Code Of Conduct

INTRODUCTION

The Directors and Management of SEREMBAN ENGINEERING BERHAD together with that of its subsidiaries and associate companies (the SEB Group) are committed to adhering to the best practices in corporate governance and observing the highest standards of integrity and behaviour in all activities conducted by the SEB Group including its interaction with its customers, suppliers, shareholders, employees and business partners, and within the community and environment in which the SEB Group operates.

All employees of the SEB Group play an important role in establishing, maintaining and enhancing the reputation, image and brand of the SEB Group and ensuring the observance to and compliance with the standards of integrity and behaviour that the SEB Group is committed to. It is required that employees display the highest levels of professionalism in all aspects of their work and comply with this Code of Conduct (the “Code”) and all applicable laws, regulations and other policies applicable within SEB Group.

OBJECTIVE

2.1 Purpose of the Code

a)	This Code provides ethical and legal guidance to all Directors and employees of the SEB Group (the “Affected Personnel”) in the conduct of their business and that of the SEB Group.
b)	This Code provides a common behavioural framework for all employees of the SEB Group irrespective of their specific detailed policies. This Code is to be read and applied in conjunction with such policies.

2.2 Applicability of the Code

a)	This Code applies to all Affected Personnel.
b)	The standards set out in this Code extend beyond normal working hours, and apply to Affected Personnel fulfilling their roles while on the business of the SEB Group, including after hours functions, conferences and social activities.
c)	It is a condition of employment and/or appointment with the SEB Group that all Affected Personnel comply with this Code and all applicable laws, regulations and other policies of the SEB Group and failure to comply may result in the commencement of disciplinary proceedings that may lead to termination of employment and/or appointment.

GENERAL PRINCIPLE

3.1 Compliance with Laws

a)	The SEB Group operates in a highly regulated business environment and its activities are subject to numerous laws, regulations and licensing conditions. Affected Personnel must ensure that they familiarsrises themselves with the laws, regulations and license conditions applicable to their activities. If in doubt, Affected Personnel are to seek advice from management.
b)	Affected Personnel must conduct the business activities of the SEB Group in absolute compliance with applicable laws and regulations.
c)	SEB Group aims to provide a safe working environment for its Affected Personnel, its customers and other business partners. Employees must work safely and adhere to appropriate industry practices and laws to protect the health, safety and wellbeing of employees, customers and other business partners.

3.2 Fair Dealing

a)	The aim of SEB Group is to provide an environment in which all Affected Personnel, Customers, suppliers and other business partners are treated fairly and equitably irrespective of, amongst others, sex, race, sexual orientation, age, disability, and religion or ethnic origin. Affected Personnel are to conduct themselves and the business activities of the Group in such manner that facilitates the achievement of these aims.
b)	SEB Group will compete effectively and fairly in the markets in which it operates. It will be honest, ethical and responsible in the way it present its products and services to its customers, uses its market power and its pricing practices.
c)	SEB Group will be fair, honest and transparent in its relationship with suppliers and contractors from selection through to payment and termination of the relationship.
d)	All commercial transactions will be properly and accurately recorded and documented.
e)	Corrupt practices, whether directly or through intermediaries, are unacceptable. No bribes or improper payments, gifts or inducements will be made to, or accepted from, any party, irrespective of local business custom and practices. The SEB Group acknowledges that modest gifts and reasonable entertainment are acceptable as part of the normal course of business provided that such gifts or entertainment are not supplied, or received, in circumstances indicating an inducement or reward has been given, or received.

3.3 Confidentiality & protection of Company Assets

a)	Affected Personnel must keep confidential all information that would reasonably be considered to be confidential, including but not limited to terms and conditions of contracts entered into by the SEB Group, employee and customer details, performance and financial details and policies and procedures of the SEB Group.
b)	The SEB Group will maintain the privacy of confidential information relating to its Affected Personnel and customers.
c)	Assets and confidential information should be fully protected and must not be used by Affected Personnel for personal gain or for any other reason that is not the best interest of the SEB Group.
d)	Misappropriation of property owned by the SEB Group, Affected Personnel, customers or suppliers will not be tolerated. Any misappropriation should be immediately reported and properly investigated. Appropriate disciplinary and legal action will be taken against persons identified.

3.4 Conflicts of Interest

a)	Affected Personnel are to act in the best interest of the SEB Group.
b)	Affected Personnel must not engage in activities that directly or indirectly involved, or could appear to involve, a conflict between their personal interest and the interest of the SEB Group.
c)	Areas where conflicts might arise include substantial share ownership in competing organizations, direct or indirect personal interest in contracts, dual employment with outside organizations within the business environment of the SEB Group.
d)	Any actual or potential conflicts of interest are to be fully disclosed to appropriate management and/or Board of Directors and where such circumstances are permitted by management and/or the Board of Director to continue, shall not be deemed as a breach of this Code.

3.5 Reporting of Non-Compliance

a)	Affected Personnel are to report genuine suspicions of non-compliance with this Code.
b)	The reporting of non-compliances with this Code may either be made to the appropriate supervising manager and/or Board of Directors or may be done in accordance with the Whistle blower Framework and Policy which provides a safe environment in which to speak up without fear, reprisal or victimization.

SPECIFIC PRINCIPLES

4.1 Employee

SEB Group envisages itself as an equal opportunity employer and aims to:

i.	make human resource decisions on the basis of merit based on the information available, including the possession of skills, experience, qualifications and characteristics relevant to the performance of work;
ii.	ensure unlawful domination does not occur in the workplace or in circumstances arising out of the employment relationship.
iii.	maintain a workplace free form sexual harassment, unfair discrimination or other offensive conduct; and
iv.	promote a work environment in which individuals have the opportunity to develop and realize their full potential.

An employee who is found to be in breach of this Code, other SEB Group policies or applicable laws will be subjected to disciplinary action. Inappropriate conduct or performance, or non-compliant issues will be brought to the attention of said employee who will be allowed to respond to all allegations. Except in the case of summary dismissal for serious misconduct, employees should be given a reasonable chance to remedy the inappropriate conduct or performance.

Any grievances with respect to an employee’s employment, treatment, the action of other staff members, customers or suppliers or compliance with this Code or other policies should be raised to management and/or the Board for an appropriate response.

4.2 Know Your Customer and Proper Documentation

a)	Management is required to conduct due diligence on new customers, suppliers and business partners of the SEB Group (including any intermediaries acting on behalf of such customers, suppliers and business partners) and monitor their activities to identify any issues of concern.
b)	Management is required to ensure that payments in respect of all transactions and business, activities of the SEB Group are properly documented to indicate that such payments are made to the proper party for legitimate purposes and in respect of which proper consideration has been received.

4.3. Occupational, Health, Safety & Environment

a)	SEB Group will conduct its business activities and operations in a safe manner and in an environment that prevents, to the extent possible, injury to its Affected Personnel, customers, suppliers and contractors.
b)	SEB Group endeavours to ensure that the SEB Group will ninimise negative environmental impacts of its business activities and will seek to do this through continuous improvement of environmental performance, protection and safety.
c)	SEB Group is committed to providing affective support and training for the employees of the SEB Group to assist them in their responsibilities of ensuring a safe workplace and reducing negative environmental impacts of their activities.

ADMINISTRATOR

5.1 Continous Improvement / Amendment and Update

a)	The appropriateness and effectiveness of this Code will be continuously monitored and appropriate agreed improvements and reporting procedures will be adopted where necessary.
b)	This Code may be updated from time to time. All updates will be announced and Affected Personnel will be required to comply with the Code as updated.
c)	Amendments to this Code must be approved by the Board of Directors.
d)	All updates and amendments are to be communicated to Affected Personnel.

Approved by the Board on 23 November 2018

Code Of Conduct

CODE OF CONDUCT

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