Code of Business Conduct and Ethics

Purpose

This code of business conduct and ethics (“COBCE”) is designed to set certain standards of conduct to be observed by the Directors and Employees of the Tambun Indah Land Berhad and its subsidiary companies (“the Group”).

These rules do not cover every issue that may arise but set out basic principles to guide the Directors and Employees of the Group in carrying out their business duties.

Responsibility and compliance with the COBCE

Apart from understanding and complying with the COBCE, as a Director or an Employee, you are also responsible to:

  • Ensure those reporting to you understand and comply with the COBCE;
  • Promote compliance and good ethical values via leadership by example; and
  • Provide guidance to others who have raised concerns or questions regarding the COBCE.

You must read and declare compliance with the COBCE upon appointment to or joining the Group. You may be subject to disciplinary action, up to and including termination of employment or dismissal, for violating the COBCE. Violation of the COBCE that is related to criminal acts may result in prosecution after referral to the appropriate authorities.

  1. Working with Local Communities

Engaging with and contributing to local communities wherever we operate in a socially responsible manner, without compromising the benefits of any particular stakeholder.

  1. Fair-dealing

In the interest of preserving reputation and integrity of the Group, every employee shall act impartially, honestly and responsibly in dealing with all other employees, stakeholders, regulators and public, where he/she shall not:-

  1. aid/assist other competitors to compete with the Group; and
  2. take unfair advantage of anyone through manipulation, concealment, abuse of power or confidential information, misrepresentation of material facts, or any unfair dealing practice.

Work Environment and Employment

We are committed to build a working environment where openness, trust and mutual respect are integral part of the Group’s culture.

Equality in Workplace

Every employee will be recognized based on their skills, knowledge, experience and performance. We will not tolerate unlawful discrimination or abuse of power in relation to employment.

Harassment and Violence

Any types of harassment and violence will not be tolerated. These actions or behaviours include derogatory comments based on gender, racial or ethnic characteristics, and unwelcomed sexual advances, spreading of malicious rumours or use of emails, voicemail and other forms of communication channels to transmit derogatory or discriminatory material.

  1. Compliance With Laws and Regulations

All directors and employees shall, in your business conduct, observe the laws and regulation applicable to the Group.  This includes the relevant law and regulation governing “Anti-Money Laundering” and “Insider Trading”.

  1. Environment, Occupational Safety and Health

Health and safety are important for our employees and communities where we operate. We ensure our business operations are sustainable, by proactively addressing environmental challenges and respecting fundamental human rights, without sacrificing long-term economic value creation. You must create and maintain a safe working environment to prevent workplace injuries by:

  • Using all devices provided for your protection;
  • Ensuring that protective devices are in good working condition;
  • Reporting immediately unsafe equipment and tools, hazardous conditions and accidents to the Management; and
  • Complying with the Occupational Safety and Health laws and regulations.

You are also responsible for the safety of fellow workers and the general public and are encouraged to promptly report any breaches of environmental, safety and health laws at the workplace.

  1. Conflicts of interests

All Directors and Employees are expected to make business decisions in the best interests of the Group. A conflict of interest arises when you have a personal interest that could be seen to have the potential to interfere with your objectivity in performing duties or exercising judgement on behalf of the Group. You should avoid conflicts of interest.

Reporting Conflict of interests

If you find yourself in a situation of conflict whether actual or potential, you must report in writing as soon as practicable stating the facts, nature and extent of the conflict:

Employee : report to respective head of department
Management : report to Managing Director
Director : report to Board of Director, and where relevant, the prior approval of shareholders must be sought, as stated in the Malaysian Companies Act,  2016 and Bursa Malaysia Listing Requirements.

Commission and other benefits

Directors and Employees are prohibited from receiving commissions or other benefits from counterparts, business partners and competitors of the Group. Every Director or Employee must ensure that their personal business dealings with suppliers and customers are on arm’s length basis.

  1. Gifts

You shall not receive or offer gifts or other benefits from or to a competitor, client or supplier of the Group. However, to receive gifts that are not excessive in value, do not constitute cash gifts, are consistent with customary business practices and do not violate any laws or regulations is permitted.

  1. Outside employment

For full-time Employee, you must not take up employment outside the Group or engage in any outside business/ service which may be in competition with the Group or give rise to actual or perceived or potential conflict of interests with your duties in the Group.

  1. Protecting Group assets

The Group entrusts you with the Group’s assets in the performance of your job.

You must protect these assets against waste, loss, damage, abuse, misuse, theft, misappropriation or infringement of Intellectual Property rights and ensure these assets are used responsibly.

  1. Proprietary and Confidential Information

In the performance of your duties, you may obtain information not generally available or known to the public or the market. Hence, you must not communicate or disclose this information in any manner to competitors, customers, persons engaged in any aspect of the securities industry, members of trade associations or other third parties unless such communication or disclosure is authorised by the Group.

You must be aware that any unlawful or unauthorised disclosure of proprietary or confidential information may result in irreparable loss and/ or damage to the Group. In such cases, the Group may institute civil and criminal proceedings against the offending party. The proprietary or confidential information is only disclosed to other Employees on a need to know basis.

You have an obligation to continue to preserve the proprietary and confidential information even after the appointment/employment has ceased, unless disclosure is required by any order of any court of competent jurisdiction or any competent judicial, governmental or regulatory authority.

  1. Political Activities

You have the right to participate as individuals in the political process. Your participation shall be carried out entirely on your own accord and volition, in your own time and with your own resources.

Your political opinions must be clearly delivered as personal opinions and not representative of the Group’s position.

Any Employee who wishes to hold any key position as office bearer in any political party must disclose and obtain prior approval from the management. Those who wish to actively participate full time in politics or are nominated as candidates in any election or are elected as representatives in the Federal or State Legislative Body must resign from the Group.

  1. Whistle Blowing

Whistle blowing is a specific means to report or disclosed matters of concern about possible improprieties and irregularities which may be raised in good faith and confidence, without fear or reprisal. The Group’s Whistle Blowing Policy is formalised in the Board Charter which is available in the Group’s website, www.tambunindah.com.