Policies

WHISTLE BLOWING

Whistle Blowing is a specific means by which a worker or stakeholder can report or complain through established channels, concerns about unethical behaviour, malpractices, illegal acts or failure to comply with regulatory requirements that is taking place/has taken place/may take place in the future.
Only genuine concerns should be reported under Whistle Blowing procedures. This report should be made in good faith with a reasonable belief that the information and any allegation in it are factual and substantially true, and the report is not made for personal gain. Malicious and false allegations will be viewed seriously and treated as a gross misconduct and if proven may lead to dismissal.

OBJECTIVE

The whistle blowing policy is to provide employees or stakeholders (shareholders, customers & suppliers) of ABSS an avenue to raise genuine concerns and to promote the highest possible standards of ethical and responsible business conduct. The objective of having the policy is also to deter serious malpractice and to avoid crisis management, thereby promoting the best practice of corporate governance at workplace.
As an employee or stakeholder of ABSS, you are encouraged to disclose any information or raise a genuine concern about serious breaches the Code of Conduct. Such breaches of code or violation of law include but not limited to fraud, corruption, malpractice financial irregularities, dishonesty, criminal activities and personal misconduct.
Any report should be based on good faith with a reasonable belief that the information and any allegation in it are factual and substantially true.

TYPES OF WRONGDOING

Parties can report a Whistle blowing complaint if they are aware of any Wrongdoing, including, but not limited to the following:

• Fraud
• Misappropriation of assets
• Sexual harassment
• Criminal breach of trust
• Illicit and corrupt practices
• Questionable or improper accounting
• Misuse of confidential information
• Acts or omission which are deemed to be against the interest of the Company laws, regulations or public policies
• Breach of Group Policies and COBC; or
• The deliberate concealment of any of the above matter of other acts of wrong doing

REPORTING

You may raise the matter either in writing or orally to your direct superior or manager. However, if for any reason, it is believed that this is not possible or appropriate, you should report to a higher chain of authority in which then the report should be made to the Censof Group Managing Director – Datuk Samsul Bin Husin or Censof Chairperson of Audit Committee – Tuan Haji Abdul Gani Bin Haron.
If you report a possible breach of the code of conduct, you have the right to remain anonymous and confidentiality will be maintained. Every effort will be made to protect the whistle-blower or complainant's identity, subject to relevant legal constraints. However, it is usually easier to conduct a full a fair investigation of your concerns if you could identify yourself and disclose as much information as possible within your knowledge.

ACTION

All reports will be investigated promptly. If required, further assistance from other resources within the Group will be sought. The progress of investigation will be reported to the Audit Committee. Upon completion of investigation, appropriate course of action will be recommended to the Audit Committee and Board of Directors for their deliberation. Decision taken by the Committee will be implemented immediately. Where possible, steps will also be implemented to prevent similar situation arising. You will be informed of the investigation from time to time and be advised in writing of the outcome of the investigation.

ACTING IN GOOD FAITH

ABSS expects all parties to act in good faith and have reasonable grounds when reporting a Whistle Blowing complaint. If allegations are proven to be malicious, parties responsible may be subject to appropriate action, up to and including legal action, where applicable.

WHISTLE BLOWING CHANNELS

ABSS is 51% owned by Censof Holdings Berhad, therefore the whistle blowing channels are as follows:

Mr. Ameer Shaik Mydin
Group Managing Director
Email: ameer@censof.com

Tuan Haji Ab Gani Bin Haron
Chairman, Audited Committee
Email: abganiharon@censof.com

For all escalation or communications of any incident(s) of mal-practice(s) or illegal conduct(s) should be address to :

Address:
Censof Holdings Berhad
Unit B-10-06, 6th Floor,
Dataran 3 Two,
Jalan 19/1,
46300 Petaling Jaya,
Selangor Darul Ehsan
Phone: 603 7962 7888
fax: 603 7962 7800

Providing a channel where whistleblowers can lodge any ethics related issues without any fear of reprisals or retributions.

INTRODUCTION

Welcome to Asian Business Software Solutions Pte Ltd (“ABSS”, “we” or “us”). Pursuant to the Personal Data Protection Act 2010 (“PDPA”), ABSS is mindful and committed to safeguarding of your personal information and your privacy. This Personal Data Protection Notice (“Notice”) describes how we may collect, use, share, and keep information about you.

We will only process your personal data in accordance with the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the Personal Protection Act 2010 and any statutory amendments or re-enactments made of the Personal Data Protection Act 2010 from time to time (collectively referred to as the PDPA) as well as this Personal Data Protection Policy.

If you are a corporate entity, references to the term “you” and “your” shall also include your employees, representatives and agents.

SCOPE

In order for us to provide you with our services and to operate in an efficient and effective manner, we may need to collect relevant personal information from you either manually or through our website. The personal information collected by us may be in the form of but is not limited to contact number, address, email address, designation, company name, license number, qualifications, business details or any other information stipulated by the PDPA.

This Notice applies to most of our public-facing ABSS websites and other online offerings and will be available by link on all sites and offerings which it covers. Other ABSS websites, apps, or online offerings may collect and use data about you in a different way and so publish a different ABSS Notice. We encourage you to take a moment to look at this Notice. We ask that you read this Notice carefully as it contains important information about how we will process and use the personal data provided by you through this website.

COLLECTION OF PERSONAL DATA

We collect information that you supply to us when you choose to contact us for more information or when you register for one of our websites or offerings. This data typically includes your name, professional credentials, email address and other contact data. We may append data from other sources to supplement what you give us. We do, on occasion, obtain or license contact information from third parties for limited marketing purposes.

In addition, we may also receive, store and process your personal data which is provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of our products and/or services, performance of conditions of agreements and/or to comply with our legal and regulatory obligations.

We gather date, time, certain information about a user's browser and system or device configuration and capabilities, navigation history and IP address for all visitors to our web sites.

PURPOSES OF ACQUIRING AND PROCESSING YOUR PERSONAL DATA

ABSS processes your personal data only for specific and limited purposes. You agree that all personal data collected and/or processed by ABSS may include but not be limited to the following purposes:

- For administrative and operational purposes;
- For contact and communication purposes;
- For internal records management;
- For identification and verification purposes;
- For compliance with laws and regulations;
- To understand our audience and improve how our websites work;
- To respond to your comments, questions, suggestions and/or requests;
- To resolve and/or to attend to any concerns, complaints and/or issues received;
- To inform you of our services;
- To provide you with the information/support you requested;
- To market and advertise our services to you.
- To process applications for and the provision of ABSS’s Products and/or services;
- For research, statistical studies and/or data analysis purposes;
- To detect, investigate and prevent any fraudulent, prohibited or illegal activity or omission or misconduct;
- For audit, risk management and security reasons;
- For our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia;
- For all other purposes incidental and associated with any of the above.
 

ACCEPTANCE OF THE POLICY

You are given notice that the services will only be made available to you upon your accepting and expressly consenting to the terms of this Notice, where such express acceptance and consent shall be evidenced by you clicking or checking or indicating accordingly on the relevant consent portion of the registration forms or such other documents as may be furnished to you, as the case may be.

By so indicating your acceptance of the term of this Notice, you shall be deemed to have expressly consented to the processing of your personal data by ABSS or any of its authorized agents, employees, partners and/or contractors for purposes as outlined.

You hereby agree and accept that by registering and/or continuing to use the services, you authorize and consent to your personal data being processed by and where required, disclosed to classes of third parties as identified by ABSS for the purposes of ABSS providing the services to you. For the avoidance of doubt, you also hereby explicitly consent to ABSS processing any sensitive personal data relevant to such purposes.

We reserve the right to modify, update and/or amend this Personal Data Protection Policy from time to time with reasonable prior notice to you. We will notify you of any amendments via announcements on the Site or other appropriate means. By continuing to communicate with us, use our services, purchase of products and/access to the Site after being notified of any amendments to this Personal Data Protection Policy, you will be treated as having agreed to and accepted those amendments.

DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your personal data to the following third parties, for one or more of the above purposes: The company’s group of companies including the subsidiaries, related and associated companies;

To vendors that work on ABSS’s behalf;

- To law enforcement when we have a good- faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on us;
- To exercise our legal rights or defend against legal claims;
- Any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge our obligations to you;
- Our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us;
- Data centres and/or servers located within or outside Malaysia for data storage purposes;
- Storage facility and records management service providers;
- Our business partners, service providers, suppliers, vendors, distributors, contractors or agents, on a need to know basis , that provide related products and /services in connection with our business, or discharge or perform one or more of the above purposes and other purposes required to operate and maintain our business;
- Any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities set out in the purposes.
 

YOUR RIGHTS

Notwithstanding anything to the contrary, you may at any time withdraw your consent to ABSS processing any personal data of yours or to any part or portion of the same by sending to ABSS at the address set out below a written notice of withdrawal and within the period prescribed under the PDPA. ABSS shall take all necessary measures to give effect to your withdrawal of consent, to the extent that such withdrawal does not conflict with any of ABSS’s other legal obligations.

If you do not wish to have your personal data shared with any other party, or if you do not wish to be solicited for services offered by ABSS or any other parties including third parties, kindly inform us in writing at the communication information as given below.

You shall, upon written request, be granted access to all personal data held or stored or processed by ABSS. To avoid confusion, “access” for the purposes of this provision shall mean notification of such personal data of yours that is processed by or on behalf of ABSS and to have a copy of such personal data communicated or conveyed to you in an intelligible form of ABSS’s choosing.

You may opt out of our Investor Relations alerts by following the directions at the bottom of our Email Alerts page. To unsubscribe from Email Alerts service from ABSS, send a request to: cs.my@abssasia.com

RETENTION OF YOUR PERSONAL DATA

Any of your personal data provided to us is retained for as long as the purposes for which the personal data was collected continues; your personal data is then destroyed or anonymised from our records and system in accordance with our retention policy in the event your personal data is no longer required for the said purposes unless its further retention is required to satisfy a longer retention period to meet our operational, legal, regulatory, tax or accounting requirements.

SECURITY OF PERSONAL DATA

We are committed to ensuring that your personal data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, we endeavour, where practicable, to implement appropriate technical, physical, electronic and procedural security measures in accordance with applicable laws and regulations and industry standards to safeguard against and prevent the unauthorised or unlawful processing of your personal data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your personal data.

However, we would like to inform you that because of the constitution of the Internet, the rules of data protection and the security measures mentioned above may not be observed by others, persons or institutions beyond our control. Especially unencrypted data - even sent via E-mail - can be read by third parties. We have no technical influence to avoid this. The user has the responsibility to protect the information he/she provides, especially user name and passwords, from misuse, by encryption or other means.

We cannot and do not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.

TRANSFER OF PERSONAL DATA OUTSIDE OF MALAYSIA

Our information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. This may include, but not limited to, instances where your personal data may be stored on servers located outside Malaysia. In addition, your personal data may be disclosed or transferred to entities located outside Malaysia. You hereby expressly consent to us transferring your personal data outside of Malaysia for such purposes. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your personal data other than for that part of the purposes and to adequately protect the confidentiality and privacy of your personal data.

EXTERNAL LINKS

Our sites contain links to other websites not owned by ABSS. We do not control the content or privacy practices of those sites and we do not accept any responsibility or liability arising from those websites.

Likewise, if you subscribe to an application, content or a product from our strategic partner and you subsequently provide your personal data directly to that third party, that personal data will be subject to that third party’s privacy /personal data protection policy (if they have such a policy) and not to this Personal Data Protection Policy.

You may at any time make a written request to ABSS to correct any personal data of yours that is inaccurate, incomplete, misleading or out-of-date and ABSS shall, upon receipt of your written request for correction(s), take all necessary measures to give effect to such correction(s).

Please direct any requests to withdraw consent or to request access and/or correction to any Personal Data as follows:

Address : 
KA3-2-13, Kuchai Avenue, 39 Jalan Kuchai Maju 13,
Kuchai Entrepreneur Park, Off Jalan Kuchai Lama
58200 Kuala Lumpur, Malaysia
Telephone : 1300 880 883
Email : finance@abssasia.com

IMPORTANT - READ THIS CAREFULLY BEFORE USE. This is the Software Licence Agreement (Agreement). As you have
purchased the Product (consisting of the User Documentation and the installation CD or other media containing the
Software), following notification of the Licence you are now legally bound by its conditions. HOWEVER, if the Licence
Agreement contains anything of which you were not aware prior to purchasing the Product or do not agree to be
bound by, DO NOT INSTALL THE SOFTWARE but return the Product to the reseller in its entirety and a full refund of
the purchase price will be made. By installing the Software and keeping the Product you are confirming that you have
purchased the Product subject to this Licence and are bound by its provisions.

TRIAL VERSION SOFTWARE LIMITATION. If you use this Software on a trial basis prior to purchase, then additional
restrictions govern its use. The Trial Version is intended to be used only for evaluation purposes and whilst you may
create your own company data files ("Company Files") you will have access to your Company Files only for a period of
7 days from the date of creation of each Company File. Thereafter, you will be able to access the Company Files
created by you only upon your purchase of the full version of the Software product licence. Upon your purchase of the
full version of the Software product licence, the restrictions in this paragraph (Trial Version Software Limitation) shall
no longer apply, but you acknowledge that your use of the full version of the Software product licence will be
conditioned on your agreeing to the terms of the Software Licence Agreement accompanying the full version of the
Software product licence.

1. Scope of Licence

Asian Business Software Solutions Pte Ltd (the Publisher), through its local publishers and distribution agents, hereby
grants to you, the original purchaser, a paid-up, personal, non-exclusive and non-transferable Licence to use the
Software and the User Documentation only in the region, territory or country specified on the packaging, or in all
countries in Asia, subject to the terms and conditions of this Agreement.

(a) Activation     You must register the Software and activate the company files you create with ABSS. You may
only access each company file you create for 7 days without registering the Software and activating the file. After 7
days the company file will become read-only until you register and activate the company file. You are entitled to
activate up to five (5) company files. If required, you can obtain additional activations by contacting ABSS Pte Ltd.
Activated company files cannot be re-used or recycled.

(b) Number of Users     If you have purchased:

i. Single-User Software Licence, then you may use the Software on only one computer that you own or operate
at a single physical location in respect of company files you have activated. You may transfer the Software from
one such computer to another that you own or operate provided that you do not use or permit the usage of the
Software on more than one computer or computer terminal at a time. In the event of an upgrade or Product
exchange the Licence hereby granted is automatically transferred to the new version or Products.
ii. Multi-User Software Licence, then you may use the Software on only one computer network that you own or
operate at a single physical location and only then in respect of company files created and activated by you or by
another licensed user. You may transfer the Software from one computer to another that you own or operate on
this network provided that you do not use or permit the usage of the Software on more than the licensed number
of computers or computer terminals at a time, nor permit the usage of the Software on more than one network
at any one time, nor permit the Software to be used in respect of company files that you have not activated or
have not been created by you or by another licensed user.

(c) Updates and Upgrades     In the event of an upgrade, update or product exchange, the Licence hereby
granted is automatically transferred to the new version or product. All rights in respect of the original Product shall
lapse and no further use of these shall be permitted. Older versions will no longer be published.

(d) Portable or Home Computer and Archive Copies     You may make a copy of the Software and install it on
either a portable computer or a computer located in your home provided that the copy is for your own exclusive use
and is not operated simultaneously with the original of the Software. Otherwise, you may not copy or duplicate the
Software, except as necessary solely for archival purposes, Software error verification, or to replace defective storage
media, provided you keep the original and the copies. You may not alter, decompile or disassemble the Software. You
may make copies of the User Documentation up to but not exceeding the number of multi-user Licences you have
purchased.

(e) Transfers     You may not sub-license, lease, rent or lend the Software or the User Documentation or
otherwise transfer any of your rights under this Agreement. Subject to the prior written consent of the Publisher and
the agreement of the transferee to be bound by the terms of this Agreement, you may permanently transfer the
Software (together with any backup copies you have made) and the User Documentation. However, you may not
retain any copies of either the Software or the User Documentation.

(f) Term     The Licence granted in this Agreement is effective until terminated. You may terminate it at any time
by destroying the Software and User Documentation, together with all copies, or by returning them to the Publisher. If
you fail to comply with any term or condition of this Agreement, this Licence will terminate and, upon any such
termination, you agree to destroy the Software and User Documentation, together with all copies, or to return them to
the Publisher. Termination of this Licence shall be in addition to and not in lieu of any other remedies available to the
Publisher.

(g) Protection and Security     You agree to use your best endeavours and to take all reasonable steps to
safeguard the Software to ensure that no unauthorised person has access to the Product and that there is no
unauthorised copying or distribution of the Software or User Documentation.

2. Limited Warranty & Disclaimer

The Publisher warrants that the media on which the Software is recorded and the User Documentation provided with it
are free from defects in materials and workmanship under normal use for a period of 30 days from the date of your
original purchase. Except for the limited warranty described above, the Software is sold as is and you are assuming
the entire risk as to its quality and performance. It is your responsibility to verify the results obtained from the use of
the Software.

If during the 30-day limited warranty period, you discover physical defects in the media on which the Software was
recorded or in the User Documentation, the Publisher will replace them at no charge to you, provided you return the
item to be replaced with proof of purchase to the Publisher. THIS IS YOUR SOLE REMEDY. IN NO EVENT WILL THE
PUBLISHER BE LIABLE TO ANY PERSON FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR
SIMILAR DAMAGES, EVEN IF THE PUBLISHER HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Some jurisdictions do not allow the exclusion or limitation of implied warranties or of liability for incidental or
consequential damages, so the above limitations or exclusions may not apply to you. This warranty gives you specific
legal rights and you may also have other rights that vary from jurisdiction to jurisdiction. In the event that any of the
above limitations or exclusions is held to be unenforceable, the Publisher's total liability shall not exceed the amount of
the Licence fee you paid.

3. Entire Agreement

This Licence constitutes the entire agreement between the Publisher and the Licensee and any prior representations,
statement or undertaking howsoever made are expressly cancelled. No amendment or modification to this Licence
shall be valid unless it shall be in writing and signed by an authorised representative of the Publisher.