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Code of Ethics

This Code of Ethics, Business Practice and Conduct (“Code”) applies to all the employees of Swap Holdings Sdn Bhd and its group of companies (“Company”), subcontractors, suppliers, vendors and all external parties(“External Parties”). This Code outlines the ethical principles that govern decisions and behaviour in the Company and outlines how the employees should behave, as well as specific guidance for handling issues like whistleblowing, safety, and conflicts of interest.


The Company has spearheaded the drive for greater integrity in business and has zero tolerance for corrupt practices and conducts its business ethically, honestly, and in compliance with the laws and regulations of the respective countries that it conducts business in. The Company believes in commitment to act responsibly by considering human rights, social requirements, and environmental considerations when conducting business.


The higher management, manager or supervisor (“Superior”) is expected to ensure that his/her department operates in accordance with the highest principles of business ethics. If the Superior becomes aware of actual or suspected violations or problems, he/she must promptly report the issue to Legal, Human Resource Departments or any Executive Director of the Company.


Each member and officer of the Company shall take appropriate steps and measures to ensure that neither the employee nor any staff is placed in a position where, in the reasonable opinion of the Company, there is or may be an actual conflict, or a potential conflict, between the pecuniary or personal interests of the employee and the duties owed to the Company under the provisions of the employment contract.

The employee shall not engage, solicit or seek to gain pecuniary or personal benefit from subcontractors, suppliers, vendors and all related third parties in the course of their employment with the Company.

The employees shall fully disclose to the Superior and/or the Company the full particulars of any such conflict of interest which may arise. Stern disciplinary actions shall be taken against employees for any violation of this Code.


All the employees of the Company, shall at all times in connection with and throughout the course of the employment with the Company and thereafter, will comply with and take reasonable measures to ensure that they do not offer and/or accept from the subcontractors, suppliers, vendors, public officials and all related third parties, any forms of bribes, improper gratifications, kickbacks (including gifts, hospitality and entertainment) which will result in contravention of Malaysian Anti-Corruption Commission Act 2009 and/or Anti-Bribery Policy of the Company and/or any applicable laws and.


All the employees of the Company are prohibited from getting involved in activities related to money laundering as stipulated under the applicable laws.


All employees and any members of the public including stakeholders involved in a business relationship with the Company shall have an avenue to report suspected and/or any known disciplinary offence including but not limited to fraud, pilferage, perpetration, corruption, misconduct, wrongdoing, abuse of resources, illegal activity, conflict of interest, sexual harassment, tampering, falsification and material misstatement of information, danger to health, safety or the environment or misappropriation by employees of the Company as per the established Whistleblowing Policy of the Company and the Whistleblower Protection Act 2010.

The divulging party may submit any genuine whistleblowing reports with reasonable grounds or suspicion with evidence by email to the Integrity Officer at integrity_officer@admin


In the course of employment, the employees will be exposed to confidential information of the Company, which includes other operations and activities. Confidential information includes, but is not limited to, data relating to the Company’s operations, customer information, financial data, computer programs, drawings, marketing plans and information, operating procedures and the like, or any other information of the business affairs of the Company (“Confidential Information”). All employees shall not, directly or indirectly, use, disseminate, disclose, or in any way reveal or use beyond the scope of authority granted by the Company, all or any part of such Confidential Information, which he/she has been or will be exposed to, and shall use such Confidential Information only to the extent specifically authorized by the Company. Upon termination of his/her employment for any reason whatsoever, he/she shall turn over to the Company all Confidential Information. The employees acknowledges that the Company may exercise any and all remedies available to it at law or in equity to enforce this obligation with respect to non-disclosure of any Confidential Information, which the employee has or will become privy to in the performance of his/her employment obligations. All employees shall abide by the requirement under the Personal Data Protection Act 2010 and all the requirement as established by the Company when the employees come in contact with the personal data of subcontractors, suppliers, vendors, public officials and all related third parties.


All employees shall ensure that all procurement decisions are made in a fair and ethical manner in accordance to the Company’s Code. The Company shall provide a range of competitive opportunities for subcontractors/suppliers/vendors to participate in the Companies’ tender or procurement process.


All employees shall maintain records, reports, supporting documents and all other relevant books, papers and other documents so as to enable the Company to meet all related reporting requirements. Records shall be maintained for a period of time as directed by the Company, or a period otherwise required by law. The records to be maintained is including notices, financial systems, records, reports, books, documents, and papers as may be necessary for audit, examination, excerpt, transcription, and copy purposes, for as long as such systems, records, reports, books, documents, and papers are retained. Any falsification or improper alterations of records are strictly prohibited.


All the employees of the Company are obliged to adhere to all the rules relating to safety, health and environment. The Company regards the regulations relating to health and safety requirements at the workplace as of high importance. Therefore, all employees are required to comply with the professional standards for health and safety as stipulated by the Company from time to time.


All employees of the Company have a right to freedom from harassment in the workplace. Employees are strictly prohibited from engaging in any form of harassment, humiliation and intimidation of a sexual nature. The Company shall take such actions as necessary from time to time to provide a safe place of work for all employees.


The Company shall update this Code from time to time to ensure it remains relevant with the progress of applicable laws in the daily operation of the Company and shall be entitled to revise, amend, modify, suspend or terminate this Code at any time, with or without notice.