In respect of Group Anti-Bribery Framework

FOR DISTRIBUTORS

SAHAJIDAH HAI-O MARKETING SDN BHD (“The Company” / “SHOM”) is committed to conducting its businesses in a lawful and ethical manner and to driving and upholding the Group’s corporate values. SHOM expects the same level of integrity, honesty, openness, and transparency being upheld by the Directors, Employees, Suppliers, Distributors and Business Associates also when dealing business with SHOM.

This Code of Ethics sets out the standards of ethical business practices and conduct that SHOM expects from Distributors (a registered member either individual or an entity). This Code makes reference to Hai-O Group’s Anti-Bribery Policy and collectively promote good and sustainable business practices.

1. Anti-Bribery and Anti-Corruption

The Company has adopted a zero-tolerance approach to bribery and will not pay any bribes to anyone for any purpose. All distributors are prohibited from soliciting, accepting, offering, or giving any form of bribes in the conduct of the Company’s businesses. All distributors shall refer to, understand, and comply with the Group’s Anti-Bribery Policy.

When faced with any attempted bribery or bribery conduct, a distributor who is offered a bribe or being solicited for a bribe must refuse the offer or solicitation and report to SHOM Compliance Unit at coe@shom.com.my

Any distributor who is involved in a bribery conduct, whether as a giving or receiving party, will be dealt with seriously by the Company, including termination of distributorship and reporting to the relevant authorities.

All distributors undertake to:

a)  not involve in fraud, bribery, corruption, extortion or any other illegal conduct in carrying out business with SHOM or on its behalf;

            b) not involve in any form of money laundering or terrorism financing activities;

c) comply with all applicable laws and regulations applicable in the distributors’ base countries and as well as in any countries in which provision of products or services are made;

d) practice fair competition in accordance with applicable laws and to avoid activities restricting competition;

e) abide by any other applicable laws and regulations which may be applicable from time to time.

2. Business Dealings

All distributors undertake to:

a) conduct business, either with SHOM or on its behalf, with integrity, honestly, fairly, openly, and transparently. Information provided in the conduct of business shall be accurate and not misleading;

b) be fully accountable for the delivery of their contractual obligations (based on formal contracts, letter of appointment, or other documentations);

c) protect confidentiality of information from sensitive information to personal data related to business dealings and not utilize this information for own personal advantage, directly or indirectly.

3. Conflict of Interest

All distributors undertake to:

a) avoid situations of any actual, potential, or perceived conflict of interest. Conflict of interest situations arise when the ability to serve its contractual obligation with SHOM may be compromised by other external or personal interest or factors;

b) declare any possible conflict of interest situations to related SHOM as soon as possible for SHOM to assess the situation and undertake any necessary mitigative actions.

4. Health & Safety and Environment

All distributors shall take reasonable measures to:

a) ensure the health and safety of all its stakeholders and creating and maintaining a conducive and productive working environment;

b) minimize the impact of business operation through strengthened efforts towards protecting the environment.

5. Audit

Subject to the provisions of the business arrangement with the Company, SHOM reserves a right to audit, at its own cost and expense, its distributors in relation to adherence to this Code. Distributors shall co-operate and provide the Company’s auditors with the information and documents required, especially if the audit is one that is required in relation to compliance with laws and regulations.

6. Reporting of violations of this Code

All distributors undertake to report the concerns on any suspects of a violation of the Code through the whistleblowing mechanism set out under SHOM’s Whistle Blowing Policy to the SHOM Compliance Unit, via the following email: coe@shom.com.my.

All reports will be treated confidentially.

Issued on 28 May 2020