SOLUTIONS ENGINEERING HOLDINGS BERHAD AND ITS SUBSIDIARIES (“SEHB GROUP” OR THE “GROUP”)

CODE OF CONDUCT

Code of Conduct

SEHB GROUP and its employees must, at all times, comply with all applicable laws and regulations. SEHB GROUP will not condone the activities of employees who achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates, and bribery. SEHB GROUP does not permit any activity that fails to stand the closest possible public scrutiny.

All business conduct should be well above the minimum standards required by law. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing SEHB GROUP’s operations.

Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, who, if necessary, should seek appropriate legal advice.

General Employee Conduct

SEHB GROUP expects its employees to conduct themselves in a businesslike manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job.

Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer.

Outside Activities, Employment, and Directorships

All employees share a serious responsibility for SEHB GROUP’s good public relations, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to SEHB GROUP and is encouraged. Employees must, however, avoid acquiring any business interest or participating in any other activity outside SEHB GROUP that would, or would appear to:
  • Create an excessive demand upon their time and attention, thus depriving SEHB GROUP of their best efforts on the job.
  • Create a conflict of interest - an obligation, interest, or distraction - that may interfere with the independent exercise of judgment in the Company’s best interest.

Relationships With Clients and Suppliers

Employees should avoid investing in or acquiring a financial interest for their own accounts in any business organization that has a contractual relationship with the Organization, or that provides goods or services, or both, to SEHB GROUP if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of SEHB GROUP.

Gifts, Entertainment, and Favors

Employees must not accept entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or organization with whom or with which SEHB GROUP has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with SEHB GROUP might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.

Kickbacks and Secret Commissions

Regarding the SEHB GROUP’s business activities, employees may not receive payment or compensation of any kind, except as authorized under the Organization’s business and payroll policies. In particular, SEHB GROUP strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law.

Organization Funds and Other Assets

Employees who have access to SEHB GROUP funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in the Organization’s policies and procedures or other explanatory materials, or both. SEHB GROUP imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that SEHB GROUP can promptly investigate further.

When an employee’s position requires spending Organization funds or incurring any reimbursable personal expenses, that individual must use good judgment on the Organization’s behalf to ensure that good value is received for every expenditure.

Organization funds and all other assets of SEHB GROUP are purposed for SEHB GROUP only and not for personal benefit. This includes the personal use of organizational assets, such as computers.

Organization Records and Communications

Accurate and reliable records of many kinds are necessary to meet the SEHB GROUP’s legal and financial obligations and to manage the affairs of the Organization. The Organization’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:
  • False expense, attendance, production, financial, or similar reports and statements
  • False advertising, deceptive marketing practices, or other misleading representations

Dealing With Outside People and Organizations

Employees must take care to separate their personal roles from SEHB GROUP positions when communicating on matters not involving SEHB GROUP business.

Employees must not use SEHB GROUP identification, stationery, supplies, and equipment for personal or political matters.

When communicating publicly on matters that involve SEHB GROUP business, employees must not presume to speak for SEHB GROUP on any topic, unless they are certain that the views they express are those of the Organization, and it is the Organization’s desire that such views be publicly disseminated.

When dealing with anyone outside SEHB GROUP, including public officials, employees must take care not to compromise the integrity or damage the reputation of either the Organization, or any outside individual, business, or government body.

Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the public and others in the Organization, all employees must make every effort to achieve complete, accurate, and timely communications - responding promptly and courteously to all proper requests for information and to all complaints.

Privacy and Confidentiality

When handling financial and personal information about customers or others with whom SEHB GROUP has dealings, observe the following principles:
  • Collect, use, and retain only the personal information necessary for the SEHB GROUP’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
  • Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
  • Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.