Corporate Policy
Central Global Technology Sdn. Bhd. maintains a formal export control and sanctions compliance program to ensure that the company, its personnel, and its business activities comply with all applicable export control and sanctions laws and regulations.
Policy Statement
Central Global Technology Sdn. Bhd. ("the Company") is committed to conducting all business in full compliance with applicable export control and sanctions laws and regulations, including, where applicable, Malaysia's Strategic Trade Act 2010, sanctions measures implemented under Malaysian law, and the export control and sanctions regimes of other jurisdictions whose laws apply to the Company's transactions, services, technology, and business partners.
The Company does not knowingly engage in any transaction, directly or indirectly, that would violate applicable export control or sanctions regulations. This commitment applies across all of the Company's business lines — AI Model-as-a-Service, EV solutions, IT services, and cloud services — and to all directors, employees, contractors, and parties acting on the Company's behalf.
Compliance with this policy is a condition of doing business with the Company. Where a proposed transaction presents an irreconcilable conflict with applicable regulations, the transaction will not proceed.
Compliance Program
Responsibility for export control and sanctions compliance is assigned at management level. The designated compliance function oversees the program, advises on transactions, maintains procedures, and reports on compliance matters to company leadership.
Customers, suppliers, partners, and other counterparties are screened against applicable sanctions and restricted-party lists before onboarding and at appropriate intervals thereafter. Matches and potential matches are escalated for review before any transaction proceeds.
For sensitive offerings — including access to AI compute capacity, model-serving infrastructure, and technology services — the Company conducts proportionate due diligence on the identity, ownership, location, and stated end use of the counterparty, and assesses diversion risk before service activation.
Goods, software, and technology transferred by the Company are assessed against applicable control lists. Where an export, re-export, or transfer requires a licence or authorisation, the Company obtains it before proceeding, and complies with all conditions attached to such authorisations.
Customer and partner agreements incorporate appropriate export control and sanctions clauses, including end-use representations, restrictions on resale or onward transfer to prohibited parties or destinations, and rights to suspend or terminate service where compliance concerns arise.
The Company applies technical and procedural controls — including access governance, usage monitoring, and geo-restriction measures within its platforms — designed to prevent its services from being accessed or used in violation of applicable sanctions or export controls.
Relevant personnel receive training on export control and sanctions obligations appropriate to their roles, with refresher training and updates when regulations or the Company's risk profile change.
Screening results, due diligence records, licence determinations, and related transaction documentation are retained for the periods required by applicable law and sound compliance practice.
Personnel are required to escalate suspected violations or red flags to the compliance function. Reports may be made without fear of retaliation. Suspected violations are investigated and, where required, disclosed to the relevant authorities.
The program is reviewed periodically — and upon material regulatory or business change — to confirm it remains effective, and is updated as needed to address evolving export control and sanctions requirements.
Application
This policy applies to all business activities of the Company and its personnel worldwide, and to all third parties acting for or on behalf of the Company. It is approved at management level, reviewed on a periodic basis, and may be updated to reflect changes in applicable law or the Company's operations.
Questions regarding this policy, or requests for compliance information in connection with a transaction, may be directed to our team.