Governing regulation
Malaysia Anti-Corruption Commission Act 2009
Trust Centre
Anti-Bribery & Corruption Policy
Upstream BPO prohibits bribery and corruption in all forms, under the Malaysian Anti-Corruption Commission Act 2009. We recorded zero substantiated bribery incidents in the past 12 months, and we conduct corruption-risk due diligence on all third-party engagements.
Key information
At-a-glance governance context
These points summarise the public scope of this page and the main contact or review context around it.
Substantiated incidents
Zero in the past 12 months
Third-party due diligence
Conducted on all third-party engagements
Policy enquiries
dpo@upstreambpo.com
Section 1
Governing regulation and definition
Upstream BPO operates under the Malaysian Anti-Corruption Commission Act 2009. Where local law in another operating jurisdiction imposes stricter controls, the stricter controls apply.
We use the definition of bribery set out in ISO 37001, the Anti-Bribery Management System standard: the offering, promising, giving, accepting or soliciting of an undue advantage of any value, financial or non-financial, directly or indirectly, and irrespective of location, in violation of applicable law, as an inducement or reward for a person acting or refraining from acting in relation to the performance of that person's duties.
Section 2
Who this applies to
This policy applies to all employees of Upstream BPO and to the Board of Directors. It also applies to our stakeholders acting on our behalf or in connection with our business: customers, vendors, agents, consultants, outsourced personnel and other representatives.
Section 3
Prohibited conduct
The following are prohibited without exception.
- Solicitation, bribery and corruption in any form.
- Facilitation payments.
- Commissions, discounts and secret profits outside authorised policies.
- Gifts and entertainment outside the controls set by our Code of Ethics.
- Political contributions. Upstream BPO makes no political contributions to parties, officials or candidates.
- Sponsorships and donations that fall outside our transparency and accounting requirements.
Section 4
Third-party due diligence
Upstream BPO conducts corruption-risk due diligence on all third-party engagements, covering vendors, agents and consultants. Due diligence is completed as part of engagement rather than applied selectively to higher-value relationships.
Section 5
Training
Anti-bribery training is embedded in onboarding, and continuous anti-bribery training runs for every employee. Completion is tracked as a percentage.
During 2025, 100% of Upstream BPO employees completed anti-bribery training.
Section 6
Incident record
Upstream BPO recorded zero substantiated bribery incidents in the past 12 months. We disclose this figure as a metric with its reporting period rather than as an open-ended assurance.
Section 7
Reporting a concern
Report suspected bribery or corruption through our whistleblowing channel, governed by Upstream BPO's Whistleblowing Policy and Procedural Manual. Reports route to dpo@upstreambpo.com or through the whistleblowing form.
Our whistleblower protection page sets out the non-retaliation commitment, the acknowledgement window and the investigation process that applies to these reports.
Reviewer questions
Questions we are asked in security review
Answers are stated in full here so they are quotable directly into a security questionnaire.
Which regulation governs your anti-bribery policy?
The Malaysian Anti-Corruption Commission Act 2009. Where local law in another operating jurisdiction imposes stricter controls, the stricter controls apply.
Does Upstream BPO make political contributions?
No. Upstream BPO makes no political contributions to parties, officials or candidates.
Are facilitation payments permitted?
No. Facilitation payments are prohibited without exception.
Do you screen third parties for corruption risk?
Yes. We conduct corruption-risk due diligence on all third-party engagements, covering vendors, agents and consultants.
How many substantiated bribery incidents have you had?
Zero in the past 12 months.
Who does the policy apply to?
All employees of Upstream BPO and the Board of Directors, together with customers, vendors, agents, consultants, outsourced personnel and other representatives acting on our behalf.
Related resources
Related governance and service pages
Use the connected pages below for deeper privacy, governance, service or contact context.
Contact & Escalation
Anti-bribery policy enquiries route to dpo@upstreambpo.com. Report suspected bribery through the same address or the whistleblowing form.
Next Step
Need a deeper governance review?
Send certificate requests, subprocessor list requests, incident reports and vulnerability disclosures to dpo@upstreambpo.com. We acknowledge security and trust enquiries within 3 business days.