral partners, suppliers, contractors, service providers, or business partners, consequences may include:

• rejection of application;
• suspension or termination of account;
• suspension or termination of API access;
• suspension or termination of referral relationship;
• withholding or clawback of commissions, incentives, or referral fees;
• cancellation of discounts or commercial benefits;
• termination of business relationship;
• reporting to Licensed Payment Partners;
• reporting to authorities where appropriate;
• legal action.

EXICASH reserves the right to take any action necessary to protect the company, merchants, consumers, licensed payment partners, systems, reputation, and legal position.

22Training and Awareness

EXICASH may provide training, guidance, reminders, or communication to employees, contractors, referral partners, and relevant business partners regarding anti-bribery and anti-corruption obligations.

Persons covered by this Policy are expected to understand this Policy and seek clarification if they are unsure whether a situation is allowed.

23Relationship with AML/CFT and Sanctions Controls

Bribery and corruption may be connected to fraud, money laundering, terrorism financing, sanctions evasion, prohibited business activity, false onboarding, and suspicious transactions.

EXICASH may review bribery or corruption concerns together with AML/CFT, sanctions, fraud, prohibited business, and partner compliance controls.

EXICASH may share relevant information with Licensed Payment Partners, banks, acquirers, regulators, law enforcement agencies, professional advisers, and service providers where necessary for investigation, compliance, legal protection, fraud prevention, or enforcement.

24Review of This Policy

EXICASH may review and update this Policy from time to time to reflect changes in law, business practices, risk exposure, internal controls, partner requirements, or operational requirements.

The latest version of this Policy may be published on www.exicash.com or otherwise communicated where appropriate.

Continued use of EXICASH services or continued business dealings with EXICASH after updates means that the relevant person or entity acknowledges the revised Policy.

25Contact

If you have any questions about this Policy or wish to report a concern, please contact:

EXICASH SDN BHD Company Registration No.: 202601015752 (1677849-M) Address: 16-19, Menara Mutiara Sentral, No. 2, Jalan Desa Aman 1, Cheras Business Centre, 56000 Kuala Lumpur, Malaysia Email: support@exicash.com Website: www.exicash.com