Anti-Bribery, Corruption and Competition


We are steadfast in our commitment to ethical business practices with a zero-tolerance stance on bribery, corruption, and competition law violations, underscoring our commitment to upholding a compliant and accountable corporate culture.


In the context of our Company, once an allegation of violating our Company's Bribery and Corruption Policy is substantiated, it will result in immediate dismissal. Under Malaysian law, such breaches can lead to up to 20 years' imprisonment and a fine of at least ten times the sum or value of gratification, or RM1 million, whichever is higher. As for competition law violations, there is a risk of being fined up to 10% of its global turnover in the EU and other jurisdictions.

Hence, we are guided by a resilient framework of ethical guidelines and policies, ensuring the highest standards of business conduct. These documents collectively establish a robust system aimed at fostering transparency, integrity, and compliance throughout our operations:



Towards preventing bribery and corruption, we employ a series of structured and pre-emptive initiatives:


Our commitment to anti-corruption is further affirmed through our proactive engagement with Wong & Partners (a member firm of Baker McKenzie) to conduct a comprehensive review of our Anti-Bribery and Corruption frameworks in accordance with Guidelines on Adequate Procedures pursuant to Section 17A of the Malaysian Anti-Corruption Commission (MACC) Act. Section 17A recommends a comprehensive risk assessment every three years, supplemented by intermittent assessments to ensure the integrity levels of an organisation are not compromised. The assessment concluded that our Company has in place comprehensive policies and procedures to counter bribery and corruption risks and is fully compliant with the Adequate Procedures.


Speak Up Channel

We are committed to ensuring that we conduct our business in an ethical and compliant manner. To support this, we have a comprehensive whistleblowing framework and policy to provide an avenue for employees, customers, suppliers, business partners or individuals to report any unethical, illegal or non-compliant practices.

Being part of a multinational organisation, we ensure that each whistleblowing report is treated with care and privacy, and in accordance with the standards and guidelines established globally. Individuals and entities who submit reports in good faith are protected under this policy, without the risk of retaliation.



In 2023, a total of 10 Speak Up cases were reported in Malaysia and a total of two Speak Up cases reported in Singapore.


Responding to Concerns

In 2022, a total of nine Speak Up cases were reported in Malaysia. All cases were investigated carefully and upon assessment by both the Company and Carlsberg Group Investigations team, six of the nine cases were found to be substantiated and actions were taken to resolve these cases.

The remaining three cases were found to be unsubstantiated after further investigation. The nature of these Speak Up cases mainly consists of non-compliance with Company policies and procedures.

Out of all the 12 cases reported in 2023, four were substantiated with actions taken to resolve these cases, while six were found to be unsubstantiated. The remaining two cases were pending internal investigation as of 31 December 2023. Two key matters were investigated by the Group Investigations team with one unsubstantiated due to lack of evidence upon further investigation.

The substantiated case was related to sexual harassment and discrimination and not fraud, competition or corruption related.