INTRODUCTION
Contraves Advanced Devices Sdn Bhd and its subsidiaries (collectively “Contraves”) are fully committed to conducting business ethically, transparently and responsibly, in line with the applicable laws of Malaysia and international governance standards. This Policy applies to all Contraves employees, directors, and all individuals and/or entities who/which perform any business transaction with Contraves (“Third Parties”).
This COBE Policy seeks to uphold compliance to applicable laws, regulations and international standards, including their addendums and/or amendments, including but not limited to:
- Malaysian Anti-Corruption Commission Act 2009 (“MACC Act 2009”)
- Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (“AMLA 2001”)
- Companies Act 2016
- Competition Act 2010
- Personal Data Protection Act 2010 (“PDPA 2010”)
- Employment Act 1955
- Occupational Safety and Health Act 1994
- United Nations Global Compact Principles
OBJECTIVES
This COBE Policy is established to:
- Promote the highest standards of integrity, honesty, fairness and accountability in all business dealings.
- Prevent bribery, corruption, money laundering, conflicts of interest and/or other unethical practices.
- Ensure proper use, protection and confidentiality of information in compliance with the PDPA 2010.
- Strengthen trust with stakeholders, including shareholders, employees, customers, suppliers, business partners, regulators and the community.
- Align Contraves’ business practices with relevant Environment, Social and Governance (“ESG”) commitments.
COMMITMENTS
To achieve these objectives, Contraves commits to:
- Enforce a Zero Tolerance policy against bribery, corruption, fraud and money laundering, in compliance with the MACC Act 2009 and AMLA 2001.
- Require all employees, directors and Third Parties to comply with Contraves’ COBE, Anti-Bribery & Corruption (“ABC”) and Anti-Money Laundering (“AML”) Policies.
- Identify and manage conflicts of interest, ensuring employees and directors act in the best interest of Contraves at all times.
- Establish responsible practices in handling gifts, entertainment, and hospitality, prohibiting any act that may improperly influence business decisions.
- Safeguard confidential, sensitive, and personal information against misuse, improper disclosure, or unauthorised access.
- Promote fair competition in compliance with the Competition Act 2010 and all applicable trade, import/export, and sanction regulations.
- Encourage responsible reporting of misconduct through the available Whistleblowing channels.
- Integrate ESG practices by respecting human rights, reducing environmental impacts, supporting diversity and inclusion, and ensuring transparent governance.
- Maintain accurate financial records, support internal/external audits and ensure accountability in all financial dealings.
- Conduct regular training and awareness programmes to ensure employees understand and comply with the COBE, ABC and AML obligations and requirements.
Employees and Third Parties are expected to seek clarification from Management whenever in doubt and to immediately report suspected violations through the appropriate channels.
Within ten (10) working days of the date of issuance indicated below, all employees shall be deemed to have read, understood and accepted this COBE Policy and all provisions contained herein. Any breach of this Policy will be subject to the appropriate review and consequences.
This Policy shall be reviewed and updated periodically to ensure its relevance and effectiveness. The latest version will be disseminated via email to all employees by Document Control and prominently displayed within Contraves premises.
Effective 06 October 2025
For and on behalf of CONTRAVES ADVANCED DEVICES SDN BHDCHIEF EXECUTIVE OFFICER