1. OVERVIEW

This Code of Business Ethics (“Code” or “COBE”) has been developed to guide and support the Ingenious Works International (M) Sdn. Bhd.’s (“ING” or “The Company”) business operations and governance policies which include the General Administration Policy and Procedures, Anti-Bribery & Corruption Policy and Whistleblowing Policy. ING has developed this COBE to outline its commitment to integrity, ethical practices across its supply chain, respect for human rights, and adherence to environmental, health, and safety standards. The Code also sets forth ING’s expectations of Associates (as defined in ING’s Anti-Bribery and Corruption Policy) when conducting business with or on behalf of ING.

2. OBJECTIVES

The Policy’s main objectives are to ensure all areas of ING’s business operations;

(i) Correct and ethical business practices
(ii) Safe and conducive working environment
(iii) Fair treatment of interest of all relevant stakeholders
(iv) Compliance to all applicable laws and regulations

3. SCOPE

This Code applies to all Employees of ING. ING requires its contractors, sub-contractors, consultants, agents, representatives and others performing work or services for or on behalf of ING to observe the relevant parts of this Code.

4. POLICY OWNER

The owner of this Policy shall be Directors and Senior Management (“The Management”).

5. APPLICATIONS

This Code states ING’s ethical position or stand; the detailed policies and procedures for dealing with specific matters may be found in the respective functional policies and procedures.

This Code is intended as a guide and is neither exhaustive nor addresses every situation that an Employee may encounter. Therefore, every Employee shall familiarize himself/herself with the relevant policies, procedures and manuals of The Company.

This Code is also neither legal advice nor identifies every law, policy or procedure that may apply to the Employees in performing their roles. Should there be a conflict between the Code and the policies and procedures of The Company with the law, the stricter provision shall apply.

Employees are expected to exercise sound judgment in making any decision and shall not conduct themselves in any manner which could negatively affect the ING’s confidence and trust in them. These duties are without limitation to duties imposed upon an Employee by law.

Apart from understanding and complying with this Code, an Employee is required to:

a) Ensure that staff reporting to him/her similarly understands and complies with this Code;

b) Guide others on this Code and any other applicable policies and procedures of The Company.

6. PILLAR OF CODES

This Code consist of four main sections;

6.1 Personal Conduct

6.2 Corporate Care

6.3 Sustainability

6.4 Compliance

6.1 PERSONAL CONDUCT

Personal conduct is the foundation of personal, family, corporate and societal well-being. The following are guidelines for personal conduct for Employees and relevant persons.

6.1.1 PRACTICE PROPER CONDUCT WITHIN AND OUTSIDE WORKPLACE

The Company expects appropriate personal conduct within and outside the workplace, of all its Employees and associates to ensure a safe, conducive and productive work environment.

6.1.2 AVOID CONFLICT OF INTEREST

Conflicts of interest situations arise when the interest of the Employee and/or their family members or related stakeholders’ conflict with the interest of The Company, and should be avoided.

Employees should use his/her position, official working hours, company’s resources and information available to them for the advancement and interest of the ING’s well-being, and not to disadvantage the ING or for undue personal gain.

If unavoidable situations of conflict of interest should arise, declaration of such conflict needs to be made and resolved in accordance to the ING’s policies and procedures governing such an issue.

Failure to avoid or declare and resolve issues of conflicts of interest may subject the affected Employee to disciplinary action.

6.1.3 KEEP AWAY FROM SUBSTANCE MISUSE

Substance misuse is not permitted. This includes any illegal drugs, medication or alcohol abuse that is against the law, and may compromise work performance or safety. Contractors and sub-contractors are required to demonstrate that they have implemented substance misuse prevention and control policies and programs. Employees with unauthorized possession of any substance of misuse or who test positive for any substance of misuse shall be subject to appropriate disciplinary action.

6.1.4 MAINTAIN PROPER PERSONAL DEALINGS WITH CONTRACTORS & SUPPLIER

Employees shall ensure that their personal business dealings with The Company’s suppliers, contractors and vendors are on an arm’s-length basis and comply with specific guidelines and rules on such dealings.

6.1.5 PROHIBIT BULLYING & HARRASSMENT

The Company takes a strong stand against bullying behavior as well as personal and sexual harassment. Violators of this Code will face severe disciplinary action.

6.1.6 MAINTAIN PROFESSIONAL WORKING RELATIONSHIP

The Company encourages the development of professional and social networking as they are part of organizational culture development and promotes teamwork and Group effectiveness. Such relations however should not lead to situations of conflict of interest, biasness, favoritism and exploitation in staff relationships and work management.

Employees are discouraged under any circumstance, from borrowing money either from their superiors, subordinates, clients, business associates, contractors and vendors.

An Employee should not place himself/herself under any serious financial obligation to any person who is directly or indirectly subject to his/her official authority or with whom he/she is likely to have official dealings.

6.1.7 DRESS PROFESSIONALLY AT WORKPLACE

Employees should dress appropriately in relation to their work requirements during working hours for the purposes of maintaining a professional image, safety or health reasons. As such, specific rules for attire may be established by specific workplaces for their respective requirements.

6.2 CORPORATE CARE

6.2.1 HANDLE COMPANY ASSETS RESPONSIBLY

All Employees are expected to safeguard, manage and use appropriately the Company’s assets, facilities, records and other resources according to the relevant manuals outlining policies and procedures for such requirements.

6.2.2 COMPLY WITH DATA PRIVACY AND PROTECTION REGULATIONS

Personal privacy, including the protection of personal data shall be respected. All applicable laws and ING’s policies and procedures on data privacy and protection must be complied with.

6.2.3 PRACTICE PROPER DOCUMENTATION

The integrity and accuracy of The Company’s financial records and reporting are paramount to the proper operation and control of its businesses. Therefore, all Employees shall safeguard the preparation, maintenance and disposal of The Company’s legal, contractual, financial and operational records.

6.2.4 AVOID INSIDER DEALINGS

All Employee shall acquaint themselves with the relevant laws and consequences governing insider trading and shall not deal in the securities of The Company while in the possession of material non-public information. The restrictions apply to price-sensitive information or other similar types of information that relevant insider-trading laws make reference to.

6.2.5 PROVIDE REFERENCE ONLY IN A PROFESSIONAL CAPACITY

In the normal course of business, an Employee shall only give reference in a professional capacity, with the approval of the Management, and may use The Company’s name or stationery with The Company’s logo.

6.2.6 SEEK APPROVAL FOR DISCLOSING CONFIDENTIAL INFORMATION

An Employee shall obtain prior approval or authorization from his Head of Department (or, from the Management) before disclosing to an external party any confidential information that may benefit the third party and/or impact The Company’s performance. Usage of Non-Disclosure Agreement must be utilized in a formal setting if there is a need to exchange official document regardless if the documents are provided or exchanged digitally or physically.

6.2.7 WHISTLEBLOW / REPORT MISCONDUCT

If any Employee is witness to, or has evidence that an unlawful act has been or is about to be committed by another Employee, he/she shall disclose or report such to The Management, as following, with reference to following the Whistleblowing Policy (ING WBP R00):

(i) Email: ingenious.mgmt@gmail.com;

(ii) Digital Submission via QR:

6.3 SUSTAINABILITY

6.3.1 SUPPORT SUSTAINABLE PRACTICES

Employees should exercise due care to ensure that the work that he/she does are in-line with globally accepted sustainable guidelines with regards the responsible and efficient use of resources, care for the community and to minimize negative impacts on our environment. To the extent possible the aim of making the world a better place for future generations shall be the guiding principle.

6.3.2 COMPLY WITH QUALITY, SAFETY, HEALTH & ENVIRONMENTAL GUIDELINES

All Employees have a role to play in providing a safe, conducive and healthy workplace and minimizing the negative impact of The Company’s operations on the environment. As such every Employee must conscientiously and diligently comply with all QHSE requirement, measures, work rules and standard operating procedures set out in ISO standards, 9001, 14001 & 4500 issued by The Company and to ensure all applicable laws and regulations are followed.

6.4 COMPLIANCE

The Company’s Employees and relevant persons are required to

• observe all statutory laws and regulations applicable to The Company’s businesses and operations and;

• comply with The Company’s policies and procedures contained in the relevant manuals.

Subject to the requirements of the applicable law, disciplinary action may be taken against any person covered by this Code for misconduct or for non-compliance with such laws and regulations, as well as the Company’s policies and procedures.