Code of Ethics & Conduct

1.	INTRODUCTION Melati Ehsan Holdings Berhad (“Melati” or “the Company”) and its group of companies (collectively referred to as “the Group”) are committed to the highest standards of ethical business conduct. In keeping with our commitment and in line with good corporate practices, the Company has adopted this Code of Ethics and Conduct (“the Code”) which sets out the principles and standards of business ethics and conduct of the Group.
2.	OBJECTIVE The objective of the Code is to assist the Directors and employees of the Group in defining ethical standards and conduct at work. The Code is not intended to be exhaustive and all Directors and employees of the Group shall always observe and ensure compliance with all applicable laws, rules and regulations to which they are bound to observe in the performance of their duties.
3.	APPLICABILITY The Code is applicable to all Directors and employees of the Group, including full time, probationary, contract and temporary staff. All Directors and employee of the Group shall read, understand and comply with the Code. Violation of any of the Code’s provisions can result in disciplinary action, termination of employment or legal and criminal charges.
4.	CORE AREAS OF CONDUCT
	4.1	Conflicts of Interest A “conflict of interest” exists when a person’s private interest interferes in any way with the interests of the Company. Conflicts of interest are prohibited as a matter of Company policy. The Directors and employees must be accountable for acting in the Company’s best interest and should avoid involving themselves in situations where there is real or apparent conflict of interest between them as individuals and the interest of the Group. Directors and employees must not use their positions or knowledge gained directly or indirectly in the course of their duties or employment for private or personal advantage. In addition, a Director or an employee shall not have an outside interest which materially encroaches on time or attention which should be devoted to Company’s affairs. A Director or an employee shall avoid any situation in which the Director or employee has an interest in any entity or matter that may influence the Director or employee’s judgment in the discharge of his responsibilities.
	4.2	Confidential Information All Directors and employees are to exercise caution and due care to safeguard any information of a confidential and sensitive nature relating to the Group which is acquired in the course of their employment, and are strictly prohibited to disclose to any person, unless the disclosure is duly authorised or legally mandated. Confidential information must not be used for the personal gain of anyone else except on legitimate business purposes.
	4.3	Inside Information and Securities All Directors and employees who have access to confidential information are not permitted to use or share that information for securities trading purposes (insider trading) or for any other purpose except for the conduct of the Company’s business. All non-public information about the Company should be considered confidential information. It is always illegal to trade in the securities of the Company while in possession of material non-public information and it is also illegal to communicate or “tip” such information to others.
	4.4	Protection of Assets and Funds Directors and employees must protect the assets and funds of the Group to ensure availability for legitimate business purposes and that no property, information or position belonging to the Group or opportunity arising from these be used for personal gain. The Group’s assets, including employee time, may not be used improperly to enrich the Company’s Directors and employees.
	4.5	Business Records and Control Accurate, timely and reliable records are necessary to meet the Group’s legal and financial obligations and to manage the affairs of the Group. The Company will ensure and maintain accurate and complete accounting records in accordance with the applicable approved accounting standards and accounting policies with adequate internal controls established. No unauthorised, false, improper or misleading records or entries shall be made in the books and records of the Group under any circumstances.
	4.6	Compliance with Laws, Rules and Regulations The Company will comply with all applicable laws, rules and regulations of the governments, commissions and exchanges in jurisdictions within which the Group operates. Directors and employees are expected to understand and comply with the laws, rules and regulations that are applicable to their positions or work.
	4.7	Bribery The Board has defined its Anti-Corruption Measures and Policies (“ACMP”) outlining the anti-corruption measures to mitigate the corruption risk of the Group as well as the policies governing the ethical business responses to bribery. All directors, members of management and employees should familiarise with and adhere to this ACMP as well as and communicate the provisions of the ACMP to all business associates.
	4.8	Health and Safety It is the Company’s policy to conduct its business operation in a manner that protects the safety of employees, customers, the public and its assets. The Company believes in providing a safe and healthy environment for its employees to discharge their duties and responsibilities and achieve excellence in the workplace. All Directors and employees must observe and comply with all the safety policies that have been set and those that will be issue in future as and when the need arises.
	4.9	Sexual Harassment Sexual harassment by any Director or employee is unacceptable. It is the Company’s policy to provide all employees with a working environment free from any form of sexual harassment. The Company will also not tolerate or condone sexual or other harassment towards other people including contractors, suppliers’ representatives, guests, customers or visitors. Any questions concerning issues of such should be directed either to the employees’ immediate supervisor, the Head of the Human Resource Department or Executive Directors. All such reports or complaints shall be treated with strictest confidence.
	4.10	Fair and Courteous Behavior Directors and employees shall behave honestly and ethically at all times and with all people. All employees are to treat their fellow employees fairly and courteously without regard to race, creed, religion, gender, nationality, age or disability, and shall not create any form of discrimination or prejudice in the workplace.
	4.11	Misconduct No Director or employee is to be involved in or abet any activity that is deemed by the Company to be an act of misconduct (includes use and abuse of drugs).
	4.12	Abuse of Power There should be control over the corporate resources that can be misused for the Director’s personal benefits and operational, checks and balances should be in place.
	4.13	Money Laundering Every Director shall not condone, facilitate or support any activity that is even remotely associated with money laundering or financing of terrorism. Directors must be on their guard to help protect the Company’s reputation and ensuring compliance with the laws.
5.	REPORTING OF VIOLATIONS OF THE CODE Any parties who know of, or suspect, a violation of the Code, are encouraged to whistle blow or report the violations in accordance with the Group’s reporting procedures in the Whistleblowing Policy which is available on the Company’s website.
6.	REVIEW OF THE CODE The Board will monitor compliance with the Code and review the Code regularly to ensure that it continues to remain relevant and appropriate.