Staff Only

The Code of Ethics (“Code”) provide a practical set of guiding principles to help us make decisions in our day to day work, whatever we do and whenever a person do it. The Code is supported by a number of policies applicable to MTrustee Berhad (‘the Company”).

1. RELATED POLICIES
   The Code has been adopted by the Board of Directors (“BOD”) who takes a leadership role in shaping and driving governance of the Company policies and practices and in ensuring the Company compliance with these policies and practices through the key components of Compliance & Risk Committee, Audit Committee (referred as “BOD Committee” respectively) and the Management. The Company’s directors are also subject to the Code for Directors of MTrustee Berhad. The Code applies to every director, management and staff of the Company. In addition, other person performing services for the Company may be subject to this Code by contract or other agreement.To the extent that exemptions are available from the Company policies, there are detailed in the specific policy, together with exemption process. Any waiver of this Code for executive officers or directors may be made only by a documented decision of the BOD and must be disclosed promptly.
2. WHEN IN DOUBT
   While the Code provides general guidance and minimum expectations regarding our conduct, no Code or policy can ever cover every conceivable circumstance a person may face. In everything a person do, a person are expected to listen to and act upon our conscience to help build and maintain the Company and our own reputation. If something seems unethical or improper to an individual, it may very well be. If a person are in doubt about whether our conduct is consistent with this Code it may help to ask ourselves the following questions:-
   • Does an employee obtain personal benefit or gain resulting from their behavior or action?
   • Does it feel like the right thing to do?
   • What would the Company’s clients or shareholder expect or want the employee to do in this situation?
   • What would the reaction be if this was reported in the newspapers?
   • Would others colleagues or manager consider his/her behavior appropriate?
   • What impact might this have on the Company and its commitment to shareholder value?

   If the employee need more information or unsure of the Company expectations or their obligations, or if he/she employee reasonably suspect or become aware of a possible violation of a law, regulation, the Company policy or ethical standard, the employee should promptly contact any of the following:-

   • Chief Executive Officer;
   • Risk or Compliance Officer or representative;
   • Chairman of the Audit/Risk/ Compliance Committee;
   • Board of Directors, through the Company Secretary.

   The employees are each responsible and accountable for their own conduct or action.

   The employee should keep in mind that it may be difficult for the Company to thoroughly investigate reports that are made anonymously. Because of this, the individual is advised to consider sharing his or her identity when making a report. The individual’s identity will be kept confidential to the extent possible under applicable laws. If the individual report an activity that he or she believe to be a violation of a law, rule, regulation, internal policy or this Code, Company will protect him or her from retaliation. If the individual believes he or she has experienced retaliation under the Company’s Whistleblowing Policy, he or she should report it immediately.

This Code applies to all employees of this Company. The following principles are the outlined in this document, of which elaborated further in the next paragraph:-

1. Compliant
2. Responsible
3. Ethical
4. Accurate
5. Trustworthy
6. Equitable

1. Comply With the Law Both in Letter and in Spirit, this Code and the Company Policies and Procedures
   All employees is subject to the laws and regulations of Malaysia. The employee must be familiar and comply with all the relevant laws and regulation in the location in which he/she works. Any breaches on the laws can have serious consequences beyond their employment, both for the Company and for the employee as individuals. The employee should be aware that breaches of the law in their personal capacity may be considered by the Company to be inconsistent with continuing their employment or engagement with the Company.Although the laws that apply may be complex, ignorance is no excuse. All employees is ultimately responsible for understanding which laws and regulations apply to them and the work they does. The Company is committed to help the employee by designing systems and processes that comply with the law, and by providing relevant policies and training.This Code and the Company policies, procedures, and practices take into account not only the strict letter of the law but also the Company way of doing things. In many cases, whenever there is inconsistency between the applicable law and the Code, the Company policy, procedure or practice, the employee must comply with whichever is higher standard.
2. Do the Right Thing
   • Complete all required training and education programmes to build and maintain their awareness and understanding of relevant laws, policies, procedures, and practices.
   • If the employee is unsure whether a particular law, policy, procedure or practice applies, seek guidance from their supervisor, line manager, human resource representative or operational risk or compliance representative. Honestly, report all actual or suspected breaches of this Code, the law or Company policies, and procedures immediately to their line manager, human resource representative or the operational risk or compliance representative.
   • If an employee is charged or convicted of a criminal offence, or subject to a sanction that impact their ability to perform their role, notify their line manager immediately.
   • Remember that at any time the employee is able to report or escalate conduct under the Company Whistleblowing Policy where the conduct is dishonest, corrupt, fraudulent, illegal, unethical or any other type of reportable conduct. There may be times where the conduct is inappropriate to raise a concern within their business unit, in which case the employee may contact officer appointed by the BOD and the matter may be escalated accordingly as provided in the Whistleblowing Policy. Escalation reports to Officer appointed by the BOD are confidential and protected by the Whistleblowing Policy.

1. Identify and Manage Conflict of Interest Responsibly
   Acting honestly and with integrity also means managing conflict of interest and never putting themselves in a situation that puts, or appears to put, their employee own personal interest before those of the Company or the clients.The perception of a conflict of interest can do as much damage to the Company reputation as an actual conflict of interest. The employee must be mindful of when a conflict may be perceived by others, and take action to avoid or address this risk.There are certain situations that have a higher risk of an improper payment, benefits or gain made or received. These includes rewards from current or potential clients or vendors that are out of the ordinary such as cash, cheques, gift, gift certificates or travel of a high value.Where rewards from a current or potential clients or vendors create any obligation or expectation that an employee will give preferential treatment to that person or the Company offering the reward, the reward is improper and must be refund.
2. Do the Right Thing
   • Be alert to actual and potential conflicts of interest and disclose them to the management.
   • Never trade in securities if the employee has information that may affect the price of the security and this information is not publicly known or generally available.
   • Seek approval for any outside business interest including business ventures, directorships, partnerships or a direct or indirect financial interest which has the potential to conflict with their employment, the interests of the Company, shareholders, clients or vendors.
   • Keep an arm’s length relationship when dealing with clients or vendors and obtain written approval of the Company to do business, hold accounts, transact with or hold a direct or indirect financial interest in the Company or vendors that the employee deal with during their work with the Company.
   • Never provide or maintain products or services for, or complete or approve transactions on behalf of, immediate family members or relatives in the course of their work
   • Disclose to the management any personal associations with a third party which the employee is involved in evaluating or negotiating with the Company whether for employment, as a clients or any other reason.
   • Never accept any gift, reward or entertainment, including discounted products, free travel or accommodation, if it could create any obligation or expectation that could conflict with their work at the Company.
   • Never offer, promise, or give a payment or anything else of value that is intended to improperly influence or even appears to improperly influence – a government official or their official actions, or any other person, or to gain an unfair business advantage. Anything of value includes any advantage, financial, or otherwise, and extends beyond cash to include gifts, entertainment, services, amenities, offer of employment, etc. There is no minimum amount or threshold of value that must be exceeded before a payment of gift may be considered illegal.
   • Never make any donation or other financial contribution from the Company to a political party or candidate unless it has been approved by the BOD.
   • Only entertain clients and business associates with lunches, dinners or other events (such as football, or the theater) if the nature and value of the entertainment is reasonable in in light of the nature and value of the business relationship the Company and the seniority of the parties attending.
   • Obtain proper approval for and properly record any donations, sponsorships, charitable contributions, gift and entertainment their accept from or give to, a third party on behalf of the Company.

1. Uphold the Highest Level of Integrity and Act with Honesty and Professionalism
   The Company success depends on the trust of it clients, which is earned by acting with honesty and integrity and by considering the Company, the shareholders, colleagues, and the general community when making decision.Honesty and integrity can be just as important in the things an employee fail to do. For example, failing to report the suspicious or dishonest conduct of a colleague reflect on their own honesty and integrity as well.
2. Do the Right Thing
   • Immediately report any suspicious of fraud, tax evasion, theft or other dishonest behavior by others (including colleague or clients).
   • Never improperly use the employee position with the Company or any information he/she receives through their work at the Company, to further their own personal interests, or help others to do so.
   • Never help the clients or anyone else to break or evade the law.
   • Consider the interests and needs of the clients when providing advice, products, or services to them.
   • Be honest and forthright in all our communications and dealings with the Company, including with their line manager, colleagues, clients, auditors or regulators. This includes communications and dealings as a clients, as well as someone who works with the Company.
   • Ensure all dealings (such as transactions or commitments) with third party are properly recorded and transparent.
   • Use the Company assets and funds for proper purposes and keep accurate and transparent records of all payments or receipts for transactions using the Company funds.
   • Never structure or amend any transaction to disguise, conceal or misrepresent the involvement of any party or the true nature of the transaction (for example, to conceal money laundering or the involvement of sanctioned countries, entities or individuals).
   • Use of all of equipment, systems, and services appropriately and for proper authorized purposes. This includes emails, messaging, internet access, and technology and other electronic communication tools, devices, data links, and data services for on-site, mobile and remote use which are provided for business purposes and to enable the employee to perform tasks related to their job.
   • Never entertain clients or participate in the Company activities or functions in a way that may damage the Company reputation, for example by consuming excessive alcohol or attending places of ill-repute.
   • Their employee use of social media relating to the Company should be strictly social. The employee must be careful never to disclose any proprietary or confidential information. He/she should not use social media sites or other online vehicles to solicit business, promote brand, product and service offering or to engage in discussion about financial matter related to the Company business unless part of Company-approved program. And of course, the employee should never post anything that is obscene, threatening, misleading, hateful, or harmful, or disparaging.
   • The employee may not consent to or engage in any public relations activity relating to Company with clients, vendors, distributors, or others without prior approval from the BOD.
   • The employee must not use the Company name, logo, or facilities for commercial purposes unrelated to their job, including outside work (including on letterhead or websites). Use of Company name, facilities, relationship, for charitable or pro bono purposes can be made only after any other notification and approvals are provided, if required by the policies of their business or legal entity.

1. Ensure Completeness and Accuracy of Underlying Records, Financial or otherwise
   All the Company records and documents must be complete, accurate, in reasonable detail and kept under strictest confidence, regardless of form or medium, which are created, received or maintained on behalf of the Company by its officer and the employee in the course of carrying their day to day business activities in compliance with applicable laws and accounting standards. The requirements also mandatory to all outsourcing service provider appointed by the Company.
2. Financial and tax records
   Falsifications of accounting and tax records and willful omissions, concealment, and alteration of transactions in the accounting and tax are unlawful. The accounting and tax records should be certain that all transaction with other persons (including related and associated companies) are properly documented and recorded to avoid any possible allegation that the Company was assisting such parties in improperly recording or detailing the nature of the transactions involved.
3. Record Management Policy
   Original physical records must be retained in good condition as per Record Management Policy. Records identified for permanent preservation are also known as achieved records. These achieved records can be in hard copy or soft copy form. All employees should be aware and adhere the Record Management Policy.
4. Expense Management
   The Company employees at every level are responsible for expense management. They are responsible for reviewing expenses to ensure they adhere to the Company’s policies, make appropriate business sense, are approved by the proper authority and are processed through approved payment services processes. An employee cannot approve their own expenses.

1. Ensure confidentiality of information and transactions
   In an employee work at the Company, he/she may come across private and confidential information relating to the Company, colleagues, clients, vendors, or other third parties. When people provide them with this type of information, they are trusting the Company. Misuse of confidential and private information can have severe commercial and reputational consequences for the Company and can also greatly affect those whose information is misused. If people feel they can’t trust us with their information they are unlikely to trust us with their finances or business.The Company is committed to maintaining the confidentiality and security of this information and an employee is expected to do their part to help honor this commitment.
2. Do the Right Thing
   • Do all he/she can to keep the information secure. This includes not sharing private or confidential information with other employees unless they need it to perform their work at the Company.
   • Never release information about clients or colleagues to third party outside of the Company unless the person the information relates has agreed or if the Company is required to release the information to family members, friends or others about an account to which they are not a signatory.
   • Follow procedures and requirements to protect information whenever he/she provides details over the phone, by email by fax or other electronic media.
   • Follow all protocols and procedures relating to the maintenance of passwords and user profile set up. Never allow someone else to log on using our individual details.
   • Collect, use, store, handle, update, and destroy information, particularly personal information, in line with applicable policies and processes at all, times.
   • Never disclose any information about the Company or any other Company or individual (including a former employer) that is not already in the public domain without proper authority to do so.
   • Company meetings are confidential. All employees are not allowed to record meetings using audio, video, or other electronic equipment unless there is a specific business purpose for doing so. In such cases, he/she must receive prior approval from a senior officer in their department.

1. Must ensure fair and equitable treatment to all
   The Company values diversify and is committed to achieving a truly diverse workforce that remains inclusive and respectful of each other’s differences.All employees are all expected to treat all people they deal through their work at the Company with dignity and respect, whether they are colleagues, clients, vendors or other third parties.
   Unlawful discrimination, harassment of any kind, bullying or victimization or other unacceptable or offensive conduct will not be tolerated.The Company believes the safety, security and physical and mental health of the employee lie at the heart of each person’s ability to contribute to our success. The Company respect the right of all individuals to work in a safe working environment that promotes well-being.
2. Do the Right Thing
   • Treat all people with through the employee work at the Company with dignity and respect.
   • Make employment decisions based on merit, and not on attributes that are irrelevant to employment or performance.
   • Never unlawfully discriminate, harass or bully our colleague, clients, visitors or anyone else in the workplace. This includes being aware that some behavior may be acceptable to that particular employee but not to others, and acting appropriately.
   • Maintain business continuity plans to minimize financial losses and respond to market and client’s needs when blackout, fire or other disaster, crisis, disruption, or emergency occurs.
   • Contribute to promoting a safe working environment by taking responsibility for health and safety and reporting any issues as soon as possible.
   • Never treat somebody less favorably because they have brought or propose to bring a genuine compliant of unacceptable behavior.
   • Misusing control substances or selling, manufacturing, distributing, possessing, using, or being under the influence of illegal drugs or other substance abuse which renders the employee unfit for duty is prohibited in the workplace or while performing work related duties.

Any breach of principles, policies or spirit of the Code will be investigated in accordance with disciplinary action and will result in consequence management. This may range from a verbal warning through the termination of employment for serious breaches.

All employees are required to cooperate fully with any appropriately authorized internal or external investigation, including but not limited to those involving ethical issue or complaint of discrimination or harassment and any act of bribery and corruption etc. The employee should never withhold, temper with or fail to communicate relevant information in connection with an investigation. In addition the employee is expected to maintain and safeguard confidentiality of an investigation to the extent possible. Making false statements to or otherwise misleading internal or external auditors, investigators, legal counsel, the Company representatives, regulators, or other relationship with the Company and also be criminal act that can result in severe penalties.