Code of
Conduct

1. Introduction
MK Land Holdings Berhad (the “Company”) adopts this Code of Conduct (the “Code”) for the Directors and employees of the Company and its subsidiaries (collectively referred to as the “Group”) to establish the corporate culture which is ethical and to promote professionalism and corporate conduct that permeates throughout the Group.

2. Code of Conduct
The Code is to assist the Directors and Employees in defining ethical standards and conduct at work. The Code is not intended to be exhaustive, and there may be additional obligations that Directors and Employees are expected to behave or conduct when performing their duties. For all intents and purposes, all Directors and Employees (the “Officers”) shall always observe and ensure compliance with all applicable laws, rules and regulations to which they are bound to and in the spirit of the following codes :-

2.1. Human Rights
The Group supports and respects human rights. The Company treats all Directors and Employees with dignity and respect in the workplace.

2.2 Health and Safety
The Group provides a work environment that is safe, secure and free of violence.

2.3 Environment
The Group conducts operations in a manner that safeguards health and sustain the environment. We strive to achieve a sustainable long-term balance between meeting our business goals and preserving the environment. At the same time, we also encourage on the same standard of environmental care from our suppliers and business partners.

2.4 Company Assets
The Group’s properties and assets should be managed and safeguarded in a manner which protects their values.

2.5 Exclusive Service
The Group expects the Officers to give their fullest attention, dedication and efforts to their duties and the Group. The Officers must avoid any personal, financial or other interest which may be in conflict with their duties and responsibilities to the Group.
Corrupt practices are operationally defined as the misuse of entrusted power for private gain. Officers must comply strictly all provisions of the Anti Bribery & Corruption Policy accordingly.

2.6. Integrity and Professionalism
All Officers should conduct themselves with the highest degree of integrity and professionalism in the workplace or any other location while on Group’s business.

2.7 Working with One Another

1. Personal Appearance
All Officers is expected to be suitably and neatly dressed so as to maintain an appropriate appearance that is business-like, neat and clean, as determined by the requirements of the work area.

2. Sexual Harassment & Violence
The Group is committed to treating everyone with respect and dignity, valuing individual and cultural differences. The Group is committed to treating all of our internal customers with respect and dignity by demonstrating a high level of professionalism. Any types of harassment and violence will not be tolerated. The Group will not condone any forms or acts of harassment including verbal, physical and visual conduct that creates a hostile work environment.
Any employee who believes that he/she has been subjected to harassment can lodge a report to Group Management who will be responsible to review the case and consider the appropriate course of action where applicable. The Management will investigate all complaints of sexual harassment fairly and will proceed with the appropriate action against the employee(s) concerned based on available evidence.
Disciplinary action will not only be confined to the harasser but will also include the complainant if such complaint is found to be falsely made. In this respect, if the punishment for sexual harassment is dismissal, the same will apply to the complainant who makes false accusations of such sexual harassment.

3. Equal Opportunity Employment
Our employees are our most valuable assets. The Group’s success depends on attracting and keeping a diverse workforce of talented employees. Every employee will be recognized for their skills, knowledge, experience and performance, which are vital to the growth of the organization. The Group fully supports the principles of providing equal opportunity in employment.

4. Alcohol and Drug Free Work Place
In the event, if an employee is found within the working area in the state of intoxication or in the influence of drugs, severe disciplinary action will be taken against the employee. Appropriate disciplinary action will also be taken against any Superior or line manager who is aware of alcohol or drug abuse by their employees but who condone to (do not take appropriate actions to deal with) the matter as other employees will be affected / endangered by such action. Any suspicion or knowledge of such abuses by any employee must be reported to the Head of Department. The Management may subject employees to undergo tests for unlawful drug consumption, etc as and when required.

2.8 Confidential Information
All information obtained in the course of engagement and/or employment with the Group shall be deemed to be strictly confidential and shall not be disclosed to any third party. This measure applies to all Officers, during and after their service with the Group.

2.9 Compliance Obligations
Officers are responsible for knowing and complying with the requirements applicable to their work activities, including those described in Rules of Conduct and Disciplinary Procedure in the Employee Handbook and other relevant documents.

3. Communication and Compliance
The Officers should ensure this Code is being communicated to all levels of Officers through staff handbook, notice board, intranet, or corporate website. The Group should include the briefing of this Code to new Officers in the induction programme.

4. Breach of Code of Conduct
The Officers should report to their supervisors, managers, Head of Department or Head of Human Resource about the known or suspected illegal or unethical behaviour. The Group’s Executive Directors and senior management shall promptly report any known or suspected breach of this Code to the Senior Independent Director. All Officers shall refer to and adhere to the Whistle Blower Policy.

5. Investigations
The Group shall investigate reported concerns promptly and confidentially with the highest level of professionalism and transparency.

6. Review
This Code shall be reviewed annually by the Board and, as and when the need arises, and the changes shall be communicated to all levels of officers.

Policy reviewed: 22 May 2020