Anti-Corruption Policy
Last Updated: 1 June 2026
1. Our Stance Against Corruption
Walk Production is operated by WP Media Sdn Bhd, a company incorporated in Malaysia and trading as Walk Production for Dubai and UAE inquiries. The Company maintains a zero-tolerance stance toward bribery and corruption. We enforce strict disciplinary measures, including suspension or termination, for personnel who engage in corrupt practices, and we will report suspected violations to the relevant authorities.
2. Legal Framework
The Company’s controlling entity is incorporated in Malaysia and is subject to Malaysia’s Malaysian Anti-Corruption Commission Act 2009 (MACC Act 2009). A person convicted of a corruption offence under the MACC Act may be liable to a fine of up to RM1,000,000 or imprisonment of up to 20 years, or both. The MACC Act also provides for corporate liability where a commercial organisation fails to prevent corruption by a person associated with it.
Walk Production conducts its business in compliance with the applicable anti-corruption laws of the jurisdictions in which it operates, including Malaysia’s MACC Act 2009 and the UAE Federal Anti-Corruption Law (Federal Law No. 31 of 2021) as applicable to its operations and engagements in the UAE.
Consequences
At the individual level:
- Criminal conviction, fines, and imprisonment
- Reputational damage
- Loss of employment
- Loss of professional association membership
At the organizational level:
- Criminal conviction and financial penalties
- Damage to business reputation
- Civil liability and compensation
- Loss of contracts and business opportunities
3. Prohibited Conduct
The following activities are prohibited:
- Offering, promising, giving, soliciting, or accepting any gratification as an inducement or reward
- Bribing public officials, including foreign public officials
- Corruptly procuring or influencing the award or withdrawal of any tender or contract
- Misusing one’s position or information for gratification
- Failing to report suspected corruption offences to the appropriate authority
4. Gratification Defined
Under applicable anti-corruption law, “gratification” is defined broadly. It includes money, gifts, loans, fees, rewards, commissions, employment, contracts, property or interests in property, discounts, the forgiving of debts, services, favors, and the exercise or forbearance of any right, whether given directly or indirectly with corrupt intent.
5. Common Corruption Risk Areas
Gifts and Hospitality
The Company maintains a strict “no gift” policy. Limited exceptions include:
- Company-to-company gift exchanges
- Festive celebration gifts and commemorative items
- Token gifts bearing company branding
Any other gift or hospitality expenditure requires approval from senior management.
Events and Entertainment
Personnel may participate in business events where there is a legitimate business reason, the costs are reasonable, and the employee has notified their supervisor. Expensive arrangements require management approval. The Company does not fund third-party travel or accommodation for business events, and vice versa, except under special circumstances and with written management approval.
Facilitation Payments and Kickbacks
Facilitation payments and kickbacks are strictly prohibited. The only exception is a payment made under duress to prevent injury or loss of liberty, which must be reported to management immediately.
Sponsorship and Donation
All sponsorships and donations require management approval and must not provide an unfair business advantage or serve political purposes.
Purchasing and Procurement
All purchasing decisions must serve the Company’s best interests and be properly documented, specifying deliverables, payment basis, rates, and delivery timelines.
6. Conducting Due Diligence
Prior to engaging third parties, personnel must conduct due diligence reviewing:
- Background and corruption investigation history
- Government or political affiliations
- Country-of-origin risk status
- Suspicious payment patterns or structures
Any irregularities must be escalated to management immediately.
7. Reporting and Whistleblowing
Personnel and third parties are encouraged to report suspected corruption. Reports may be made to the Company, and suspected offences may be reported directly to the Malaysian Anti-Corruption Commission (MACC) at www.sprm.gov.my or to the relevant UAE authorities where the suspected conduct involves UAE-based activities.
Reports to the Company may be submitted to:
WP Media Sdn Bhd (trading as Walk Production)
Email: [email protected]
WhatsApp: Message us
We treat reports in confidence and do not tolerate retaliation against anyone who reports a suspected violation in good faith.