CODE OF ETHICS FOR EMPLOYEES OF KPS CONSORTIUM BERHAD

Objective
The objective of the Group’s Code of Conduct and Ethics are to set the tone and standards for ethical conducts in the Group; to provide guidance to stakeholders on the ethical behaviors to be expected from the Directors, Management and employees of the Group; and to act as the reference point for Management in making their day to-day decisions with respect to conflict of interest, abuse of power, corruption, insider trading and money laundering.

All individuals in the Group are required to be familiar with this Code, adhere to its provisions, and report any suspected violations provided in this Code. No individuals of the Group shall provide advice or assistance to other stakeholders to attempt to violate provisions of this Code.

It shall be noted that non-compliance of this Code may not only entails disciplinary sanctions, but also criminal charges. 
When in doubt regarding the application and provision of this Code, all individuals shall consult senior management of the Group.

Conflicts Of Interest

Conflict of interest is a situation in which an individual or organization is involved in multiple interests and were serving one of the interests could involve working against the other’s interests.

Where an actual or potential conflict of interest arises, or may arise, the affected individual shall immediately disclose his/her interest to immediate superior the nature and extent of such conflict of interest. Thereafter, the individual shall not take part in deciding with respect of any transaction, contract or proposed contract or arrangement in which he/she is interested, directly or indirectly.

When an individual has concealed or has unreasonably failed to disclose a conflict of interest, the Board or Management may other than disciplinary action, recover the losses from the individual.

Abuse Of Power

The Company does not tolerate abuse of power. Abuse of power is illegal or coercive use of power by imposing the will of a superior over a subordinate, through the exercising of the power conferred by the position of the superior for gaining benefits or particular objective that is usually in violation of laws, rules and regulations.
Corruption All individuals of the Group should never solicit gifts or favors in connection with their official duties. Gifts that are offered should not be accepted if this would create or give rise to the appearance of impropriety or bias that would damage the reputation of the Group.

No individuals shall use improper means or provide gift, brides and benefits to influence other stakeholders in order to obtain and retain business or secure an unfair advantage in any business transaction.

Insider Trading

By nature of our work, directors or senior management staff may have access to information that is price sensitive. Accordingly, no directors, officers and staff shall enter into any transaction in the securities while they are in possession of non-public information about the Company or recommend others to purchase the securities of the Company on the basis of insider information.

When price sensitive information is withheld, the Board and Management must closely monitor the market activities of the securities of the Company. However, the Board and Management shall immediately announce the price sensitive information withheld to Bursa Securities when:-

(a) Unusual market activity in the Company’s which signifies that a ‘leak’ of the information may have occurred. (b) Rumours or reports concerning the information have appeared. (c) Where the Board and Management learn that there are signs that insider trading may be taking place.

Money Laundering

Money laundering is the process of hiding the true nature or source of illegally obtained funds and passing it surreptitiously through legitimate business channels by means of bank deposits, investments, or transfers from one place or person to another.

Money laundering activities may include, but not limited to the following:-
• Attempts to make payment in large and unusual amount of cash.
• Payments made by or to third parties who are not parties to the contract.
• Payments made in currencies differ from invoices.

Board’s Responsibilities

The Board shall define the Code of Conduct and Ethics of the Group and ensure the objectives of the Code are met by:-

1. Committing and ensuring the implementation of appropriate internal systems to support, promote and strengthen the awareness and compliance with this Code.
2. Ensuring implementation of appropriate communication channel to receive feedbacks.
3. Integrating this Code into management decision, practices and procedures; and
4. Reviewing the Code periodically.

Management’s Responsibilities

In making operational and business decisions, Management is responsible to the Board for observing the principles of this Code. Management must ensure that their action is consistent with the spirit of this Code and promote good ethical standard through their internal and external interaction with all stakeholders of the Group.

Whistleblowing

Any individuals who know of or suspect a violation of this Code is encouraged to report the incidence to kps@whistleblower.com.my or the Chairman of the Audit Committee at hew@hnp.com.my.

The identity and personal information of the whistleblower will be protected and kept confidential unless the whistleblower agrees otherwise or unless otherwise required by law. When a whistleblower makes a disclosure in good faith, he/she will be protected under the Whistleblower Protection Act 2010. Internally, the Board will also ensure that the whistleblower is protected from reprisal, including any form of harassment and victimisation, as a consequence of his/her disclosure.

Publication Of Corporate Code Of Conducts And Ethics

This Corporate Code of Conducts and Ethics shall be published on the Company’s website.