Governance

Anti-Corruption

Keyfield maintains a zero-tolerance approach to bribery, corruption and unethical conduct. In FYE 2025, anti-corruption training was implemented across all employee categories, achieving 100% employee participation. Anti-corruption risk assessments were reviewed and updated covering 100% of operations. Over the past three years, the Group recorded zero substantiated incidents of corruption and no whistleblowing reports. The Group has established a comprehensive Anti-Bribery Management System (ABMS) aligned with the requirements of ISO 37001 and the Malaysian Anti-Corruption Commission (MACC) Act 2009. This framework is supported by the Anti-Bribery and Corruption Policy (ABC Policy), Whistleblowing Policy, and a suite of ABC Guidelines that collectively govern ethical conduct, prevent corruption risks, and ensure compliance across all business operations.

The Group’s ABMS framework includes the following key guidelines:

• Guideline on Declaration of Interest

• Guideline on Gifts, Entertainment, Hospitality and Travel (GEHT)

• Guideline on Donations and Sponsorships

• Guideline on Due Diligence on Employees and Business Associates

• Guideline on Training and Communication

The GEHT Guideline (Rev 1, 2025) establishes a “No GEHT” policy, setting clear thresholds, declaration procedures, and approval limits. Employees are prohibited from offering, giving, soliciting, or accepting any GEHT that could influence business decisions or create conflicts of interest. Permitted GEHT must be transparent, infrequent, reasonable in value, and conducted in good faith. All declarations are recorded in a central GEHT Register maintained by the Human Resources department.

Keyfield conducts due diligence on all employees, business partners, contractors, and intermediaries to identify and manage potential corruption risks. Anti-bribery and corruption due diligence are embedded in the supplier and contractor evaluation process, and all third parties are required to acknowledge compliance through a signed Letter of Undertaking. The Guideline on Due Diligence on Employees and Business Associates ensures comprehensive assessment of anti-corruption risks before engagement.

The Group’s Whistleblowing Policy provides confidential and anonymous reporting channels via both website and email platforms at https://keyfieldoffshore.com/whistle-blowing. The policy specifies covered concerns such as bribery, conflict of interest, fraud, and abuse of power, and guarantees protection under the Whistleblower Protection Act 2010 for individuals reporting in good faith.

Keyfield promotes continuous learning through regular Anti-Bribery and Corruption (ABC) training. In 2024 and 2025, the Group conducted training sessions facilitated by external trainers, including representatives from the Malaysian Anti-Corruption Commission (MACC) and Keyfield’s Chief Compliance Officer. These sessions covered types of corruption, Section 17A of the MACC Act, due diligence, and whistleblowing procedures. Awareness is further reinforced through internal ABMS briefings, communication campaigns, and employee acknowledgements of policy compliance.

The Group’s anti-corruption framework aligns with the Guidelines on Adequate Procedures (T.R.U.S.T. Principles) and international best practices, including the OECD Due Diligence Guidance. Regular corruption risk assessments, internal audits, and management reviews are conducted to evaluate the effectiveness of the ABMS and ensure continuous improvement. Through these measures, Keyfield demonstrates strong top-level commitment to ethical governance, integrity, and accountability in all business dealings.

Keyfield protects customer and employee privacy by restricting access to authorised personnel and safeguarding information through password protection and firewall security. The Group complies with the Personal Data Protection (Amendment) Act 2024 and has developed a Personal Data Protection Act Handbook to guide employees on data privacy protocols. In FYE 2025, there were zero substantiated complaints concerning breaches of customer privacy and losses of customer data.

The Group aims to progressively strengthen the integration of ESG considerations into its procurement processes by screening 100% of new suppliers for environmental and social criteria by 2026, and assessing 100% of major suppliers for environmental and social impacts by 2027.