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Anti-Bribery, Corruption and Competition

ANTI-BRIBERY, CORRUPTION AND COMPETITION

We are committed to upholding the highest standards of integrity across our business and to maintaining an uncompromising stance against bribery, corruption and violations of competition
law.

 

Why Is It Important

At Carlsberg Malaysia Group, we believe that our decisions and actions directly influence stakeholder trust. When this matter is not managed well, it weakens confidence in our leadership, raises doubts about our governance standards and creates uncertainty around the integrity of our operations, which in turn places our employees and the company in a vulnerable position.


Building on this understanding, we will strive to safeguard our workforce and Carlsberg’s operations in their entirety by applying a strict zero-tolerance policy on bribery and corruption. We will reinforce clear expectations, strengthen internal oversight and ensure that every level of the organisation understands its responsibility to uphold these standards in our daily business conduct.

 

Our Approach

We based our approach to anti-bribery, corruption and competition on the following frameworks, policies, guidelines and procedures:

 

Progress/Achievements

In the year under review, we intensified our review of bribery and corruption, competition law and data protection through:

Compliance Enhanced Risk Assessment

We completed the Compliance Enhanced Risk Assessment for the Malaysia and Singapore markets to evaluate our legal compliance exposure. The assessment determined that the overall residual risk level remained low risk despite the high impact associated with the identified areas. Based on these findings, we developed and executed mitigation plans addressing key risk areas in bribery and corruption, competition law, data protection and trade sanctions.

Regulatory Compliance Drill

We conducted a regulatory compliance drill exercise at two Carlsberg Malaysia locations together with our external lawyers to evaluate our level of preparedness in the event of regulatory audits. The exercise examined employees’ readiness and their understanding of the required procedures in the event of regulatory audit by Malaysian regulators. The overall outcome was assessed as low risk, indicating a high level of awareness amongst our employees of legal obligations at the locations involved.

 

 

 

Compliance Carnival
We organised our third Compliance Awareness Day for employees across Carlsberg Malaysia and Carlsberg Singapore. The 2025 theme “Compliance Campus” was designed around a campus concept and the programme was structured and conducted over a two-month period. The initiative concluded with a Graduation Day ceremony recognising employees who completed the designated compliance training modules and successfully passed the corresponding knowledge assessment test.

Data Protection Project
We continue to comply with the Personal Data Protection Act 2010, which regulates the processing of personal data in commercial transactions and imposes obligations on data controllers and data processors when handling personal data. We also addressed the introduction of the Personal Data Protection (Amendment) Act 2024 in Malaysia, which was implemented in three stages throughout the first half of 2025 to update the legal framework, align it with General Data Protection Regulation (GDPR) standards and introduce mandatory breach notification requirements. We also incorporated these changes into our internal data protection framework.

Achieved ISO 37001:2025 Anti-Bribery Management Systems Certification

In 2025, we obtained certification for ISO 37001:2025 Anti-Bribery Management Systems from SIRIM QAS International, making Carlsberg Malaysia the first public listed beverage manufacturing companies in SIRIM and one of the first public listed beverage manufacturing companies in SIRIM to achieve this certification.

To obtain the certification, we underwent a comprehensive review of how decisions are made, how supplier relationships are managed, how approvals are handled and how employees are encouraged to speak up. In addition, the upgraded ISO 37001:2025 standard, refreshed after nearly a decade, goes beyond the usual compliance checklist. It now emphasises climate-related bribery risks, stronger Board oversight while promoting an anti-bribery culture across the organisation.

This certification demonstrates that Carlsberg Malaysia met the following requirements of:

  • Having a clear anti-bribery policy supported by top management

  • Carrying out risk assessments and due diligence for suppliers and partners

  • Implementing strict financial and non-financial controls

  • Providing training on anti-bribery practices

  • Operating confidential whistleblowing channels

  • Conducting internal audits and continuous improvements

Speak Up Channel

At Carlsberg, we are committed to ensuring that all business activities are conducted to defined ethical standards and with the required level of professional competence. To give effect to this, we established a formal Speak Up reporting framework and policy, which serves as a channel for employees, customers, suppliers, business partners and any individual to raise concerns relating to misconduct, unlawful behaviour or breaches of internal requirements so that every submission is reviewed and handled within a reasonable timeframe. In this regard:

  • Each report is processed with strict confidentiality and careful oversight in accordance with internationally recognised standards and guidelines

  • Protection from retaliation is provided to individuals and entities who report matters in good faith

In 2025, reported matters in Malaysia and Singapore were recorded as follows:

    • In Malaysia, seven cases were lodged, consisting of two cases that were substantiated and five that were not substantiated following review. The substantiated cases concerned workplace bullying and harassment, while the unsubstantiated matters related to workplace bullying and harassment, retaliation and business integrity

    • In Singapore, four cases were recorded, comprising one unsubstantiated matter, one partially substantiated matter, one substantiated matter and one case that remains under investigation. The unsubstantiated case involved allegations of asset misappropriation, the partially substantiated case related to workplace retaliation, the substantiated case concerned allegations of asset misappropriation and the ongoing investigation pertains to business integrity

Our Performance

In 2025, 100% of our operations were assessed for risk related to corruption. The assessment concluded the following:

Going forward, we will maintain our ISO certification to uphold recognised standards across our operations, strengthen the deployment of our Code of Ethics and Conduct to ensure clear expectations in daily business practices and introduce Compliance Champions as the central theme for Compliance Day 2026 to reinforce ownership and accountability for ethical conduct and compliance obligations across Carlsberg.