Code of Conduct

This Code of Conduct (this "Code") sets out the guiding principles and desired behaviours which form the framework by which companies and employees in the Group are expected to operate, and it embraces business practices and standards of behaviour that support the commitment to honest and ethical business conduct.

1. Applicability of this Code

   This Code is applicable to all employees (including all the executive directors) of the Company, its subsidiary and associated companies (unless the subsidiary or associated company is a listed entity). Contractors, consultants and agents who are working on the Group's behalf shall be required to act consistently with this Code when acting on our behalf, and their undertakings to act consistently with this Code shall be incorporated into their contracts with us.

2. How is this Code administered?

   All employees must comply with the standards as set out in this Code. Any violation of the standards in this Code shall subject the violator to disciplinary actions which may include, inter alia, termination of employment and legal repercussions (civil and/or criminal) under the applicable laws.

   Employees are encouraged to report any non-compliance or breach of this Code with the direct supervisor of the employee concerned, or with the Human Resource Department.

   Employees are also reminded that the Group implements a Policy on Whistleblowing (the "Whistleblowing Policy"). In the event where an employee discovers any non-compliance or breach of this Code, but feels uncomfortable to report such non-compliance or breach with the relevant supervisor or the Human Resource Department, the employee is encouraged to report such non-compliance or breach through the whistleblowing process as specified in the Whistleblowing Policy.

   If there is any doubt to any part of this Code, please do not hesitate to consult the Human Resource Department.

3. Revising of this Code

   Employees are encouraged to continually refer and familiarize themselves with this Code to understand what the Company deems as appropriate behaviour. In order to align this Code with applicable laws and/or the prevailing guiding principles of the Company and/or the Group, this Code may from time to time be amended or substituted, in whole or in part. In the event of such revisions, the Company will notify its employees of such change. Employees shall constantly keep themselves updated and understand the latest Code, so as to fully comply with it.

Employees must at all times act honestly and uphold integrity in all relationships with customers, suppliers, contractors, regulatory authorities and other stakeholders or any person in general.

Employees must carry out their responsibilities in compliance with the Group's Guidelines and all applicable laws, rules and regulations.

As a listed entity, it is important to ensure that confidential information is disseminated only via the proper channel to all stakeholders. Therefore, it is of utmost importance that employees who come into contact with confidential information relating to the Group shall keep such information confidential and do not share such information with another person without authority. Such information also should not be used to obtain personal benefit or for the personal benefit of other persons. Such activities may contravene applicable laws, such as the provisions in the Securities & Futures Act (Cap. 289) and the Prevention of Corruption Act (Cap. 241).

Employees must always act in the best interests of the Group. They must at all times act honestly and use reasonable care, skill and diligence in the discharge of their duties and responsibilities, including the proper acquisition, use, maintenance and disposal of Group assets (including materials, equipment, tools, real property, information, data, intellectual property and funds) and services. Theft, carelessness and waste should be avoided. Group assets should be used for legitimate business related purposes and not for personal benefits.

The Group is committed to running business operations based on integrity, transparency and honesty. Whilst the giving and receiving of favours, concessionary offers and gifts (including entertainment, meals, tickets to social/sports events etc.) may help in the building of business relationships, good judgment must be exercised at all times. In the event where an employee when exercising his or her good judgment is unable to ascertain if the giving or receiving of favours, concessionary offers and gifts is appropriate or otherwise, the employee should always take the prudent approach not to proceed with the giving or receiving of favours, concessionary offers and gifts. In such cases, the employee should consult and seek approval from his or her direct superior on whether such giving or receiving of favours, concessionary offers and gifts is appropriate.

Bribery, or the corrupt giving or receipt of gratification in relation to any person as an inducement or reward for any person doing or forbearing to do something, is strictly prohibited under the Prevention of Corruption Act (Cap. 241).

It is to be stressed that the Group's Whistleblowing Policy is intended to act as an internal reporting structure that enables and encourages our employees, and external parties, to raise concerns, in confidence, about possible irregularities within the Group.

The Group adopts a strict policy against bribery and corrupt practices. Any employee found guilty of engaging in corrupt practices or giving or receiving bribes shall be subject to the appropriate disciplinary proceedings, which may include, inter alia, termination of employment. Notwithstanding this, the Company and the Group reserve the right to commence civil proceedings to recover any loss or damage suffered by the Company and/or Group resulting from the employee's actions or omission, or to report the employee to the appropriate authorities where the employee's act constitutes a criminal offence.

Employees must avoid any conflict between their own interests and the interests of the Group. A conflict situation can arise when an employee takes action or interest that may make it difficult to objectively and efficiently perform his or her duties for the Group.

Employees are to disclose promptly any conflict of interest or potential conflict of interest situations that may arise.

The Group has put in place a Whistleblowing Policy to facilitate with the reporting of activities or practices which are in violation of the Group's work ethics and rules. The Group encourages employees or any other parties with whom the Group has a business relationship to report unlawful, unethical or fraudulent activities or practices in strict confidence. All whistle-blowing reports are submitted either to the HR Manger, Chief Financial Officier or the Chairman of the Audit & Risk Management Committee (ARMC) so that independent investigations and appropriate follow-up actions can be carried out.

All officers of the Group are prohibited from dealing in the securities of the Company while in possession of pricesensitive information. They are also prohibited from dealing in the securities of the Company during the closed period, which is two weeks before the date of announcement of results for each of the first three quarters of the Company's financial year and one month before the date of announcement of the full-year financial results. In addition, officers of the Group are also discouraged from dealing in the Company's securities on short-term considerations.

The collection, use, disclosure and storage of personal data during the course of business are governed by the Personal Data Protection Act 2012. Employees should adhere to the Personal Data Protection Security Policy and applicable laws as well as the Compliance Manual through guidance by the Data Protection Officers.