Code of Conduct and Ethics for Employees

Corporate GovernanceCode of Conduct and Ethics for Employees

Corporate Governance

Code of Conduct and Ethics for Employee

The Code of Conduct and Ethics (“Code”) adopted by Amtel Group of Companies (“Company”) has been formulated to protect and enhance the Group’s reputation for honesty and integrity.

This section is applicable to all category of employee.

  • Employees shall abide and guided by the Code principles, in all respects and at all times, conduct themselves with propriety and decorum.
  • Discovery of events or acts questionable, fraudulent or illegal nature or which are in violation of the Code is to be reported to the Chairman or Group Managing Director.
  • Breaches of the Code by the employee, especially where it is related to honesty, integrity and maintenance of ethical standards may constitute ground for dismissal or other punitive action.
  • Employees of the Group should not at any time be guilty of any criminal or civil act or conduct that would cause damage to the Group’s reputation, its property or general interests.

1.3.1  The following Code applies to the Group’s daily activities and business decisions:-

A.  Commitment

All employees are required to observe and adhere to the following:-

  • To faithfully and diligently perform such duties and accept such responsibilities as may from time to time be assigned by the Company. Every employee is expected to promote and advance the interests of the Company at all times.
  • To perform duties in respect of the Company he is attached to as well as any other Company within the Group.
  • To faithfully observe and comply with all rules, regulations, procedures, practices and policies of the Group or Company whether expressed or implied.


B.  Personal Benefits

  • No employee may accept personal benefits whether from customers, potential customers, suppliers or agent acting on their behalf.
  • Personal benefits include terms of value, gratuity, favour, service, loan, and legacy, lavish entertainment and free holiday trips and any items where there is a reasonable likelihood that the employee will be or will appear to have been improperly influenced in the performance of his duties to the Company.
  • No employee shall accept any personal fee or commission for any work or advice in connection with the Company’s business unless he has obtained prior clearance from the Company in writing.
  • If an employee receives any personal benefit, he shall immediately report it to Human Resource Manager or the Company Secretary, and upon instructions from Human Resource Manager or the Company Secretary, shall either retain the gift or return it or donate the gift to a charitable organisation selected by the Company.
    The following are excluded:-
  • Normal entertainment in the ordinary course of business of the Company or Group (lunch, dinner etc);
  • Token gifts of commercial value which are occasional and not from a supplier/customer calculated to influence decision;
  • Gifts or cash contribution due to festivities and which are not abnormal (flower basket, festival hampers) and lucky draw sponsorship for annual staff gathering;
  • Remuneration received from an organisation for which the employees provide separate services outside his duties to the Company and for which he has obtained prior clearance from the Company in writing.


C.  Compliance with Laws and Regulations

The Company shall comply strictly with all applicable laws, rules and regulations. If there are questions about any law, advice should be sought from Human Resource Manager or the Company Secretary.


D.  Conflicts of Interest

Members must be alert to and avoid or declare conflict of interest situations. Conflict of interest situation either involves conflict between the Company’s and personal interest or the Company’s and the customer’s interest or personal interest and customer’s interest.

Personal Interests

  • To abstain from acting on behalf of the Company in a transaction that involves parties with whom he or his family members has significant connection/decision making influence or material financial interest; or
  • To engage or concern himself or be interested in any other  business, whether or not the business belongs to him or  to any members of his family  or any other person or  corporation; or
  • To have proprietary or pecuniary interest in the business of any other company, firm or individual, business of which is in whole or in part similar to any trade or business carried on by the Company or Group; or
  • To trade with any company or firm in which the executive or his family members of the staff is interested directly or indirectly; or
  • Any interest outside the Company which indirectly conflict with the business of the Company; or
  • Any executive found to be so employed, engaged, invested,  traded, concerned or interested in business will be regarded to have wilfully breached a condition of employment and the Group or Company reserves the right to terminate the contract of employment forthwith  without  notice  or take other action as the Group or Company deems fit.

Conflict of Interest between Company and Customers

The following are examples of conflicts of interests’ situations involving conflict between the Company’s and the Customer’s interests that should be referred to the management for advice:-

  • Acting as agent for both buyer and seller of a business or asset.
  • Acting as adviser for the acquirer and acquiree in a takeover.
  • Acting as adviser for the acquirer when the Company holds shares in the acquirer as material investment or loan collateral.
  • Acting as advisers to two competitors on similar business issues e.g. marketing strategies.


E.  Dealings with Suppliers

Subject to policy where group services are preferred, an employee must award orders or contract to suppliers strictly based on merits without favouritism.


F.  Confidentiality and Publication

  • An employee of the Group or Company shall not, either during the continuance of his employment or thereafter, except in the proper course of his duties, divulge to any person whosoever and shall use his best endeavours to prevent the publication or disclosure of any trade secrets or manufacturing process or any information concerning the business or finance of the Company and of the Group or any dealings, transactions or affairs which may come to his knowledge during or in the course of his employment.
  • Employees shall not discuss internally or externally confidential information regarding the Company and the Group, its directors or business partners, customers, employees or others except when required by law or in the normal and ordinary course of business conduct of the Company and the Group.
  • Any information generally not available to the public is classified as confidential and such information must not be shared with a third party or used to influence an investment decision in connection with the purchase or sale of securities.
  • Any employee who receives a subpoena or other requests seeking disclosure of the Company and the Group’s information is to contact his immediate superior for guidance.


G.  Public Statement Or As A Guest Speaker

  • Employees are prohibited from making any public statement, either orally or in writing or in any form, on the policies or decisions of the Company and the Group nor shall he circulate any such statement made either by him or anyone else except with the approval of the Company in writing.
  • An employee shall inform Human Resource Manager or the Company Secretary if he is approached by a member of the media to comment on any matters pertaining to the Company or the Group.
  • An employee of the Company and the Group is not allowed to participate as a speaker in talks/seminars/conferences that are not organised by the Company or the Group without the prior approval of the Company in writing.
  • When applying for prior approval from the Company, the employee concerned is required to submit the full text of his talk or speech to be delivered for consideration and approval.
  • When approval is granted and the employee delivers his speech or talk, the employee should not digress by divulging any confidential and pertinent information pertaining to the Company and the Group’s business, operations and policies.If it is established that the employee has divulged confidential and pertinent information of the Company and the Group, the employee shall be subject to the appropriate disciplinary action.

Note: For the purpose of this Code, “family member” means the spouse, parent, child (including adopted child and step child), brother, sister and the spouse of child, brother or sister.