INTRODUCTION
Contraves Advanced Devices Sdn Bhd and its subsidiaries (collectively “Contraves”) are fully committed to complying with all applicable export control and strategic trade laws of Malaysia, particularly the Strategic Trade Act 2010 (“STA2010”), its amendments and subsidiary legislations.
In line with good governance and responsible business conduct, Contraves shall also observe relevant export and import regulations of other jurisdictions where we operate. This Policy applies to all Contraves employees, and all individuals and/or entities conducting business transactions with Contraves.
OBJECTIVES
This Policy is established to:
- Safeguard national security, foreign policy and international obligations in accordance with STA2010.
- Prevent unauthorised transfer of strategic items, controlled technologies, software and/or related services.
- Implement a robust internal compliance programme encompassing due diligence, licensing and record-keeping.
- Ensure clear accountability of employees in fulfilling export control responsibilities.
- Mitigate risks of penalties, reputational impact and operational disruption arising from non-compliance.
COMMITMENTS
To uphold these objectives, Contraves commits to:
- Provide continuous training and awareness programmes on STA2010 compliance and export control obligations.
- Establish and maintain formal export control procedures with clear structures, processes and documentation.
- Appoint designated personnel to oversee STA2010 and export control activities, with regular reporting to senior management.
- Conduct thorough due diligence and screening of customers, suppliers and end-users to prevent prohibited transactions.
- Obtain all required permits, authorisations and licences under STA2010 before exporting, transhipping and/or brokering strategic items and services.
- Monitor compliance through periodic audits, system reviews and continuous improvement actions.
- Prohibit all illegal, unethical or non-compliant activities involving controlled items, technologies or services.
- Ensure all relevant approvals and compliance documentation are retained in accordance with legal requirements and internal records procedures.
Employees are expected to seek clarification from Management whenever in doubt about STA2010 requirements, and to immediately report suspected violations, red flags or concerns to their supervisor, Head of Department and/or the CEO.
Within ten (10) working days of the issuance date indicated below, all employees shall be deemed to have read, understood and accepted this STA Policy. Any breach of this Policy will be subject to review and appropriate consequences.
This Policy shall be reviewed periodically to ensure continued relevance and effectiveness. The latest version will be disseminated via email by Document Control and displayed at Contraves premises.
Effective 03 October 2025
For and on behalf of CONTRAVES ADVANCED DEVICES SDN BHDCHIEF EXECUTIVE OFFICER