Code of Conduct & Business Ethics
Code of Conduct & Business Ethics
This Code of Conduct & Business Ethics sets out the acceptable general practices and ethics that guide the employees of Malayan Cement Berhad and its subsidiaries in Malaysia (“MCB”). It is intended to apply to all employees at all levels and, where applicable, to directors of MCB and where necessary, the relevant subsidiary companies under MCB may implement additional policies specific to their industry for further compliance to complement this Code of Conduct & Business Ethics (“Policies”). References to employees in this Code of Conduct & Business Ethics will include directors employed in an executive capacity by MCB.
Table of Contents
Conduct At The Workplace
1. Accountability
2. Health and Safety at the Workplace
3. Non-Discrimination
4. Business Communications
5. Record Keeping
6. Personal Data Protection Notice
7. Confidential and Proprietary Information
Conduct in Business Ethics
8. Outside Employment
9. Conflicts of Interest
10. Insider Trading
11. Anti-Bribery & Anti-Corruption
12. Anti-Money Laundering
13. Whistleblowing
Conduct in Public
14. Responsible Corporate Citizenship
15. Distribution of Non-MCB Related Materials and MCB’s Bulletin Boards
16. Social Media Policy
17. Press Release and Public Statements
18. Business Associates
Other Environmental, Social and Governance (ESG) Priorities
19. Employment, Human Rights and Ethics
20. Commitment to the Environment
21. Ethical Supply Chain
22. Compliance and Review of the Code
Conduct At The Workplace
(1) Accountability
1.1. All directors and employees of MCB are responsible for acting in accordance with this Code of Conduct & Business Ethics of MCB (“Code“), Policies and the core values of MCB and ensure compliance with relevant laws, rules and regulations (“Laws”).
1.2. Any employee of MCB who violates the Code, any Policies or any Laws is deemed to have committed a serious misconduct and may be subjected to disciplinary action, including dismissal, depending on the facts, severity and circumstances of each case. Any serious violations may also subject the individual employee to civil or criminal implications.
1.3. All employees of MCB shall ensure that they conduct their work in a manner consistent with all directives, practices, guidelines and policies which are issued from time-to-time. Where there are any directives, practices, guidelines and policies issued by the relevant subsidiary companies, the employees working for such subsidiary companies shall also ensure compliance with the same in the conduct of their work. In the event of any conflict, the directives, practices, guidelines and policies of their immediate employer applies.
1.4. All employees of MCB are obliged to exercise sound judgment in all work undertaken, and to exercise all reasonable care in safeguarding MCB’s interests, properties and assets, including for the avoidance of doubt, data and intellectual property, against any loss, damage, misuse, illegal use and/or theft and are expected to use such resources for MCB’s business purposes.
(2) Health and Safety at the Workplace
2.1. MCB prioritises protecting the health, safety and welfare of all employees and stakeholders at MCB’s workplace, and this remains an established and shared responsibility that is essential to MCB.
2.2. In the conduct of their duties, all employees of MCB are expected to:
(a) comply strictly with applicable health, safety and legal requirements at their work location(s);
(b) comply with all health and safety processes established at their work location(s);
(c) ensure that any safety equipment and tools utilised are in good condition and used correctly to perform all work safely and to reduce health and safety impacts;
(d) assist to maintain a clean and safe environment at all work locations;
(e) attend all mandatory trainings, attain the requisite authorisation to perform assigned jobs and conduct job risk assessment before starting any job;
(f) never override safety devices and controls on any machinery, equipment and processes;
(g) immediately report any unsafe equipment and tools, hazardous conditions, near misses and accidents; and
(h) comply with the security system requirements, arrangements and plans in place at all work locations.
(3) Non-Discrimination
3.1 MCB maintains a policy of non-discrimination and greatly values and respects the diversity of its employees.
3.2. All employees of MCB are expected to cooperate and support MCB’s vision of cultivating and maintaining a work environment that is safe, free from discrimination and harassment, and to be respectful of differences among employees.
3.3. We are committed to providing employees with access to equal opportunities across MCB. During the hiring process, candidates will also be evaluated based on their willingness to adhere to the vision, values and overall corporate culture of MCB.
3.4. MCB encourages a healthy work environment that is free from discrimination, bullying and harassment in the workplace which are further detailed in the Employee Handbook.
(4) Business Communications
4.1. All employees of MCB are expected to exercise due care, diligence and etiquette in all work-related communications, be it in written form, verbal or otherwise, and to ensure that the contents are clear, truthful, courteous and accurate.
4.2. MCB exercises a no tolerance policy for any communications made by its employees over the course of business and/or using MCB’s resources that contain any material found to be discriminatory, defamatory, offensive, contains sexual connotations, pornographic, misleading and/or any other communications of a similar nature.
(5) Record Keeping
5.1. All employees of MCB are to ensure that they undertake proper record keeping of all commercial arrangements, transactions, accounts, tax matters, communications and information, particularly where it is required by Law. Employees must never delete, destroy or discard any records without authorisation and particularly where it is to hide a wrongdoing or a mistake.
5.2. Any falsification or improper alterations of records are strictly prohibited. This includes that an employee of MCB should not be giving instructions to any other person, including colleagues and third parties, to prepare or approve false or misleading records to either hide the true nature of the records, or to achieve an improper purpose that will otherwise be in violation of any Laws or Policies of MCB.
5.3. Any discrepancies or inaccuracies within a record must be immediately and properly resolved with appropriate corrections, including informing all related parties who need to know of such corrections.
(6) Personal Data Protection Notice
6.1. MCB respects and is committed to the protection of employee’s personal information and privacy. An employee’s personal information are kept strictly confidential and not released to any parties without the prior consent of the employee. The Personal Data Protection Notice issued to employees explains how MCB collects and handles employee information in accordance with the Malaysian Personal Data Protection Act 2010.
6.2. All employees of MCB, particularly employees who have access to personal data of any persons, whether employees, consultants, customers, suppliers, shareholders and/or any other party whereby personal data is processed and accessed, must not unlawfully use, access and/or revise such personal data for any purpose or reason. All employees are to ensure that such personal data processed within MCB is protected at all material times and in compliance with the applicable Laws.
(7) Confidential and Proprietary Information
7.1. MCB greatly values and protects all confidential and proprietary information.
7.2. Proprietary information includes but is not limited to emails, documents and all other files, electronic or otherwise, edited and/or stored on equipment utilised by MCB and are considered to be the exclusive property of MCB.
7.3. All directors and employees of MCB are expected to exercise the highest possible standards of professionalism, ethics and integrity in order to protect the MCB’s confidential information, assets and standing and ensure the proper use of the same.
7.4. Directors and employees of MCB may have access to confidential and proprietary information during their tenure or employment with MCB. Such information cannot be shared, disclosed or utilised for personal gain or any other gain or any reason to any individual, business or third party entity, including family and friends, except where expressly approved by the relevant company under MCB, required by Law and/or reasonably necessary for the purposes of carrying out their duties under contract or employment within MCB. This obligation of non-disclosure is effective and shall continue even after the termination or cessation of employment.
7.5. Where such confidential and proprietary information needs to be disclosed to persons outside MCB, the relevant parties are required to undertake necessary measures to ensure that all confidential and/or proprietary information is sufficiently protected, for instance through the execution of a non-disclosure agreement.
7.6. MCB reserves its right to take any and all appropriate action against previous or current directors or employees who, whether directly or indirectly, breach the obligation relating to the confidential and proprietary information of MCB.
7.7. Any employee who is unsure of what is permissible or non-permissible is advised to seek guidance from their head of department or the Human Resources Department.
Conduct in Business Ethics
(8) Outside Employment
8.1. Employees are hired on the premise that MCB is their primary employer and that any other employment or commercial involvement, even outside of working hours is strictly prohibited particularly where it conflicts with the interests of MCB, unless express approval is obtained.
8.2. Employees and managers are required to obtain written approvals from their head of department or the Human Resources Department before participating in outside work activities. Any employee already engaged in any outside employment is required to disclose and obtain approval from the Human Resources Department. Any approval given is at the sole discretion of MCB and can be withdrawn at any time with or without prior notice, and the employee is required to immediately cease such outside employment, failing which MCB is entitled to claim compensation for any unlawful profiteering as a result of any conflict of interest.
(9) Conflicts of Interest
9.1. All directors and employees of MCB are obliged to:-
(a) act solely in the best interests of MCB at all times;
(b) avoid conflict of interests; and
(c) exercise due care and diligence when complying with these provisions, in accordance with its letter and spirit, intention and purpose.
9.2. Employees of MCB are not permitted to:-
(a) engage, either directly or indirectly, in any act, practice, transaction or arrangement or proposed act, practice, transaction or arrangement that conflicts with, or appears to conflict with, the interests of MCB, even in their own time;
(b) solicit or create business opportunities for themselves or anyone related to them in the course of their employment with MCB, particularly where it is a conflict of interests with MCB unless otherwise approved in writing by the Managing Director;
(c) use their employment position in any manner or any information acquired by virtue of their employment to gain any personal, financial or other advantage for themselves and/or their relatives which is contrary to their employment or interests of MCB; or
(d) use any assets, data, intellectual property or resources owned or used by MCB, or abuse any loopholes in MCB’s process and procedures, for personal interests or gain.
9.3. Situations where a conflict of interest may arise include, but are not limited to the following:-
(a) where a director, employee or their relative has a personal relationship or financial or other interest that would or could potentially interfere with his/her existing obligations or exercise of judgment in decision making as a director or employee of MCB; or
(b) where a supervisor or a person in a position to determine the remuneration and/or promotion of a subordinate is in a personal, romantic or intimate relationship with the subordinate.
9.4. It is not possible to anticipate every situation or activity that may give rise to a conflict of interest due to the complex and multi-faceted business environment in which MCB operates. Situations which will or will not give rise to a conflict of interest may be subjective and depend on specific facts and circumstances. The measures needed to address or manage the conflicts of interest will depend on relevant facts and circumstances of each case.
9.5. All directors and employees of MCB are obliged to disclose and report in writing as soon as practicably possible all potential and real conflicts of interest, stating in detail the facts, nature and extent of the conflict. This written report should be made as appropriate, either to the board, the employee’s immediate supervisor(s) and/or executive director(s) and/or any other relevant parties as notified.
9.6. All directors and employees of MCB must take prompt action in eliminating the said conflict if requested to do so by MCB. MCB has the sole discretion in determining the nature of conflict of interests and the next steps or disciplinary action to be taken in relation to it.
9.7. Where it is found that a director or employee of MCB is engaged in any activity that constitutes a conflict of interests with MCB which provides personal and monetary gain, particularly where it is at the expense and loss of MCB, MCB is entitled to claim compensation for such unlawful profiteering from the conflict of interest, which for employees, may include deduction of the employee’s salary until such payments are repaid in full or legal action against the employee.
9.8. External Board Membership:
Employees of MCB are allowed to serve on the boards of government agencies or bodies and/or incorporated or unincorporated entities outside MCB only under exceptional circumstances, provided that prior written approval has been obtained from the Board of Directors. The exception to this is where such board appointments relate only to businesses or entities that were formed by non-profit organisations, such as social or community-related clubs or associations.
9.9. Political Activities:
(a) All employees of MCB have the right to participate as individuals in the political process of their local jurisdiction provided that all acts pertaining to the same are carried out entirely of the employee’s own volition, in his/her own time and using his/her own resources. The employee must ensure at all times that such activities do not and will not have any impact on his/her performance at the workplace.
(b) The employee must ensure that his/her political views are clearly communicated as his/her personal political views and that it is not reflective of the position adopted by MCB.
(c) If any employee of MCB has any interest or intends to hold any key position as an office bearer in any political party, this interest or intention must first be disclosed to his/her immediate supervisor and head of department.
(d) Any director of any company under MCB who has any interest or intends to hold any key position as an office bearer in any political party must disclose such interest or intention to the Managing Director.
(e) Directors and employees of MCB are not permitted to endorse any political act, activity and/or event or political donation using MCB’s name, reputation and/or connections.
(10) Insider Trading
10.1. Any director or employee of MCB who is in possession of market sensitive information is prohibited from trading in the securities of the listed companies of MCB or any other listed company if that information has not been made public. Foreign laws on insider trading may apply where the information concerns companies listed outside of Malaysia.
10.2. This prohibition extends to any act of disclosing the insider information to another person, including family members and friends, if the employee knows or reasonably knows that the other person would make a trade in reliance on that information, even if the employee does not derive any economic benefit from the trade.
10.3. Under the Capital Markets and Services Act 2007 (“CMSA”), an “insider” refers to a person who possesses information that is not generally available and which, upon it becoming generally available, would have a material effect on the price or the value of securities.
10.4. The scope of information is wide and includes inter alia:
(a) matters of supposition and other matters that are insufficiently definite to warrant being made known to the public;
(b) matters relating to the intentions or likely intentions of a person;
(c) matters relating to negotiations or proposals with respect to commercial dealings or dealing in security;
(d) information relating to the financial performance of MCB;
(e) information that a person proposes to enter into, or has previously entered into one or more transactions or agreements in relation to securities or has prepared or proposes to issue a statement relating to such securities; and
(f) matters relating to the future.
10.5. Employees are encouraged to consult with their manager or supervisor if they are uncertain of the status and nature of the information they possess.
(11) Anti-Bribery & Anti-Corruption
11.1. MCB conducts all business transactions and negotiations with transparency, and is determined to maintain a work and business environment where trust is of paramount importance. MCB has a zero tolerance policy for any form of bribery or corruption at any level.
11.2. All directors and employees of MCB are required to adhere to the Anti-Bribery & Anti-Corruption Policy (“ABC Policy”) which clearly sets out MCB’s policies in various matters that relate to bribery and corruption.
11.3. All companies under MCB and their directors and employees shall refrain from offering, promising, giving, demanding or receiving anything of value to them in the form of bribes and/or any other improper gratification.
11.4. All directors and employees of MCB must refrain from any acts of bribery which take the form of offering, promising, giving, demanding or receiving anything of value to or from anyone in the form of bribes, kickbacks and/or any other improper gratification (including gifts, hospitality and entertainment) to improperly influence the outcome of any transaction, whether it is for their own personal benefit or for the benefit of MCB.
11.5. MCB strictly does not tolerate any bribes given for purposes of obtaining or retaining business for MCB or providing an advantage to the businesses of MCB. MCB does not tolerate any such acts of bribery even in a personal capacity.
11.6. “Gratification” shall have the meaning defined in the Malaysian Anti-Corruption Commission Act 2009 which includes but not be limited to anything of monetary and non-monetary value or benefit to the person. Gratification can be money, donation, gift, loan, fee, reward, valuable security, property or interest in property, movable or immovable property, financial benefit, office, dignity, employment, contract of employment or services, agreement to give employment or render services in any capacity, any offer, undertaking or promise, whether conditional or unconditional, of any gratification, including favours or promise not to do something which is of value or beneficial to the recipient. Gratification does not have to be directly received by the director or employee, but it can also be received by anyone related to the director or employee that is beneficial, of value or advantageous to the employee.
11.7. Any gifts to be given by employees of MCB to any third parties, if at all, must only be under circumstances which are approved by the employee’s head of department or Human Resources Department. It should only be a token gift either for purposes of expressing appreciation or for customary and festive purposes. Such gifts should not at any material time, be given with the intention of obtaining any favour or hopes of retaining business or undue influence for obtaining future business from the recipient of the gifts.
11.8. MCB recognises that the practice of giving and receiving gifts varies between countries, regions, cultures and religions, so the definitions of what is acceptable and not acceptable will inevitably differ for each. When dealing with public officials, directors and employees of MCB should ensure that any giving or receiving of gifts do not relate to, in any form whatsoever, the public official’s official dealings or public duty. At all material times, directors and employees are to ensure compliance with Laws of their respective jurisdictions, and the higher standard will be applicable to all directors and employees to avoid non-compliance of any Laws on anti-bribery or anti-corruption which may be applicable to MCB as a whole. “Public officials” are defined as any person who is a member, an officer, an employee or a servant of a public body.
11.9. In respect of any gifts, hospitality or entertainment in the commercial context:-
(a) The intention behind giving or receiving the gift, hospitality or entertainment must always be considered first. It should never be for an improper motive to obtain or retain a business, or to obtain some form of benefit or advantage, whether it is for the business or for the individual employee;
(b) If an employee is unsure of how to consider the motive behind any gifts, hospitality or entertainment offered, the employee must always disclose and refer the matter to his/her immediate supervisor or head of department to obtain advice and also approval before proceeding;
(c) Employees of MCB are not allowed to give or receive any gratification, gifts, hospitality or entertainment where it is for an improper purpose and can be deemed as a gratification, regardless of whether it is to benefit the employee individually or to benefit the business of any of MCB;
(d) An employee must obtain prior clearance and approval from his/her immediate supervisor and/or head of department before giving any gifts to or receiving any gifts from any person which is not of any improper motive;
(e) Where any gift is not improper and received before prior approval can be obtained, an employee must always disclose such gifts to the immediate supervisor and/or head of department, regardless of the value; and
(f) Where it is difficult or inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted but it must be declared and surrendered to the employee’s immediate supervisor and/or head of department, who will assess the relevant circumstances and take the necessary steps, including returning the gift on the employee’s behalf, where appropriate or required to do so.
11.10. Any employee of MCB that breaches the ABC Policy will be subject to disciplinary action including as stated in the ABC Policy.
(12) Anti-Money Laundering
12.1. “Money laundering” concerns the process of engaging with and/or concealing, directly or indirectly, the identity of the proceeds of illegal activities or converting the illegal proceeds to a legitimate source of income or asset.
12.2. All directors and employees of MCB are prohibited from dealing in any money laundering activities and must comply with the applicable Laws relating to anti-money laundering.
12.3. In the event that any director or employee has a reasonable suspicion of money laundering activities being conducted as part of MCB’s business, the director or employee is expected to alert his/her immediate manager or supervisor to the same, and the director is expected to alert the Managing Director to the same.
(13) Whistleblowing
13.1. The Company encourages employees to raise genuine concerns, including the reporting of unlawful, unethical or questionable behaviour, in confidence and without risk of reprisal.
13.2. The policy covers, but is not limited to:
(a) abuse of power;
(b) bribery;
(c) breach of laws and statutory requirements;
(d) criminal activity;
(e) conflict of interest;
(f) danger to health and safety or the environment;
(g) sexual harassment;
(h) fraud;
(i) unauthorised and intentional overpayment to suppliers or under any contract;
(j) misuse of any property belonging to or utilised by MCB;
(k) gross negligence;
(l) theft or embezzlement; and/or
(m) non-compliance with any of MCB’s policies, including cover-up of any of the above in the workplace.
13.3. If any employee of MCB has concerns about any of the matters set out above or that the integrity of MCB is being compromised in any other way, the employee should bring this to the attention to the Whistleblowing Channel as set out in the Whistleblowing Policy, which includes the line manager, head of department, Human Resources Manager or Legal.
13.4. MCB does not tolerate retaliation against employee for any genuine reports made in relation to any commission of misconduct as stated above by any employee of MCB.
13.5. All employees of MCB must exercise sound judgment to avoid baseless allegations. MCB does not tolerate use or abuse of the Whistleblowing Channel with the intention to scandalise. Employees who intentionally file false reports will be subjected to disciplinary action and possible termination.
13.6. External parties may submit any genuine whistleblowing reports with reasonable grounds or suspicion with evidence by email to [email protected].
Conduct in Public
(14) Responsible Corporate Citizenship
14.1. MCB conducts its businesses ethically, honestly, and in compliance with Laws.
14.2. MCB is committed to being a responsible employer and a good corporate citizen in line with our vision and values.
(15) Distribution of Non-MCB Related Materials and MCB’s Bulletin Boards
15.1. All employees of MCB cannot distribute non-MCB related materials during their working hours and on MCB’s premises.
15.2. Bulletin boards are to be used purely for MCB’s related announcements and related activities.
15.3. The acts of solicitation and/or distribution of any materials relating to the sale of any goods or services unrelated to MCB’s business is strictly prohibited anywhere on any MCB’s premises.
(16) Social Media Policy
16.1. Directors and employees are free to express their personal views as long as it is made clear that it is their personal views. Unless specifically authorised, directors and employees are not authorised to make any statements on behalf of MCB or any other statements that bring MCB’s name and reputation into disrepute.
16.2. All directors and employees of MCB are reminded that any messages or posts made online are presumed to be public and permanent. Online messages or posts can be copied, forwarded or subpoenaed and the original publisher will have no control over the ultimate use, distribution and/or publication of the message or post. As such, all directors and employees are strongly encouraged to exercise discretion at all times when using and publishing on online platforms and must not disclose any of MCB’s confidential information and non-public information including photographs.
16.3. Directors and employees must not use MCB’s logos, pictorial images related to MCB and MCB’s trademarks in their own personal social media accounts.
(17) Press Release and Public Statements
17.1. All queries and/or requests made by members of the third party media outlets are to be directed to the Director of Communication to ensure that a consistent and professional approach is adopted when addressing all external media queries.
17.2. All directors and employees of MCB are not permitted to make any public releases or public statements on behalf of MCB, whether orally, in writing or otherwise, without having obtained prior written approval from the Managing Director.
(18) Business Associates
18.1. MCB works with a vast network of business associates and partners across the region. Whilst they are not employees of MCB, we expect them to have policies and principles consistent with the ABC Policy in all their business dealings whether with MCB, on behalf of MCB, or any business dealings which are related to MCB. In the absence of having their own anti-bribery and anti-corruption policies within their organisation, all business associates and partners of MCB are required to comply with MCB’s ABC Policy.
18.2. MCB has zero tolerance of business associates, partners, suppliers and contractors who do not conduct themselves in accordance to the principles of the ABC Policy where it brings disrepute or legal implications to MCB. Any non-compliance with the principles of the ABC Policy by any business associate, partner, supplier or contractor may lead to the review and/or termination of the agreement with such party.
18.3. Where applicable in the relevant jurisdictions and industries that MCB retains a dominant position in its operations or business dealings, all relevant employees shall reflect proper business practices, agreements and arrangements with business associates in compliance with Laws on fair competition or anti-trust laws, including any internal policies, practices and guidelines to maintain fair dealing and competition.
Other Environmental, Social and Governance (ESG) Priorities
All employees are expected to conduct themselves at work in a manner which supports MCB’s ESG priorities and commitments
19) Employment, Human Rights and Ethics
19.1. MCB is committed to professionalism and ethical integrity in all of business dealings and operations.
19.2. MCB is committed to continually address and assess the following employment and hiring policies:-
(a) any human trafficking or modern slavery, or any employment of minors contrary to the laws of Malaysia or any form of child labour are strictly prohibited;
(b) employees are hired on the principles of freely-chosen employment and there shall be no forced labour imposed on any person at any level of work within MCB’s business units;
(c) employee hiring is conducted through a fair and transparent process based on merit and suitability of the candidate for the job, taking into consideration of MCB’s policy of non-discrimination under this Code;
(d) employees are granted flexibility to express their opinions freely and safely through their line managers and via suitable platforms such as employee engagement surveys, the company intranet and HR communication channels. Feedback and constructive criticisms are treated with respect and confidentiality, and raised or cascaded to the relevant parties for follow up and action;
(e) employees are not prevented from being associated with any external bodies or entities, so long as such association does not jeopardise the reputation of MCB, represent a conflict of interest for the employee and/or hinder their performance at work;
(f) employees are afforded fair employment working hours, treatment, benefits and rights for their health and well-being in accordance with the relevant employment Laws; and
(g) employees are ensured the right to minimum wage, fair compensation, freedom of association and collective bargaining, and timely payment of monthly remuneration in accordance with employment Laws.
20) Commitment to the Environment
20.1. MCB firmly believe that sustainability is a key driver for future business growth. Focusing on sustainable development allows MCB to adapt its corporate culture to meet the long-term challenges of its businesses. MCB is committed to carrying out its business activities in an environmentally responsible and sustainable manner in order to minimize the environmental impact of its business activities.
20.2. Employees of MCB are responsible for demonstrating prudent environmental behaviours and reporting potential environmental risks.
20.3. Employees, suppliers, contractors and third parties shall ensure that all work performed for MCB align with the principles of MCB’s Climate and Environmental Protection Policy. Site leadership teams have the additional responsibility to ensure everyone working at MCB’s premises or property or those occupied by MCB have read, understood and takes measures to comply with such policy.
21) Ethical Supply Chain
21.1. To empower communities and reduce emissions, MCB is committed to engaging local suppliers and providing employment to locals at all locations where possible.
21.2. MCB expects contractors and suppliers (and their respective contractors, subcontractors or suppliers) (collectively, “Suppliers”) to practice good governance and to be responsible and ethical in their business dealings, including in the following areas:-
(i) fully comply with environmental regulations in all business activities;
(ii) strive to continuously improve the environmental footprint of their activities;
(iii) fully comply with all local health and safety laws, regulations, guidelines and recommendations, and provide their full support towards governmental or regulatory authorities or bodies;
(iv) ensure safe working conditions for their employees, contractors, suppliers and other stakeholders.
(v) fully comply with local laws, regulations and guidelines, particularly for those on human rights and labour; and
(vi) adhere to Laws on protection of personal data and confidential information.
22) Compliance and Review of the Code
22.1 Where there is any uncertainty for any practices which relate to the Code, employees must always seek the advice of their supervisor or head of department. Where such uncertainty persists and is not resolved, they should direct their concerns to the Human Resources and/or Legal departments.
22.2. The Code will be reviewed from time-to-time to ensure that it continues to remain relevant, appropriate and effective in the enforcement of the principles herein and to ensure continued compliance with prevailing Laws.
22.3. All directors and employees of MCB are responsible to keep themselves up-to-date with the Code, and the latest policies and processes of MCB and their relevant workplace(s), and to ensure that the highest standards of compliance are followed. There is no tolerance for non-compliance with the Code.