1. DEFINITION

• 1.1 A code of conduct is set of rules outlining the social norms and rules plus responsibilities of, or proper practices for, an individual, party or organization.
• 1.2 United Malacca Berhad (UMB) Code of Conduct sets forth the standards of how an employee should conduct themselves on their job and to respect each category of our stakeholders.
• 1.3 Our goal in articulating these basic principles for all UMB directors and employees to build even greater confidence and trust in UMB business practices in the international and local communities.

2. OBJECTIVE

• 2.1 The aim of this Code is to share principles and guidelines to employers, employees, other direct and non-direct individuals in the organization on practices of the industrial and labour relations functions for achieving greater industrial harmony.

3. CODE OF ETHICS

The code of ethics is organized into categories, as follows:-

• 3.1 Conflict of Interest
• 3.2 Company Property
• 3.3 Harassment
• 3.4 Discrimination
• 3.5 Safety and Health
• 3.6 Confidentiality (business plans, new & current products)
• 3.7 Anti-Bribery

• 3.7 Anti- Bribery
  • UMB Group is committed to conducting our business in accordance with all applicable laws, rules and regulations and the highest ethical standards, and this commitment is embodied in the Code of Business Conduct and Ethics. The purpose of this Anti-Bribery policy is to reiterate UMB’s commitment to fully comply by the Company, its subsidiaries and affiliates, and its officers, directors, employees and agents with Malaysia’s Corruption 2009 Act.

4. CODE ADMINISTRATION

• 4.1 Reporting – Whistle Blowing Policy
  • Enables Employees to raise genuine concerns regarding actual or suspected unethical, unlawful, illegal, wrongful or other improper conduct and also sets out the process for employees and others to report their concerns freely without fear of reprisal or intimidation.
• 4.2 Managerial responsibilities
  • Being in a managerial position, it is the duty and responsibility of a Manager to promote a culture of ethics and compliance within the organization. Managers should at all times, model appropriate conduct and discipline.
  • As a Manager you should,
    • Make sure that the individuals supervised under your division, to understand the Code and other company policies.
    • Make opportunities to discuss the Code and reinforce the importance of ethics and compliance with the employees.
    • Develop an environment where employees are able to communicate raising concerns without fear of retaliation.
    • Always act to stop violations of the Code by the employees who you supervise.
• 4.3 Human Resource (HR) responsibilities:-
  • HR is in charge of consulting and advising matters arise based on grievance reported.
  • The mechanism of handling such grievance will be based on the internal discipline management system.

5. VIOLATION OF THE CODE OF CONDUCT

• 5.1 When the Code of Conduct is violated, and the violation falls into a disciplinary category defined in the employee work rules or other regulations, the employee(s) involved in the violation may be subject to the disciplinary action in accordance with these rules and regulations.
• 5.2 In addition, directors, managers, and supervisors who ignore violations or through gross negligence fail to prevent them may also be subject to disciplinary action in the manner stipulated by the employee work rules and other UMB regulations.

The code of conduct defines the perspective of the organization, catering Components from:-

• Employee
• Business and Financial
• Products

Is to also assist an individual who is associated directly and indirectly with the Organization to work and carry job function in a CORRECT manner.

The code is subject to change and will be revised as and when required.

BY ORDER OF THE MANAGEMENT