1. Introduction
Sg. Rambai Holdings Sdn Bhd and its group of Companies (the “Group”) is committed to conducting its business in a fair, professional, ethical, and lawful manner with the highest standard of integrity. Accordingly, we expect our business partners to share the same commitment.
This Code of Business Conduct and Ethics for Third Party (“Code”) serves to set out the minimum standards of business which the Group expects its Third Parties to conform to in their course of conducting business with the Group.
This Code may be amended by the Group from time to time, and all such amendments shall be binding on the Third Party with effect from the date the amended Code is uploaded on our website at www.srholdings.com.my.
2. Scope and Application
This Code shall apply to all vendors, suppliers, service providers, contractors, sub-contractors, consultants, agents, representatives, and any other persons or entities who provide goods or services to any company within the Group, whether directly or indirectly.
The Group expects its Third Parties to communicate the standards and expectations contained herein effectively throughout their organization as well as their supply chain to ensure that this Code is at all times upheld throughout the entire supply chain.
3. Compliance with Applicable Laws and Regulations
The Third Parties shall comply with all applicable laws and regulations in every country in which they operate and where their goods and/or services are provided/supplied. This includes, without limitation, ensuring that:
3.1 They have obtained and maintain all necessary licenses, approvals, permits, and permissions; and
3.2 They have control measures in place to prohibit, detect, and rectify any non-compliance or breach.
Where there is a discrepancy between the requirements of this Code and any prevailing laws or regulations, the Third Party shall comply with the provision which imposes a higher or more onerous standard and/or obligation on the Third Party.
4. Anti-Bribery and Corruption Practices
In line with the Group’s commitment to conducting its business professionally, ethically, and with integrity, the Group practices a zero-tolerance approach against all forms of bribery and corruption and upholds all applicable laws in relation to anti-bribery and corruption.
The offering or acceptance of any form of bribe or corruption, such as facilitation payment, kickbacks, rewards, gifts, blackmail, gratification, or behavior involving improper advantages, benefits, or incentives, is strictly prohibited.
The Third Parties shall conduct business ethically in compliance with:
a. The Malaysian Anti-Corruption Commission Act 2009 and all applicable anti-bribery and corruption laws; and
b. The Group’s Anti-Bribery and Corruption Policy, an electronic copy of which is available at www.srholdings.com.my.
5. Gifts and Entertainment
The Group adopts a “No Gift” policy whereby, except in limited exempted circumstances, employees of the Group are prohibited from receiving or providing gifts, whether directly or indirectly.
Accordingly, the Third Parties shall refrain from offering or giving gifts and entertainment in any form with the intention of influencing business decisions or encouraging the recipient to act inconsistently with his/her duties and obligations, whether for the benefit of the Third Parties or otherwise.
6. Company Information
Company information is confidential, regardless of its form and method of communication, as well as whether such information is marked as “Confidential.”
Third Parties must keep all company information secure and only provide limited access to the Group’s information to their personnel where necessary to execute their job functions in the course of business with the Group.
The Third Parties must only use company information strictly for business purposes involving the company and in the best interest of the Group. Third Parties must not use the company information for any unauthorized purpose or reason.
7. Conflict of Interest
The Third Parties shall not engage directly or indirectly in any personal or business activity that conflicts with the interest of the Group.
All business decisions and actions undertaken by Third Parties must be made with the Group’s best interest in mind and must not be motivated by any personal considerations or relationships.
All Third Parties must declare in writing to the Group any conflict of interest or potential conflict of interest before making any such decision and/or action, or as soon as they become aware of any actual or potential conflict of interest.
8. Labour and Human Rights
All forms of forced, abusive, and illegal labor are prohibited.
The Third Parties shall treat their employees (whether contractual or permanent) with fairness, dignity, and respect, and provide a working environment that is free from discrimination and harassment, regardless of race, ethnicity, nationality, gender, and age, amongst others.
The Third Parties shall ensure compliance with all applicable labor laws and regulations, including, without limitation, those in respect of minimum age, health and safety standards, minimum wage and benefits, working hours, freedom of association, collective bargaining, and provident/retirement fund contributions.
9. Health, Safety, and Environment (HSE)
The Third Parties shall provide their employees with a safe and healthy working environment in compliance with all applicable occupational safety and health laws and regulations.
They shall also conduct safety trainings and implement effective programs to educate and raise awareness amongst employees regarding workplace health and safety fundamentals.
The Third Parties shall comply with all applicable environmental laws and regulations and are encouraged to operate in an environmentally responsible and efficient manner.
This includes, without limitation, the responsible and efficient use of energy, water, and materials/resources, along with sustainable waste disposal methods, with the objective of reducing environmental issues such as waste generation, pollution, climate change, and biodiversity impacts.
10. Whistleblowing
The Third Parties must immediately report or raise concerns regarding actual or suspected unethical, unlawful, illegal, wrongful, or other improper conduct to the Group through its whistleblowing channel, available at www.srholdings.com.my.
11. Non-Compliance of this Code
In the event a Third Party breaches any provision of this Code, the Group shall be entitled to terminate any business transactions with the Third Party.
The Third Parties are subject to loss of access privileges, unsatisfactory performance evaluation, sanctions, accountability in a court of law, civil and criminal prosecution.
In the event of termination, the Third Parties shall not be entitled to any further payment or services, whichever applicable, regardless of any activities undertaken or agreements entered into prior to termination. They shall be liable for damages and/or remedies as available in law.