Code of Conducts and Ethnics

1.0      INTRODUCTION 

Quality Concrete Holdings Berhad and Group of Companies (“QC”) commits to maintain good corporate governance, where all employees are required to maintaining a high standard of code of conduct and ethics (“the Code”). 

All Directors and employees hold responsibility and accountability to comply this Code and keep themselves abreast of the latest update of this Code. Directors and employees (including permanent, contract, probationary, and trainees) are bound to this Code and shall act professionally with integrity in their performance of their duties. 

All Directors and employees in QC shall read and understand the Code. Any breaches to this Code by any Director or employee shall be taken to disciplinary action, including possibility of suspension or dismissal. If a Director requires further clarification on the Code, the Director may refer or highlight any concern to the Chairman of the Board.  Whereas for an employee may refer or highlight any concern to his/her immediate superior, or alternatively, he/she may
choose to call Human Resource Department.  

2.0      OBJECTIVE 

This Code is served as guidelines for Directors and employees when work for QC to commit themselves to ethical standards and conduct at work as QC aims to grow a sustainable business.  The Code is not intended to be exhaustive, and there may be additional obligations that Directors and employees are expected to behave or conduct when performing their duties. All Directors and employees shall always observe the highest standards of ethical conduct and ensure compliance with all applicable laws, rules and regulations to which they are bound to observe in the performance of their duties.  

3.0      CORE AREAS OF CONDUCT 

3.1      Confidential Information 

Directors and employees are prohibited from disclosing any confidential, proprietary and sensitive information of QC to any person, including family, friends or third parties, unless the disclosure is duly authorized or required by law.  

In the event that a Director or an employee knows of material information affecting the Group which has not yet been publicly released, the material information must be held in the strictest confidential by the Director or employee involved until it is publicly released. 

Directors or employees who holding positions that allow access to price sensitive information (“inside information”) are prohibited to trade securities or tip others to trade securities of QC on the basis of material information before it is made publicly available to ordinary investors through appropriate media. 

If Directors or employees are required to disclose Confidential Information by the law, they should inform the Board, if practical in advance. 

Investor Relations/Corporate Communication is the channel to handle all queries from media or third parties about QC business for a consistent and professional approach in handling of such matters. 

Vendors or any third party who may have access to confidential and proprietary information of QC shall sign a non-disclosure agreement so as to protect the interest of QC. 

3.2      Protection of Assets, Properties and Facilities 

Directors and employees are expected to protect the assets, properties and facilities of QC to ensure these are safeguarded to avoid any loss, damage, misuse or theft. 

Communication system, including internet and email system, are the property of QC and such facilities are primarily for business purposes. Directors and employees are prohibited from sending, willfully receiving, displaying, printing or otherwise disseminating material that is fraudulent, harassing, bullying, illegal, embarrassing or sexually explicit. This includes but is not limited to messages containing sexual comments or offensive comments relating to gender, age, race, sexual orientation, religious or political beliefs or other ground of discrimination. 

3.3      Social Media 

Social media is an interactive internet-based application used in sharing and discussion of information among people in digital networks. Social media includes but is not limited to:  

–      Instant messaging (e.g. SMS, Whatsapp, Wechat) 

–     Websites 

–     Social networking sites (e.g. Facebook, Instagram, LinkedIn, Twitter) 

–     Video and photo sharing websites (e.g. YouTube) 

–     Podcasting 

–     Blog, including corporate blogs and personal blogs.  

Directors and employees should be aware of and understand the potential risks and damages to QC’s reputation that may occur, either directly or indirectly, in their personal use of social media and beyond. Directors and employees, except for authorized personnel, are prohibited from commenting or disclose any information relating to QC in the social media, and neither imply that you are authorized to speak as QC’s representative nor give the impression that the views expressed are those of QC’s. 

3.4      Conflict of Interest 

Directors and employees shall carry out their responsibilities to the exclusion of any personal advantage in performing their duties, either directly or indirectly. 

Directors should immediately notify to Chairman of the Board, whereas employees should immediately notify to their immediate superior or Head of Department in writing upon becoming aware of any such real potential or perceived conflict. Where an employee is in any doubt about whether there is a real or potential conflict of interest, clarification should be sought from his/her immediate superior or Head of Department, or the Head of Department will take all reasonable steps to either resolve the conflict or to advise what steps need to be taken to avoid or handle the situation. 

Directors shall take action, as appropriate, to address any conflict of interest, or the appearance of a conflict of interest arises with QC, and inform the Board. 

Employees shall not
engage in any conduct involving a real, potential or perceived conflict without having first received prior written consent from the Managing Director. 

3.5      Business Records and Control 

Employees shall be committed to ensure: 

(i)     all books, records and accounts comply with all applicable accounting and financial reporting 

rules and regulations,and laws and regulations; 

(ii)    preparation and maintenanceof accurate and adequate business records; 

(iii)   all transactions are properly authorized and accurately and completely recorded in the relevant accounts with no false, improper or misleading records made in the books and records under any circumstances; and 

(iv)    all business records are appropriately retained and disposed of according to QC’s  data retention and disposal practices, applicable laws and regulations. 

3.6      Gifts and Entertainment 

QC recognizes that offering or accepting gifts and entertainment during festive or special occasions and from social functions attended by employees on behalf of the Group, if done in an
appropriate way and on an appropriate scale, are permissible.  

Other than the above, no Director or employee should accept personal gifts, favours, entertainment, services or gratuities given, in cash or in kind, by third parties who have business dealings with QC. It is not acceptable to offer, give, solicit, or receive any forms of bribe or kickbacks under any circumstances. 

3.7      Anti-Money Laundering 

Money laundering is the process by which persons or groups try to conceal the proceeds of illegal activities or try to make the sources of their illegal funds look legitimate. 

QC will to the best of its ability and knowledge conduct businesses with reputable customers with legitimate funds and for legitimate business purposes. If any Director or employee suspects any money laundering activities occurs within QC, he/she should report it to the Chairman of the Board or respective immediate superior or Head of Department. 

3.8      Health and Safety 

The well-being and safety of our Directors and employees is our priority of concern. QC strives to continuously improve the health and safety aspects in the operations to provide healthy and safe products and services, as well as a healthy and safe work environment to every Director and employee. All Directors and employees should familiarize themselves and commit to comply with all applicable laws, regulations and standards. 

3.9      Protecting the Environment 

QC strives to maintain the environment for future generations. Directors and employees shall endeavor to demonstrate commitment to embedding sustainability as an integral part of our culture, skills and deliverables, through: 

(i)        reducing the carbon footprint of our operations; 

(ii)       increasing our sustainability knowledge, skills and tools to add value; 

(iii)      incorporating sustainability considerations into our products and services; and 

(iv)      dispose of construction wastes in a properand environment friendly manner. 

3.10    Equal Employment Opportunity 

QC values the employees are the main drivers that build up the sustainable business. QC holds the principle to respect employees and one another, and is committed to ensuring fair and equal
treatment for all employees and that all working in an environment free of discrimination and harassment. QC has zero–tolerance to accept, under any circumstances, any bullying, sexual harassment, discrimination or general harassment in the workplace.  

4.0      RESPONSIBILITY FOR REPORTING BREACHES OF THE CODE 

All employees are expected to report unethical or improper conduct or breaches or suspected breaches of the Code with the applicable reporting procedures. Employees who wish to report breaches of the Code should refer to the Whistle-blower Policy, which is available on QC’s website. 

All reports of unethical conduct or a breach of this Code will be treated in strict confidential, and QC will take appropriate action against anyone who engages in retaliatory action against any person who reported in good faith on breaches or suspected breaches of the Code.  

5.0      REVIEW OF THE CODE 

The Code shall be reviewed periodically or whenever necessary by the Board to ensure that it remains current and relevant.