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Code of Conduct & Ethics

The policies and guidelines below (extracted from the Company’s Hand Book) set out the standard of conduct and ethics that all employees are expected to adhere to while at work.


1.1 Under the Contract of Service an employee may be transferred, posted or otherwise instructed or requested to perform duties, permanently or temporarily, in any subsidiary and/or associated or related companies of the Group.

During the course of employment in the Company or in circumstance as described above, it is acknowledged that an employee may obtain Confidential Information.

Confidential Information means any information or material which is proprietary to the Company or designated as Confidential Information by the Company whether or not owned or developed by the Company, of which the employee may have obtained knowledge through or as a result of his employment with the Company; or communications with suppliers, vendors, customers, partners and associates of the Company; or other knowledge with the Company including but not limited to information conceived, originated, discovered or developed by the employee; information not generally known outside the Company or in the relevant trade or industry about or concerning:

a. computer programme, software, processes, data systems used by the Company;

b. the Company’s products whether new or old, processes and services including but not limited to information relating to (whether or not reduced to writing or still in development) designs, concepts, drawings, ideas, inventions, specifications, technologies, discoveries, model, data, documentation, diagrams, flow charts, research, development, processes, procedures, know-how, product or technology information, marketing techniques, materials, plans, timetables and strategies, development plans, customers names and pricing policies.

c. any information in respect of the organization, business, finances, transactions or affairs of the Company; and

d. any information that arises in the course of the Company’s transactions and operations.

1.2 The code of conduct in respect of confidentiality as appended below, shall be binding on all employees:

a. at all times to comply with the Company’s procedures for the receipt and maintenance of Confidential Information at all times;

b. not to disclose or to dissipate whether verbally, in writing or in any manner whatsoever to any third party any Confidential Information or records or any part thereof without the prior written consent of the Company;

c. not to use or attempt to use any Confidential Information in any manner whatsoever whether or not such use may injure or cause loss either directly or indirectly to the Company or its existing business or any business it may venture into or embark upon;

d. upon ceasing employment with the Company for any reason whatsoever, to return immediately the Company all information, records, manuals, notes, files and documents in the employee’s control containing or relating to Confidential Information;

e. not to appropriate or duplicate any Confidential Information, wholly or partially copy the information or any material embodying any Confidential Information by any means whatsoever;

f. the employee shall not for a period of five (5) years after the cessation of employment with the Company for any reason, use for himself or on behalf of or disclose to any third party any Confidential Information or part thereof, except such information in the public domain that was published other than as a result of a breach of this Confidentiality; and

g. The expression “information in the public domain” shall mean only such information published for general public information, but is not limited to publications in a trade journal, trade articles or newspapers and the like.

1.3 The employee hereby acknowledges that the Confidential Information shall at all times remain the property of the Company.

1.4 The employee hereby agrees that if there is a threatened or attempted breach of any of the provisions of the Confidentiality clauses as set out herein, the Company will be entitled to enforce the provisions and will be entitled in addition to any other legal or equitable remedies and without prejudice to any other remedies that the Company is entitled to at law to injunctive relief and a decree for specific performance of the terms of the Confidentiality and Non-Disclosure Agreement without the necessity of showing irreparable harm or actual or threatened damage.

1.5 Where deemed necessary, the Company reserves the right to require an employee to sign and execute a specific Confidentiality and Non-Disclosure Agreement.

1.6 All properties belonging to the Company which are in the possession of the employee and/or given to the employee for his use may be recalled or retracted at any time at the sole discretion of the Company.


2.1 General

It is necessary that all employees should display good discipline and conduct at all times if the Company is to operate efficiently. All employees are also required to follow security, safety, health and other regulations as may be laid down from time to time. A list of misconduct which is illustrative only and not exhaustive is set out in Disciplinary Procedure.

The Company’s policy on discipline is built on equity and all employees can be expected a fair and just treatment in accordance with the Disciplinary Procedure as set out by the Management.

2.2 Disciplinary Actions

In the event an employee is found guilty of misconduct after due inquiry, the Company may either:

a) Give the employee a written warning.
b) Withhold salary increment for one (1) year.
c) Suspend the employee without pay for a period not exceeding one (1) week.
d) Downgrade the employee.
e) Dismiss the employee without notice in the event of any criminal breach of trust or other proven serious offence.
f) Impose any other lesser punishment as it seems just and fit.

2.3 Right to Appeal

An employee who is subject to any disciplinary action shall have the right to appeal.


In line with the Group’s policy of maintaining channels of communication with employees, any employee who has a grievance can apply to resolve that grievance by following the Grievance Procedure as set out by the Management.

The following are the Management’s prerogatives and cannot be the subject matter of a valid grievance:

a) Promotion of any employee from a lower grade or category to a higher grade or category;

b) Transfer of an employee within the organization provided that such transfer does not entail a change that is detrimental to the employee with regards to his terms of employment;

c) Employment of any person by the Company in the event of a vacancy arising in the Company;

d) Termination of the services of an employee by reason of redundancy or by reason of the reorganization of the Company’s business, trade of work or the criteria for such termination;

e) Dismissal and reinstatement of an employee by the Company

f) Assignment or allocation of duties or specific tasks to an employee that is consistent or compatible with the terms of his employment.

Disciplinary Procedure

Disciplinary action may be taken against any employee for having committed any one or more of the following misconduct:

A. Minor Misconduct

i. Relating to Attendance

  • Absent without permission and without valid cause.
  • Reporting late for work.
  • Leaving workplace without permission.
  • Ceasing work before the proper finishing time without permission.

ii. Relating to Safety & Health

  • Refusal to wear or use safety equipment/apparel provided by the Company.
  • Failure to observe safety & health rules and regulations.
  • Careless use of public facilities/utilities.
  • Smoking in areas designated as non-smoking areas.
  • Conduct which is likely to endanger the life or safety of any person.
  • Willful failure to report at once to Immediate Superior of any defect that an employee may notice in any equipment connected with his work.
  • Willful non-reporting of any defect or occurrence which an employee may notice or which might endanger himself or any other person which might result in damage to the Company’s or any person’s property within the Company.

iii. Relating to Company’s Property

  • Not taking proper care of tools, equipment etc entrusted to him.
  • Not keeping machinery and/or workplace clean and tidy.
  • Not taking proper care of uniforms provided.
  • Posting, altering or removing any matter on bulletin boards or Company’s property without the permission of the Management.
  • Excessive use of the telephone for personal calls.
  • Using Company’s stationery and postage for private correspondence.
  • Deliberate rough handling of Company’s equipment/motor vehicle.
  • Unauthorized use of Company’s motor vehicle or equipment.

iv. Relating to Conduct

  • Failure to comply with Company's policy and procedure.
  • Unruly or disorderly conduct in the Company's procedure.
  • Not properly dressed and groomed for work.
  • Obtaining or attempting to obtain leave of absence through false reason(s).
  • Eating and drinking during working hours except in given time for tea break and lunch.
  • Lending or borrowing money within the Company in circumstance prejudicial to discipline.
  • Selling or advertising non-Company products within Company premises during working hours, to colleagues or Company’s customers/clients.
  • Soliciting for funds or business from co-employee’s or Company’s customers/clients without permission.
  • Discouraging customer/clients from buying Company products or using Company services.
  • Interfering with co-employee’s work during working or non-working hours.
  • Writing frivolous or offensive notes, memos, letters etc to co-employees and Superiors.
  • Not wearing uniforms provided by the Company while at work.
  • Playing pranks within Company premises or during working hours.
  • Entertaining private visitors without permission during working hours.
  • Loitering and lingering within Company’s premises.
  • Unsatisfactory work performance.
  • Incurring debts or acting in any manner which would affect the public image of the Company or that of a Company’s employee.
  • Unauthorized liaison with the Press about the Company.
  • Participating in any act or entering into any relationship that could adversely affect the public image of the Company or that of another Company’s employees.
  • Gambling or card playing of any form, whether for money or not, within the Company’s premises at any time.

B. Major Misconduct

i. Relating to Attendance

  • Clocking another employee’s time-card on his behalf or tampering with the time clock or altering the time-card to produce a fraudulent result or attempting to do any of the above.
  • Interfering with the record of attendance or recording attendance of any other absent employee or falsification, defacement, alteration or destruction of any record of the Company.
  • Leaving workplace repeatedly during working hours without permission or overstaying sanctioned leave without valid reasons and without informing or attempting to inform his Immediate Superior of the reason(s) for such absence, immediately.

ii. Relating to Honesty

  • Thefts, fraud or dishonest practices, including attempted thefts, attempted fraud or attempted dishonesty in connection with the Company’s business or property, or that of the Company’s customer/client or other employees.
  • Taking or giving bribes or any illegal gratification.
  • Forging or defacing medical certificate(s) or other document(s) to defraud the Company.
  • Submitting or attempting to submit false reimbursement claim(s).
  • Any misrepresentation or falsification of information on the Application for Employment form.

iii. Relating to Safety and Health

  • Tampering with any Company’s machinery or equipment, thus adversely affecting Company’s operations.
  • Bringing or consuming or using alcoholic beverages, illegal drugs or narcotics within the Company’s premises.
  • Possession of any lethal weapon on the Company’s premises.

iv. Relating to Conduct

  • Willful insubordination or disobedience whether alone or in combination with others, to any lawful and reasonable order.
  • Willful damage, interference, contamination to or loss of Company’s goods or property or that of Company’s customers/clients.
  • Riotous or disorderly behavior or threatening to assault or to do any injury to other employees, or Superiors, within the Company’s premises at any time, or to Company’s customers/clients.
  • Violence, abusing or assaulting other employees, or Superiors within the Company’s premises at any time, or to Company’s customers/clients.
  • Going on strike at work or inciting others to strike in contravention of any law or rule having the force of law.
  • Willful slowing down of work or inciting others to do so.
  • Sleeping while on duty; claims of sickness are not accepted as an excuse, unless the sickness is of a serious and unexpected nature.
  • Unauthorized disclosure of commercial or manufacturing secrets or calculations or formula or designs or any other information.
  • Refusal or failure to submit to medical treatment provided by the Company for addition of any form or illness or injury.
  • Committing an immoral or indecent act within the Company’s premises.
  • Failure or refusal to submit to a search when required to do so by a Company authorized personnel.
  • Engage in private work or trade within or without the Company that is directly or indirectly in conflict with the Company’s interest.
  • Refusal to accept any communication served in the interest of discipline.
  • Trespassing or forced entrance and occupation of the Company quarters or premises.
  • Instigating any form of industrial action among employees against the Company.
  • Spreading false and unpleasant information of the Company among employees and outsiders.
  • Mass attendance at Company’s Panel Doctor or any other medical centers in support of a trade dispute.
  • Holding meetings within the Company’s premises without the approval of the Management except in accordance with the provision of the law for the time being in force.
  • Participating in illegal strikes or abetting, inciting and instigating such activities.
  • Defacing or destroying Company’s documents without permission.
  • Taking part in anti-government activities.
  • Withholding overtime at a critical time to bring pressure on Management.
  • Committing of any act subversive to the discipline of the Company or general behavior.
  • Conviction and imprisonment for any criminal offence.

The above list is illustrative only and not exhaustive.

The principle of this Code of Conduct and Ethics (“Code”) is based on principles in relation to sincerity, integrity, responsibility and corporate social responsibility.

This Code is formulated to enhance the standard of corporate governance and corporate behaviour with the intention of achieving the following aims:

(1) To establish a standard of ethical behaviour for directors based on trustworthiness and values that can be accepted, are held or upheld by any one person.

(2) To uphold the spirit of responsibility and social responsibility in line with the legislation, regulations and guidelines for administrating a company.

In the context of this Code, a company director means any person who holds the position of director in the Company irrespective of any designation used, including anyone who follows the directives and advice of a corporate director and who usually takes action, as well as an in-turn or substitute director. A director also includes both executive and non-executive directors as well as executive and non-executive chairpersons.

In the performance of his duties, a director should at all times observe the following:

Corporate Governance
  1. Should have a clear understanding of the aims and purpose, capabilities and capacity of the company;
  2. Should devote time and effort to attend meetings and to know what is required of the board and each of its directors, and to discharge those functions;
  3. Should ensure at all times that the company is properly managed and effectively controlled;
  4. Should stay abreast of the affairs of the company and be kept informed of the company's compliance with the relevant legislation and contractual requirements;
  5. Should insist on being kept informed on all matters of importance to the company in order to be effective in corporate management;
  6. Should limit his directorship of companies to a number in which he can best devote his time and effectiveness; each director is his own judge of his abilities and how best to manage his time effectively in the company in which he holds directorship;
  7. Should have access to the advice and services of the company secretary, who is responsible to the board to ensure proper procedures, rules and regulations are complied with;
  8. Should at all times exercise his powers for the purposes they were conferred, for the benefit and prosperity of the company.
  9. Should disclose immediately all contractual interests whether directly or indirectly with the company;
  10. Should neither divert to his own advantage any business opportunity that the company is pursuing, nor may he use confidential information obtained by reason of his office for his own advantage or that of others;
  11. Should at all times act with utmost good faith towards the company in any transaction and to act honestly and responsibly in the exercise of his powers in discharging his duties; and
  12. Should be willing to exercise independent judgment and, if necessary, openly oppose if the vital interest of the company is at stake;
Relationship with Shareholders, Employees, Creditors and Customers
  1. Should be conscious of the interest of shareholders, employees, creditors and customers of the company;
  2. Should at all times promote professionalism and improve the competency of management and employees; and
  3. Should ensure adequate safety measures and provide proper protection to workers and employees at the workplace.
Social Responsibilities and the Environment
  1. Should ensure that necessary steps are taken in accordance with the law to properly wind-up or strike off the company register if the company has not commenced business or has ceased to carry on business and is not likely to commence business in the future or resume business as the case may be;
  2. Should adopt an objective and positive attitude and give the utmost cooperation for the common good when dealing with government authorities or regulatory bodies;
  3. Should ensure the effective use of natural resources, and improve quality of life by promoting corporate social responsibilities;
  4. Should be more proactive to the needs of the community and to assist in society- related programmes in line with the aspirations of the concept of 'Caring Society' in Vision 2020; and
  5. Should ensure that the activities and the operations of the company do not harm the interest and well-being of society at large and assist in the fight against inflation.


Other Governance and Policies: