Correct Supplier Code of Conduct and Ethics

Why do we have this Code?

We, Kuan & Ho Sdn, Bhd are committed to conducting business in a fair, ethical and lawful manner in which the company operates. Accordingly, we expect our business partners to share the same commitment. This Supplier Code of Conduct and Ethics serves to set out the minimum standards of business we expect from all our Suppliers (as hereinafter defined).

This Code may be amended by us from time to time and all such amendments shall be binding on the Suppliers with effect from the date the amended Code is uploaded on our website at www.kuanho.com.my

Who docs this Code apply to?

This Code applies to all Suppliers of the Group. For purposes of this Code, “Supplier” means all third parties that are permitted to perform duties and functions for, or provide goods and/or services to Kuan & Ho Sdn. Bhd. (“KHSB”), whether directly or indirectly – this includes, without limitation, contractors, sub-contractors, consultants, suppliers, vendors, service provider and agents of the KHSB.

We expect our Suppliers to communicate the standards and expectations contained herein effectively throughout their organization as well as their supply chain to ensure this Code is all times upheld throughout the entire supply supply chain.

This Code shall be a condition to all contracts made or to be made between the Supplier and the KHSB. By the acceptance of any purchase order from the KHSB, the entering into any contracts with the KHSB, and/or the supply of any goods and/or services whether directly or indirectly to the KHSB, the Supplier acknowledges and signifies its acceptance this Code and the agreement to comply with the provisions here under.

What are the standards and expectations?

(a)    Compliance with Applicable Laws and Regulations

The Supplier shall comply with all applicable laws and regulations in every country in which the Supplier operates and where its goods and/or services are provided/supplied. This includes, without limitation, ensuring that it:

• • has obtained, and maintains, all the necessary licensees, approvals, permits and permissions; and
  • has control measures in place to prohibit, detect and rectify any non-compliance or breach.

Where there is a discrepancy between the requirements of this Code and prevailing laws or regulations, the Supplier shall comply with the provision a higher or more onerous standard and/or obligation on the Supplier.

(b)    Anti-Bribery and Corruption Practices

The offering or acceptance of any form of bribe or corruption such as, without limitation, facilitation payment, kickbacks, reward, gifts, blackmail, gratification or behavior involving improper advantages, benefits or incentives, is strictly prohibited. The Supplier shall conduct business ethically in compliance with:

• • the Malaysian Anti-Corruption Commission Act 2009 and all applicable anti-bribery and corruption laws; and
  • the KHSB’s Anti-Bribery Policy, an electronic copy of which is available at www.kuanho.com.my

(c)    Gifts and Entertainment

The company adopts a “No Gift” policy whereby, subject only to limited circumstances, employees of the Group are prohibited from receiving or providing gifts, whether directly or indirectly. Accordingly, the Supplier shall refrain from offering or giving gift and entertainment in any form with the intention of influencing business decisions or encouraging the recipient to act inconsistently with his/her duties and obligations, whether for the benefit of the Supplier or otherwise.

(d)    Conflict of interest

The Suppliers shall not engage directly or indirectly in any personal or business activity that conflicts with the interest of the Group.

Additionally, in the event any of the directors, shareholders or key management members of the Supplier or becomes related to any director, shareholder or employee of KH, the Supplier shall immediately notify Managing Director, details of which is set out at the bottom of this Code.

(e)     Fair Competition Conduct

The Supplier shall adopt fair practices in all its business conduct. The Supplier shall ensure compliance with all applicable anti-competition / anti-trust laws and regulations, and shall not engage in anti-competitive conducts or arrangements such as, without limitation, price fixing, manipulation, bid rigging, allocations/division (whether or customers, territories, products and/or market), boycotting, collusive behavior (such as entering into an arrangement with competitor(s) to increase the price of a product/service), tying or linking arrangements, misuse/abuse of market power, dumping, and refusal to supply without any justification.

(f)     Privacy

The Supplier shall comply with all applicable data privacy laws and regulations as well as the KHSB’s Privacy Policy, the electronic version of which is available at www.kuanho.com.my this includes, without limitation, having adequate system and policies in place to safeguard the collection, use, disclosure, retention and processing of all personal sata.

(g)     Labour and Human Rights

All forms of forced, abusive and illegal labour are prohibited. The Supplier shall treat its employees (whether contractual or permanent) with fairness, dignity and respect, and provide a working environment that is free discrimination and harassment. The Supplier shall ensure compliance with all applicable labour laws and regulations, including, without limitation, those in respect of minimum age, minimum wage and benefits, working hours and provident/retirement fund contributions.

(h)    Environment

The Supplier shall comply comply with all applicable environmental laws and regulations. The Supplier is also encouraged to operate in an environmentally responsible and efficient manner.

(i)     Safety and Health

The Supplier shall provide its employees with a safe and healthy working environment in compliance with all applicable occupational safety and health laws and regulations. This includes, without limitation, providing, the employees with adequate personal protective gears and equipment and trainings on its use, as well as having appropriate controls and safe work procedures in place. Consistent with such obligation, the Supplier shall also conduct safety trainings and implement effective programs to educate and raise awareness amongst the employees of the fundamentals of health and safety in a workplace.

(j)     Disclosure of Information

The Supplier shall be honest and transparent in the disclosure of all information to the company. It is the responsibility of the Supplier to notify KH in writing in the event of any change or update in information provided to KHSB. Falsification of documents or concealment or misrepresentation of fact is unacceptable to the company.

(k)    Confidentiality and Intellectual Property

The Supplier shall respect the principles of confidentiality and third part’s intellectual property rights, and shall ensure that there are no infringements on its part.

(l)     Anti-Money Laundering

The Supplier shall comply with all applicable anti-money laundering, anti-terrorism financing and proceeds of unlawful of unlawful activities laws and regulations. Amongst others, we expect our Suppliers to refrain from engaging or attempting to engage in any transaction involving proceeds derived from unlawful activities and not have dealings with individuals or entities who are subject to international economic sanctions.

(m)   Monitoring and Review

The Supplier shall have in place policies and procedures to ensure its compliance with the provisions of this Code. The Supplier shall also monitor and ensure that its supply chain is made aware of, understands and complies with the standards and expectations of this Code. The Supplier shall participate in compliance verification activities of this Code and/or audits that may be carried out by KHSB from time to time.

What happens in the event of a breach of this Code?

In the event a Supplier breaches any provision of this Code, KHSB shall be entitled to terminate any business transactions with the Supplier, and the Supplier shall indemnify and hold harmless the company and each of their respective officers, directors, employees, attorneys and agents (“Indemnified Parties”), from and against any and all claims, causes of actions, liabilities, losses, damages, judgments, suits, settlements or the like entered into by any of the Indemnified Parties (whether or not liability is admitted by such Indemnified Party), royalties, license fees, and all cost and expenses of any kind arising out of or resulting from or in connection with such breach.

Who to contact in event of any concerns?

Should you have any concerns about improper or illegal conducts, please contact:

Managing Director / Executive Director
20-22, Jalan Panglima,
30000 Ipoh, Perak, Malaysia
E-mail: whistleblowing@kuanho.com.my

WHISTLEBLOWING POLICY

We, at KUAN & HO SDN BHD, shall be committed to good business ethics and integrity. All parties either internal or external are encouraged to raise genuine concerns on improper or wrongful conduct at the earliest opportunity, and in an appropriate way.

Who & What types of concerns should you raise?
Internal or external parties should raise any concern on any improper conduct or wrongful act involving KUAN & HO SDN BHD that is committed, including but not limited to:

• Any criminal offences, including bribery, fraud and blackmail
• Any failure to comply with legal or regulatory obligations
• Any improper conduct which would be a disciplinary offence
• Any gross mismanagement of company affairs
• Any act or omission which jeopardizes the health and safety of any parties

Who should you raise your concerns with?
Any parties may make reports of any such concerns to the Managing Director/Executive Director, details as follows: –

E-mail: whistleblowing@kuanho.com.my

Please include your full name and contact details, as well as full details of your concern and any supporting documentation you consider relevant. Should you wish to do so, you may use our Whistleblowing Reporting Form to provide the details required.

Kuan & Ho Sdn Bhd reserves the right not to investigate any concern which is raised anonymously.

What action can be taken against you?
To the extent permitted by law, you will be protected from adverse employment action and where feasible, from disclosure of you identity, provided your report is made in good faith, even if you are genuinely mistaken in the concerns you raise.

Your report should not be made with malicious intent. Malicious reports or complaints lose the protection afforded under this Policy, and appropriate action may be taken against you.

WHISTLEBLOWER REPORTING FORM

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