Rotiboy Bakeshoppe Sdn Bhd

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The Rotiboy Group strictly prohibits bribery and corruption in all its businesses. The Company adopts a ZERO TOLERANCE APPROACH against all forms and acts of bribery and corruption, and upholds all applicable laws concerning anti-bribery and corruption. The objectives of this policy is to establish a standard policy to ensure that the whole approach and process in dealing with all external parties, which includes Suppliers, Franchisee, current and future Business Partners is consistent across the company and in line with the Company’s policies and commitment against bribery and corruption.


This Anti-Bribery & Corruption (ABC) Policy ensures that members and business partners of the Rotiboy Group understand their responsibilities in compliance with the Rotiboy Group's zero tolerance for bribery and corruption within the organization. Rotiboy Group does not tolerate Bribery and Corruption!


This ABC Policy shall apply to all Directors, Managers, members of the Rotiboy Group in dealing with internal and external parties in the commercial context.
This policy's scope also applies to Suppliers, Franchisees, current and future Business Partners. From here on, this group will be known as ‘Business Partners’.

3.1 Introduction

Bribery or Corruption is the act of giving or receiving of any gratification or reward in the form of cash or in-kind of high value for performing a task in relation to his/her job description. Accordingly, all members of the Rotiboy Group and Business Partners must refrain from any acts of bribery that take the form of offering, promising, giving, demanding, or receiving anything of value to anyone in the form of bribes, kickbacks and/or any other improper gratification (including gifts, hospitality and entertainment) to influence the outcome of any transaction improperly, whether it is for their benefit or the benefit of the Rotiboy Group.
Gratification can be subdivided into the following categories (without limitation to):-

  • Agreement to give employment or render services
  • Employment
  • Dignity or title
  • Contract of services
  • Position
    • Money
    • Donation
    • Gift
    • Loan
    • Fee
    • Reward
    • Financial Benefit
    • Valuable Security
      • Property – can be movable or immovable
        Examples :-
      • Movable property: car, shares in a company
      • Immovable property: house, land
        • Undertaking or promise to do or not to do something (whether orally or in writing, with conditions or without
        • Favours

          3.2. EXAMPLE
          1. A contractor comes to the company to pitch for a contract of services. The contractor then awards someone within the company a watch or treats the employee to a meal or dinner to gain the award of a contract of service. The employee is wrong in accepting the gift/meal.
          2. Someone that comes for an interview and provides the interviewer with a gift, to get the job. The interviewer accepts the gift.
          3.3 COMPLIANCE
          All members of the Rotiboy Group and its Business Partners are responsible for always complying with all laws and regulations. No excuses or exceptions will be acceptable for non-compliance with any domiciled laws and regulations where the Rotiboy Group conducts its business. The 4 main offences that are stipulated in the Malaysian Anti-Corruption Act 2009:-
          1. Soliciting/Receiving Gratification (Bribe) [section 16 & 17(a) MACC Act 2009]
          2. Offering/Giving Gratification (Bribe) [section 17(b) MACC Act 2009]
          3. Intending to Deceive (False Claim) [Section 18 MACC Act 2009]
          4. Using Office or Position for Gratification (Bribe) (Abuse of Power/Position) [Section 23 MACC Act 2009]
          3.4 REPORTING
          Where there are reasonable grounds and genuine reasons to suspect that there is a violation of the ABC policy or need any clarification, members of the Rotiboy Group and Business Partners are required to report the particulars of such suspicions or consult the Rotiboy Group’s dedicated channel for reporting. And they are:
          1. To Managing Director (Hiro Tan at [email protected]) or
          2. To the Head of People & Culture (David Jansen at [email protected])
          3.5 IMPLICATIONS
          The Rotiboy Group strictly does not tolerate any bribes given for obtaining or retaining business for the Rotiboy Group or providing an advantage to the companies of the Rotiboy Group. Furthermore, the Rotiboy Group does not tolerate any such acts of bribery, even in a personal capacity.
          1. Any member of the Rotiboy Group that breaches any of the ABC Policy may fall within the scope of serious misconduct. It will be subjected to disciplinary action, up to and including dismissal, depending on the facts and circumstances of each case.
          2. For Rotiboy Business Partners, contracts will be terminated immediately.
          3.6 WHISTLEBLOWER
          The Rotiboy Group ensures that there will be no retaliation or repercussions on any member for making genuine reports on violation of the ABC Policy. Any genuine reports made will be kept strictly confidential and only informed to persons on a need-to-know basis to safeguard the interests of the Rotiboy Group and also to ensure that any processes undertaken will not be compromised.
          1. A WHISTLEBLOWER informs the Management in his/her view of an act of bribery or corruption. Whistleblowers are protected.
          2. WHISTLEBLOWERS are also protected under the Whistleblower Protection Act 2010 and Section 65 of the MACC Act 2009.
          3. A WHISTLEBLOWER who has witnessed a bribery or corruption will be considered a witness and protected under the Witness Protection Act 2009.

          All members and Business Partners of the Rotiboy Group are responsible for keeping themselves up-to-date with the Rotiboy Group and their employer's latest policies and processes, in particular, this Rotiboy’s ABC Policy and ensuring the highest standards of compliance are followed.


          This policy outlines the spirit behind the Company’s approach and standard procedures, which must be followed in the ordinary course of business. Where circumstances are abnormal or situations not anticipated by this document arise, these matters should be resolved in a manner that is consistent with the whole aim and spirit of this policy.
          It is difficult for any policy to cover every conceivable situation therefore, there may be some particular circumstances that fall outside the scope of the above policy. These individual cases will be discussed with the individual and a mutually agreeable arrangement will be made. Any matter not specifically covered under the policy guidelines shall be referred to the Head, People & Culture (David Jansen) for necessary advice. The interpretation of this policy rests exclusively with the Rotiboy Group. The decision of the company shall be final and binding.