Daiman Development Berhad

Code of Ethics and Conduct

OF DAIMAN DEVELOPMENT BERHAD AND ITS SUBSIDIARIES & ASSOCIATES

The Directors and Management of Daiman Development Bhd, together with that of its subsidiary and associated companies (‘the Group’) are committed to observing and maintaining the highest standards of integrity and behaviour in all activities conducted by the Group, including the interaction with their customers, suppliers, shareholders, employees and business partners, and within the community and the environment in which the Group operates.

To this end, all officers and employees (‘the Affected Persons’) of the Group are required to observe and comply with the ethical policies and guidelines set out below in all aspects of their work and in their dealings with third parties.

Code of Ethics and Conduct

Affected Persons serving the Group shall at all times act in a manner consistent with their fiduciary responsibilities to the Group and shall exercise particular care not to detriment the Group’s results from conflicts between their interests and those of the Group.

For the purposes of this statement, an Affected Person is considered to have a conflict of interest when he / she, or any of his / her Family 1 or Associates 2:

  1. has an existing or potential financial or other interest which impairs or might appear to impair the his / her independent judgment in discharging his / her responsibilities to the Group, or
  2. may receive a material, financial or other benefits from confidential knowledge or information with regard to the Group.

Areas where conflicts might arise include:

  1. substantial share ownership in competing organisations
  2. direct or indirect personal interests in contracts
  3. dual employment with outside organisations
  4. seeking or accepting gifts or entertainment beyond levels considered reasonable in the business environment of the Company / Group

This policy is to be interpreted and applied in a manner that will best serve the interests of the Group. If an Affected Person believes that he or she may have a conflict of interest, the Affected Person shall promptly and fully disclose to conflict to the Managing Director and shall refrain from participating in any way in the matter to which the conflict relates until the conflict question is resolved. In some cases, it may be determined that, after full disclosure to those concerned, the Group’s interests are best served by the Affected Person despite the conflict.

All managers and all employees involved in contracting and procurement are required to make an annual Conflict of Interest Declaration directly to the Managing Director within 10 working days after the year end.

CODE OF CONDUCT

All Affected Persons shall observe and abide by the following:

Honesty, Integrity & Performance Standard

  • Uphold at all times, the principles of honesty and integrity during the course of performing their duties and tasks
  • Avoid conflict of interest by not getting involved directly or indirectly in any business or occupation whatsoever, whether as principal agent, broker, shareholder or otherwise, or be engaged in activities that would be detrimental, whether directly or indirectly, to the Group’s interest.
  • Perform their duties with utmost commitment and with diligence at all times and accept responsibilities as assigned. These include compliance with all procedures and policies and faithfully observe all rules, regulations, practices, directions and goals of the Group.
  • Ensure that any action and conduct does not damage the Group’s property or reputation.
  • Ensure completeness and relevance of all business and accounting records.

Fair Dealing

  • Must never accept or give a bribe, facilitation payment, kickback or other improper payment for any reason. A kickback is the giving or accepting of money, gifts, or anything of value that is provided in return for favourable treatment. However, in recognition of the reality of commercial and business practices, modest gifts and reasonable entertainment are acceptable as part of the normal course of business provided always that such gifts or entertainment are not supplied, or received in return for favourable treatment or potential favourable treatment.
  • Ensure speedy and equitable treatment of customers, contractors and business associates.

Occupational Health, Safety & the Environment

  • Comply with the Group’s occupational health and safety requirements and their procedural aspects so as to ensure maximum safety and comfort for employees and customers.
  • Comply with applicable environmental laws and regulations in the conduct of the Group’s business.

Alcohol & Illicit Drugs

  • Be free from the influence of alcohol and illicit drugs during the course of performing their duties.

Confidentiality & Protection of Assets

  • Keep confidential all information that would reasonably be considered to be confidential and not divulge either directly or indirectly to any person or corporations, such knowledge or information which would be acquired as an officer or as an employee of the Group, including but not limited to terms and conditions of contracts, employee and customer details, performance and financial information and policies and procedures of the Group.

Note:

  1. Family includes spouse, parents, siblings and children and if living in the same household, other relatives.
  2. Associates include any person, trust, organization or enterprise of, in or with which the individual or any member of his or her Family is (a) a director, officer, employee, member, partner or trustee, or (b) has a financial interest that enables him or her acting alone or in conjunction with others to exercise control or influence policy significantly, or (c) has any material association.