Code of Ethics and Professional Conduct

Integrity is the most important value we hold at Partners Corporate Services Sdn Bhd (“Partners”) and underlines everything we do.

Our emphasis on integrity is important because it reinforces our approach to doing business based on a foundation of ethics and ethical decision-making. It’s both good business and the right thing to do.

In fact, “doing what’s right” has always been a fundamental principle at Partners and a core element of our culture. An ethical mindset supports values-based decision-making when serving clients and during the course of our daily lives. We pride ourselves in focusing on doing not only what is good for business, but what is good for our people and the communities in which we live and work.

Ethical Dealings

The Directors and Management of Partners are committed to adhering to the best practice in corporate governance and observing the highest standards of integrity and behaviour in all activities conducted by the business, including the interaction with its customers, suppliers, employees and business partners, and within the community and environment in which Partners operates.

All employees of Partners play an important role in establishing, maintaining and enhancing the reputation, image and brand of Partners and ensuring the observance to and compliance with the standards of integrity and behaviour that Partners is committed to.

Applicability

All Directors and employees of Partners are bound by the terms of this Code of Ethics and Professional Conduct. It is a condition of employment and/or appointment with Partners that all personnel comply with this Code and failure to comply may result in the commencement of disciplinary proceedings that may lead to termination of employment and/or appointment.

For the avoidance of doubt, the standards set out in this Code extend beyond normal working hours and apply to all personnel fulfilling their roles while on the business of Partners including after hours functions, conferences and social activities.

The code clearly defines the expectations for everyone at Partners and it is the obligation of all Partners’ personnel to know, understand, and comply with the code – both in letter and in spirit. That obligation also includes a duty to act, including reporting any potential violations.

Our Code

• Quality of our Work Product

The reputation of Partners is dependent on the quality of the work product rendered to clients. It is the responsibility of all personnel to abide by the quality control systems in place.

Partners will not overstate its ability to deliver services nor will take offer or provide any services that will damage its reputation or the reputation of its clients.

Prejudice, bias, conflict of interest or undue influence of others must not be allowed to override objective professional or business judgments.

• Zero Tolerance to Bribery & Corruption

Partners was founded and run with a zero-tolerance regime towards any acts or omissions which are corrupt or may create the impression of being corrupt or acting less than with the utmost integrity. Partners will refuse engagement by clients or recuse itself immediately if for whatsoever reason, Partners is required to breach this Code or in any form to facilitate an act of corruption or bribery to acquire any advantage whether for the benefit of Partners or any of its clients directly or indirectly.

As Partners is required in the course of its business, to engage with government officials – such meetings, and dialogues should be carried out during normal working hours, at the normal place of business, and conversations properly and accurately recorded and documented.

The term “government official” means:

• Any officer or employee of a government or any department, agency, or instrument of a government;

• Any person acting in an official capacity for or on behalf of a government or any department, agency, or instrument of a government;

• Any officer or employee of a company or business owned in whole or part by a government;

• Any officer or employee of a political party or any person acting in an official capacity on behalf of a political party; and/or

• Any candidate for political office

Where Partners wishes to extend modest gifts and entertainment normally associated with the proper carrying on of business, any such festive gifts and entertainment must be modest and in accordance with Partners policy on Gifts and Entertainment. At no time is Partners permitted to gift or serve as a conduit, a gift to a government official or any persons whom Partners is aware could be connected or associated with any government official for the purposes of gaining any unlawful advantage.

At all times, personnel of Partners must be cognizant of the perception of impropriety and thus must refrain from any action which may create the impression of impropriety. In complying with these standards, Partners personnel should ask themselves the following questions to aid in assessing what action will raise any inference of impropriety: -

• Are my actions illegal or unethical?

• Am I being fair and honest?

• Would I be unwilling or embarrassed to tell my family, co-workers or the Anti-Corruption agency?

• Would the reputation of Partners be harmed if the action were revealed in the newspapers?

• Could the intended action appear inappropriate to a third party?

• Political Activity

As part of doing business, Partners engages with governments, regulators, public interest groups, industry associations and other similar bodies.

We do this to inform them of our position on issues that affect our clients as well as to promote the interests of our clients in Partners’ mandates to apply for government & regulatory approvals and licences.

We always ensure that we comply with all laws governing political engagement. As a business, Partners are politically neutral. Partners does not have any political party affiliations and does not make political donations.

• Fair Dealing / Conflicts

Partners respects its competitors and compete effectively and fairly at all times.

We quote and receive fees that reflect the value of services provided and responsibilities assumed and are considered fair and reasonable by our clients. We do not incur additional costs by undertaking any work outside our scope of service without prior agreement from our clients.

Partners will be honest, ethical and responsible in the way it presents services to its customers and must be fair and transparent in its relationships with suppliers and contractors from selection through to payment and termination of the relationship.

All personnel must not engage in activities that directly or indirectly involve, or could appear to involve, a conflict between their personal interests and the interests of Partners and/or any of its clients. Areas where conflicts might arise include direct or indirect personal interest in contracts and/or dual employment with or interests in other businesses with outside organisations.

Any actual or potential conflicts of interest are to be fully disclosed to the Board of Directors and where such circumstances are permitted by the Board of Directors to continue shall not be deemed a breach of this Code.

• Compliance with Competition Laws

Partners complies strictly with competition laws.

These laws are complex. Employees who are unsure of appropriate practices must consult with the Compliance officer assigned to their business for additional information and clarification.

The following guidelines will help ensure fair business conduct and appropriate competition.

Do Not:-

• Agree formally or informally with a competitor to fix prices or other terms of sale, rig bids, set sales levels, or allocate customers, markets, or territories

• Discuss any of the following with a competitor: prices, bids, customer sales, commissions and terms of sale, profits, margins, costs, production, inventories, supplies, marketing plans or other competitively sensitive information

• Attend meetings with competitors at which competitively sensitive information, including the subjects mentioned in the above two points, is discussed

• Agree with others outside of Partners as to which suppliers or customers to do business with

• Make unsubstantiated or untruthful comparisons to competitors or comments about their products or services

• Obtain competitively sensitive information from Partners’ competitors or those known to have a duty of confidentiality to such competitors.

• Partners prohibits using illegal or unethical means to obtain competitor or supplier confidential information, including trade secrets. Obtain competitive information about Partners’ competitors only from lawful and appropriate sources.

• Gifts & Entertainment

The giving and receiving of modest gifts or entertainment is an important part of building relationships with suppliers and other parties. However, this should never influence – or appear to influence – our business decisions in any way. We will never seek or apply any influence in exchange for promises, gifts or any other inducements and any gift or entertainment given or received must be appropriate, be approved in accordance with our policy, and where required must be logged in the local gift register.

 Under no circumstances can gifts or entertainment of any description be offered to:-

•  any government official

•  any person working for any Regulator in Malaysia

•  procurement Teams of any existing or potential clients 

• Confidentiality

All Partners personnel must keep confidential all information that would reasonably be considered confidential, obtained in the course of client service.

The disclosure of confidential client information is prohibited to:-

• Anyone who works outside the client’s organization and

• Anyone within the client organization without a need to know

Confidential or proprietary information about a client or other parties which has been gained through employment or office with Partners, shall not be used for personal advantage or for the benefit of third parties.

All Partners personnel are reminded that buying or selling stocks or shares using ‘insider information’ (which includes any information which may affect the prices of securities, either positively or negatively, that is not generally available to the investing public) is illegal. Thus personnel with access to any ‘insider information’ is not to discuss such information with others and are prohibited by law to buy and sell such securities based on any ‘insider information’ obtained under any circumstances.

•  Social Media Guide

Partners personnel are:-

• not permitted to communicate on social media on Partners’ behalf unless one is expressly designated by Partners to do so

• not permitted to use social media to harass or disparage our co-workers, customers, competitors, or others, or express any opinions or ideas attributed to Partners

• not permitted to discuss sensitive information, including confidential and material non-public information on social media

• Sexual Harassment Policy

Partners does not tolerate sexual harassment in the workplace in any shape or form. Partners’ culture is based on mutual respect and collaboration. Sexual harassment is a serious violation of those principles.

Further, Partners does not tolerate sexual harassment from inside or outside of the company. Employees, contractors, customers and everyone interacting with our company are covered by the present sexual harassment policy

Sexual harassment has many forms of variable seriousness. A person sexually harasses someone when they:

• Insinuate, propose or demand sexual favors of any kind.

• Invade another person’s personal space (e.g. inappropriate touching.)

• Stalk, intimidate, coerce or threaten another person to get them to engage in sexual acts.

• Send or display sexually explicit objects or messages.

• Comment on someone’s looks, dress, sexuality or gender in a derogatory or objectifying manner or a manner that makes them uncomfortable.

• Make obscene comments, jokes or gestures that humiliate or offend someone.

• Pursue or flirt with another person persistently without the other person’s willing participation. Also, flirting with someone at an inappropriate time (e.g. in a team meeting) is considered sexual harassment, even when these advances would have been welcome in a different setting. This is because such actions can harm a person’s professional reputation and expose them to further harassment.

The most extreme form of sexual harassment is sexual assault. This is a serious crime and Partners will support employees who want to press charges against offenders.

Partners’ rules on sexual harassment:

• No one has the right to sexually harass employees of Partners

Any person in our company who is found guilty of serious harassment will be terminated, whether they are VPs or assistants. Also, if representatives of Partners’ contractors or vendors sexually harass Partners’ employees, Partners’ will demand that the company they work for takes disciplinary action and/or refuse to work with this person in the future.

• Sexual harassment is never too minor to be dealt with

Any kind of harassment can wear down employees and create a hostile workplace. Partners’ will hear every claim and punish offenders appropriately.

• Sexual harassment is about how we make others feel

Many do not consider behaviors like flirting or sexual comments to be sexual harassment, thinking they are too innocent to be labeled that way. But, if something one does makes your colleagues uncomfortable, or makes them feel unsafe, you must stop.

• We assume every sexual harassment claim is legitimate unless proven otherwise. 

Partners will listen to victims of sexual harassment and always conduct our investigations properly.

If any person is being sexually harassed (or suspects another person is being harassed), please report it to the Managing Director.

Equal Opportunities Employer

Partners prides itself as an equal opportunity employer and aims to:-

• make human resource decisions on the basis of merit with the information available to it, including the possession of skills, experience, qualifications and characteristics relevant to the performance of work

• ensure unlawful discrimination does not occur in the workplace or in circumstances arising out of the employment relationship

• maintain a workplace free from sexual harassment, unfair discrimination or other offensive conduct and

• promote a work environment in which individuals have the opportunity to develop and realise their full potential.

Reporting non-compliance

All Partners personnel are to report genuine suspicions of non-compliance with this Code.

The reporting of non-compliance with this Code should be made to the Managing Director of Partners Corporate Services Sdn Bhd who is responsible for maintaining a safe environment in which to speak up without fear, reprisal or victimisation.

This a reminder that the Managing Director of Partners Corporate Services Sdn Bhd, as a British citizen, can be prosecuted for any corrupt practices carried on outside the UK pursuant to the UK Bribery Act 2010.