(Industry-Friendly Version – 2025)

1. 1. 1. PURPOSE

These guidelines help ensure that AFAM and its members operate in line with the Malaysia Competition Act 2010. As AFAM brings together companies that may compete with each other, it is important that our discussions and activities do not — even unintentionally — lead to anti-competitive behaviour.

Our goal is simple: AFAM must be a safe, professional platform for discussions on industry development, regulatory issues, and operational challenges.

1. 1. 2. AFAM’S COMMITMENT

AFAM is committed to:

• • • Supporting fair and open competition in Malaysia’s freight and logistics sector.
    • Ensuring our meetings and activities do not involve any anti-competitive conduct.
    • Helping members understand what can and cannot be discussed in an association setting.
    • Creating an environment where international and domestic partners can participate confidently, knowing AFAM upholds competition law principles.

1. 1. 3. WHO THESE GUIDELINES APPLY TO

These guidelines apply to:

• • • AFAM Committee and office bearers
    • All members
    • Committee and task force members
    • Guests, observers, and invited participants
    • All AFAM meetings, WhatsApp groups, emails, circulars, and official communications

1. 1. 4. WHAT MUST NOT BE DISCUSSED

To remain compliant with the law, AFAM members must not discuss or exchange information on:

4.1 Pricing

• • • freight rates
    • surcharges and charges
    • fuel or security fees
    • discounts, rebates, or margins
    • future price intentions

4.2 Commercial or Competitive Strategies

• • • customer lists
    • tenders or quotations
    • credit terms
    • business expansion plans
    • operational cost structures

4.3 Market Division

• • • allocation of customers
    • allocation of routes, airlines, carriers, or territories

4.4 Coordinated Actions

• • • collective boycotts
    • agreements that reduce competition
    • restricting members from dealing with certain customers or suppliers

If in doubt, do not discuss it at an AFAM platform.

1. 1. 5. WHAT CAN BE DISCUSSED

AFAM encourages open and transparent conversations on topics that genuinely help the industry, including:

• • • regulatory matters (Customs, MAHB, CAAM, MOT, MyCC, etc.)
    • operational challenges at CTOs, GHAs, airports, ports
    • infrastructure issues
    • security, safety, and compliance standards
    • digitalisation efforts
    • industry capacity-building and training
    • government policies affecting freight and logistics
    • general, aggregated industry statistics (not company-specific)

These are the core purposes of AFAM’s existence — and are fully permitted.

1. 1. 6. HOW AFAM MEETINGS SHOULD BE CONDUCTED

(Simplified, practical version)
To protect the Association and its members, all meetings will follow three simple principles:

6.1 Stay Within the Agenda

Meetings should stick to the agenda and cover only industry-wide issues, operational topics, and regulatory matters.

6.2 Competition Reminder

At the start of each meeting, the Chairperson will briefly state:

“Please note that discussions must comply with competition laws. No pricing or commercially sensitive information.”

6.3 Stop Improper Discussions

If any participant raises a topic that may breach competition law, the Chairperson will:

• • • stop the discussion immediately
    • move the meeting to the next agenda item

No further action is needed unless the behaviour continues.

1. 1. 7. COMMUNICATIONS & WHATSAPP GROUPS

AFAM communications — including WhatsApp — are professional channels.

Members must not share:

• • • sensitive pricing information
    • tenders or quotations
    • customer data
    • internal cost structures or strategies

Admins may remind members if needed and move discussions back to appropriate topics.

1. 1. 8. DOCUMENTS, SURVEYS & DATA

AFAM may collect or publish only:

• • • general industry information
    • historical, non-sensitive data
    • aggregated feedback for government submissions

AFAM will not collect company-specific pricing, market share, or competitive strategy information.

1. 1. 9. MEMBER RESPONSIBILITIES

Each member is responsible for ensuring their representatives:

• • • understand these guidelines
    • participate responsibly
    • avoid raising prohibited topics
    • notify AFAM if something appears non-compliant

AFAM is a shared platform — every member plays a role in protecting it.

1. 1. 10. ENFORCEMENT

If a member repeatedly disregards these guidelines, AFAM may:

• • • issue a reminder or warning
    • limit participation in certain meetings or groups
    • escalate issues to the Committee

For serious or deliberate violations, AFAM may notify MyCC.

However, AFAM’s approach is always to guide, educate, and resolve matters amicably first.

1. 1. 11. ACKNOWLEDGEMENT BY MEMBERS

All AFAM members agree that:

“Our participation in AFAM activities will comply with the Competition Act 2010 and these Competition Compliance Guidelines. We will not use AFAM as a platform for anti-competitive behaviour.”

1. 1. 12. EFFECTIVE DATE

These guidelines become effective upon adoption by the AFAM Committee on 15^th January 2026.

1. 1. 13. CLOSING NOTE

These guidelines are designed to be:

• • • practical
    • industry-friendly
    • easy to follow
    • aligned with Malaysian and international standards

AFAM remains committed to supporting the growth of Malaysia’s freight and logistics sector while maintaining the highest standards of compliance and professionalism.

AIRFREIGHT FORWARDERS ASSOCIATION OF MALAYSIA (2019)(AFAM)
MEMBER COMPETITION COMPLIANCE DECLARATION FORM

Company Name: ______________________________________________________________

Address: _____________________________________________________________________

Representative Name: __________________________________________________________
Position: _____________________________________________________________________
Email / Contact: _______________________________________________________________

COMPETITION COMPLIANCE DECLARATION

We, the above-named company and its authorised representative(s), hereby declare the following:

1. 1. 1. We acknowledge receipt of the AFAM Competition Compliance Guidelines (2025).
      2. We agree to comply fully with the Malaysia Competition Act 2010 and all relevant laws governing competition and anti-trust practices.
      3. We shall not use AFAM as a platform to engage in, encourage, or facilitate any anti-competitive conduct, including but not limited to:
         • discussion of pricing, freight rates, surcharges, margins, or cost structures
         • exchange of tenders, quotations, or commercially sensitive information
         • market or customer allocation
         • collective boycotts
         • any coordinated action that may restrict competition
      4. We shall ensure that all representatives attending AFAM meetings or forums on our behalf understand and follow these guidelines.
      5. We shall inform AFAM immediately if we observe or have concerns about any discussion or activity that may breach competition law.

We acknowledge that non-compliance may result in AFAM taking corrective action, including reporting serious breaches to the Malaysia Competition Commission (MyCC).

Signature                          : _______________________________________
Name                                   : _______________________________________
Position                             : _______________________________________
Date                                     : _______________________________________
Company Stamp           :