The Group’s management is responsible for ensuring that G3P is uniformly implemented throughout the Company and its subsidiaries in relation to all projects. Disciplinary action, as clearly stated in the document, will be taken against any offence committed.
Confidentiality of information will be observed at all times. This encompasses technical information, particularly with regard to Gamuda projects, financial data, commercial data, strategies, manuals, professional documents, operating procedures and information related to tenders. All information provided by tendering companies, including technical and commercial analysis documents, will also be treated with the strictest confidentiality.

To the extent that it is applicable, no employee is allowed to be a member of more than one of the following committees:
• Tender Opening Committee (TOC)
• Technical Evaluation Committee (TEC)
• Financial Evaluation Committee (FEC)
• Legal Evaluation Committee (LEC)
• Commercial Evaluation Committee (CEC)
In certain circumstances, the TEC, FEC and/or LEC could be joined as one Technical-Financial-Legal Evaluation Committee (TFLEC). In such situations, the TFLEC will ensure a clear segregation of duties to prevent any conflict of interest and eliminate any possible risk of malpractice.

Employees engaged in procurement activities should be honest and impartial with regard to any tender or bid, including the provision of fair contractual terms and conditions. Additionally, the Group reserves the right to conduct an audit on any contractor or consultant to verify the contents of their tender applications.
Employees involved in procurement activities should avoid any form of conflict of interest, as these could adversely affect their actions and decisions.
All employees have a duty to declare and disclose to their respective senior management any material fact or relationship that could be reasonably presumed to cause and/or create a conflict of interest, failing which the respective senior management reserves the right to take disciplinary action against the employee.
All procurement is to be conducted in accordance with free competition to ensure the best quality at lowest cost. This entails issuing competitive bids.

Employees are to treat all contractors and consultants equally, and to adhere to the following guidelines:
• To select contractors and/or consultants who meet requirements with regard to special skills, related experience, good track record,
production capacity and sound financial capacity
• Not to select any bidder who has expressed no interest to bid or work with Gamuda
• Not to disclose the identity of bidders to each other
• To issue the same tender or bidding documents, including addendums and clarification, whether printed or in electronic form, to all
contractors and/or consultants

All contractual commitments, expressed or implied, will be recorded in written documents that accurately reflect the outcomes of any award or negotiation, in line with the contractual terms and conditions as advised and agreed by Gamuda.
Employees are forbidden to accept any form of bribery or corruption at any time, and especially during the procurement process. Any employee who is made an offer or receives an attempted bribe from any individual, contractor or consultant is to immediately lodge a report of the incident to his/her respective senior management including the Head of Internal Audit. Legal provisions with regard to bribery are stipulated under the Malaysian Anti-Corruption Commission Act 2009 (Act 694).
Employees are not permitted to accept any offer for any kind of social entertainment or leisure trip sponsored by any individual, contractor, consultant, agent or proxy of the individual, contractor or consultant given with the intention to seek any benefit to the individual, contractor or consultant.

Employees are not obliged to any individual, contractor or consultant in the course of procurement activities and will not participate in any transaction that will lead to personal gain. This includes the acceptance of gifts, benefits, compensation or consideration as
an inducement or reward from any individual, agent or proxy of the contractor or consultant for doing or refraining from doing or to show favouritism or disapproval to any contractor or consultant.

Any employee who is aware of irregular business dealings between an employee and individual, contractor or consultant is to bring the matter directly to the attention of the respective senior management, including the Head of Internal Audit. This includes any bribery, act of cronyism, ownership of stakes (directly or indirectly) in an individual’s, contractor’s or consultant’s company or any kind of inappropriate behaviour that runs counter to the G3P.
Unauthorised communication or engagement via e-mail, telephone or personal visits between an employee and contractor or consultant during the procurement process is not allowed, unless authorised by the Procurement Committee and approved by the Management Committee.
No property owned by Gamuda is to be used to give any undue advantage to employees or contractors or consultants, either for personal use or benefit. This includes industrial tools, technical know-how, strategic information, technologies, business strategies and development projects.