1. The aim of this Policy is to ensure that all Directors and employees of the Group act in the best interest of the Group in the course of conduct of their affairs, striving at all times to enhance the reputation and performance of the Group.
2. The rights of fellow Board members, employees and all stakeholders must be respected and each person must be accorded equal opportunity without regard to their race, colour, creed, religion, national origin, age, sex, marital status, lawful alien status, mental or physical disability, sexual orientation or gender identity.
3. Misconduct cannot be excused and all parties are expected to alert the Management of the Group (“Management”) whenever an illegal, dishonest or unethical act is discovered or suspected.
4. The Group conducts its affairs consistent with all applicable laws and regulations where it carries on its businesses. Business practices, customs and traditions may differ from state to state, country to country, community to community and entity to entity. Where conflicts arise between the Group’s practices and the practices, customs, laws or traditions in any particular matter and if the conflict cannot be resolved, the Group will not proceed with the proposed action giving rise to that conflict. 

1. Respect for the Law.
2. Conflicts of Interest.
3. Corporate opportunities.
4. Insider Trading.
5. Confidential Information.
6. Protection and preservation of Company Assets and Financial Records.
7. Discrimination and harassment.
8. Reporting Violations.

2.a        Respect for The Law

Powertechnic, its Directors and all employees are bound by all applicable laws, rules and regulations. Compliance with all applicable laws and regulations must be observed and all employees must adhere to all internal company policies, rules and regulations specific to the Group which may go beyond what is requested by law.

This Policy should be read in conjunction with and complied with the following policies:

1. Board’s Policy on Conflict of Interest (“COI Policy”); and
2. Board’s Policy on Anti-Bribery and Anti-Corruption (“ABAC Policy”).

2.b        Conflict of Interest

The Board has adopted a COI Policy which provides guidance on how to deal with conflict of interest situations and the COI Policy can be viewed at the Company’s website at www.powertechnicgroup.com.my.

2.c        Corporate Opportunities

All employees shall whenever possible, avoid competing with the Group or take personal advantage of business opportunities that arise or may be discovered during the course of their employment unless Powertechnic expressly waives its interest in pursuing such an opportunity.

Where any employees desire to pursue business opportunities that the Group is interested or engaged in, they shall inform their head of department or the head of human resources department who will then seek clearance from the Management or Board where applicable.

In respect of Senior Management employees and taking into consideration the processes as set out in the Board’s COI Policy, the issue should be brought to the attention of the Group Managing Director or in his absence any one Executive Director and in respect of the Board members, it should be brought to the attention of the Audit and Risk Management Committee (“ARMC”) for review before being brought to the Board.

2.d        Insider Trading

As a general policy, all employees of the Group are disallowed from engaging in speculative trading (as opposed to investing) in the Company’s listed securities and are reminded to observe the prohibitions imposed on “insiders” in relation to insider trading under the Capital Markets and Services Act 2007.

In addition to this, all Directors and key senior management, identified and designated pursuant to the Board’s Corporate Disclosure Policy (“Designated Key Senior Management”) are required to comply with Bursa Malaysia Securities Berhad’s ACE Market Listing Requirements on Dealings in Listed Securities under Chapter 14.

Directors which possess insider information including market sensitive information which has not been made known to the investing public shall not deal/trade in securities or communicate such information to any unauthorized corporations, persons, for the benefit of themselves or any other corporations or persons.

2.e        Confidential Information

Confidential Information comprises of any information that is not or has not been released to the public and includes business and trade secrets, business, marketing and service strategies and plans, research information, reports and data, business ideas, products, designs, databases, records, human resource information, and any non-published financial and non-financial data as well as the price, value or market activity of the Company’s listed securities or other data deemed by Powertechnic to be confidential and secret.

Unless required by law or authorised by Management, all employees shall not disclose, divulge or reveal any confidential information, allow or facilitate the disclosure of such confidential information.

All employees are required to use their best effort and endeavour to avoid unintentional disclosure of confidential information including taking precautions and care when storing or transmitting confidential information.

Directors and employees of the Group are obligated to preserve the confidential information even after an individual ceases to be a Director/employee (as the case may be), until the information becomes publicly available or the Group no longer considers it as confidential. Directors and employees must not misuse the confidential information of a third party.

2.f         Protection and preservation of Company Assets and Financial Records.

All employees shall safeguard and make proper and efficient use of the Group’s assets and financial records.

All employees shall use their best efforts and endeavour to protect the Group’s assets and financial records from loss, damage, misuse, theft, fraud, embezzlement and destruction. These obligations cover both tangible and intangible assets including trademark, know- how, confidential or proprietary information, information systems, Group’s physical premises, equipment and facilities.

Powertechnic reserves the right to monitor and inspect how its assets and financial records are being used by its employees including inspection of all correspondence, e-mails, chat messages, data and files kept on the Company’s network terminals.

2.g        Discrimination & Harassment

Powertechnic respects the privacy, dignity and personal rights of all employees and is committed to ensuring a workplace environment which is free from any discrimination and harassment of whatsoever nature.

The rights of fellow Board members, employees and all stakeholders must be respected and each person must be accorded equal opportunity without regard to their race, colour, creed, religion, national origin, age, sex, marital status, lawful alien status, mental or physical disability, sexual orientation or gender identity.

Employees who feel that they have been discriminated against are encouraged to raise their concerns to the head of department or to head of human resources department or the persons designated under Section 2.h.

2.h        Reporting Violations

The maintenance of a strong and highly ethical environment with business conduct carried out with utmost integrity must be reinforced by an efficient reporting structure.

If you are aware of or suspect misconduct or violations of any nature outlined in this Policy, you must report it to the appropriate levels of Management.

You are to report in priority firstly to your head of department, or failing him the head of human resources department.

If, after speaking with the appropriate levels of Management or you feel uncomfortable speaking to them, you may (if you wish) elevate your concerns to any of the executive directors, or failing them to the independent chairman of the board.

Any reports that involve the executive directors, non-executive directors or group accountant must be communicated to the chairman of the ARMC who will then, where appropriate, table to ARMC before escalating the matter to the Board.

Your report/calls/emails will be dealt with the strictest confidentiality and will only be disclosed and shared in order to address the matters appropriately. Regardless, the Board wishes to assure you that the Board will shield and protect you from any retaliation by any other employees of the Group.

This Policy should be read in conjunction with the Board’s ABAC Policy which can be viewed at the Company’s website at www.powertechnicgroup.com.my.

1. This Policy applies to all employees of the Group (including all Directors).
2. Any reports made will be thoroughly investigated and if such violation is proven, appropriate disciplinary actions will be taken by the Management with the sanction of the executive director or the Board depending on the nature and level of the breach including dismissal and termination.