Brewing Great Moments with Great Drinks Using Honesty, Integrity and Respect GAB Code of Conduct

Transcription

1 Brewing Great Moments with Great Drinks Using Honesty, Integrity and Respect GAB Code of Conduct 1

2 1. Our Way 1.1 Our Vision, Mission & Values Our Vision: GAB is Malaysia s Most Celebrated Drinks Company Our Mission: Brewing great moments with great drinks Our Values: We have a Passion for Winning: o At GAB, we are focused on our business goals and we understand the role each of us plays in driving the Company towards achieving those goals. We Value and Respect Each Other: o We are a team of professionals, always conducting ourselves in a manner befitting a representative of GAB. We show Integrity in everything that we do: o Our actions and attitude at work are strongly tied to our values and we all have a responsibility to protect GAB s reputation by always following the code. We are committed to Service Excellence: o We take ownership of our actions, always doing what is necessary and right. We provide Enjoyment: o We brew great moments with complete honesty, integrity and respect. 1.2 Why must we have a Code of Conduct? This Code is formulated based on the guiding principles of GAB s philosophy in conducting business, rightly referred to as What We Stand for: GAB s Vision, Mission and Values. The Code comprises a set of shared values and work habits that are at the heart of our business. We strive to demonstrate the highest standards of integrity in the way we behave towards each other and to those outside of the Company. Our actions and interactions with our consumers, customers, employees, Government, suppliers, shareholders and other stakeholders should clearly reflect our commitment to doing the right thing. Reputation is critical to our commercial success and can only be enhanced by behaviours of which we can all be proud of. 1.3 Who must follow the Code of Conduct? All employees of GAB are expected to abide by the Code in letter and spirit. The Code also applies to contractors, consultants, suppliers, partners and others who do business with us. We recognise that the principles and practices described in this Code are general and not exhaustive, and urge any employees in doubt to contact your line manager or the respective policy owners (refer to Contact List on page 23). Breaching the Code, policies or procedures may have serious consequences for the Company and for each of us as individuals. Those who fail to follow the Code put themselves, their colleagues and GAB at risk. This is taken very seriously and will result in disciplinary action which may mean dismissal. 2

3 1.4 What is the difference between the Code of Conduct and GAB s Policies? The Code of Conduct is a guide to the values and behaviours that we are all expected to practise in our day-to-day life at GAB. This includes adherence to local laws and regulations, as well as the laws and regulations of any location where we do business Policies are business principles and protocol that apply to all employees. 1.5 Why are you responsible for compliance & ethics? Each GAB employee is responsible for compliance with the Code, in addition to all laws, regulations and industry standards. The Company places its trust in each of us to act in a way which is not only compliant but which supports our values and business principles. You are expected to work and act in accordance with the principles of the Code, relevant policies and procedures. If you are involved in retaining any such third party, it is your responsibility to ensure that they are made aware of the Code and our expectation that they act in accordance with its principles. 1.6 What is your role as a line manager? As a line manager, you must lead by example and act as a role model for those under your leadership. You must establish yourself as the go-to person for guidance, training and resources concerning conduct policy as well as compliance. You are positioned to create a culture of reporting and investigating any unlawful or unethical conduct. It is your duty to protect those who choose to step forward and raise issues, as well as maintain confidentiality of information shared. When you are working with third parties and acting on behalf of the Company, you must ensure that they are aware of the Code and meet our strict standards of compliance. 1.7 Who do I turn to if I have questions? When unclear or in doubt regarding the Code, your immediate manager serves as the first point of contact for clarification. If your immediate manager is not available or you prefer to speak to a third party, you may reach out to the respective policy owners (refer to Contact List on page 23). 1.8 How will I know if there is an issue? You will know it is not right when you have questions about a person s behaviour/actions, or have noticed something unusual from the way business is normally conducted. If you are unsure whether your concerns are valid, always seek advice from a manager. 1.9 How should I report if there is an issue? You may lodge a complaint in writing, via or complaint form and address it to your line manager, Head of Department or the Human Resources Department. You may also lodge a complaint via the SpeakUp hotline, website or (more information in Section 9 of this manual). Rest assured that all complaints will be treated in strictest confidence, under full anonymity. 3

4 2. Our People We have provided a guide to everyday behaviour to make your daily life in GAB as safe, productive and enjoyable as possible. The list includes day-to-day situations that explain how GAB s values are to be applied in all interactions and transactions Day-to-Day Behaviour All employees must follow Malaysian law at all times. This can be a complex issue so whenever you have questions, please speak to your line manager or the respective policy owners (refer to Contact List on page 23) No employee can force you to break laws, regulations or company policy. If you are given an instruction by an individual that breaks any law, regulation or policy, you should speak to your line manager or Head of Department, who can confidentially consult your line manager or you may speak to the respective policy owners (refer to Contact List on page 23). Here at GAB, we will not punish employees for reporting any violations or breach of law made in the best interests of the Company Our mission is to brew great moments with great drinks, and we do so with honesty, integrity and respect. As an individual and as part of the GAB team, we must always act with honesty, integrity and respect in all aspects of your work You are expected to represent GAB and not act in any way that would damage the reputation of GAB We understand that there must be flexibility surrounding local customs and practices that do not breach the law or our own policies. Please always inform your manager or relevant Head of Department when you need to practise flexibility At GAB, we must work together to brew great moments. Team work is highly prized and encouraged. You are each responsible for cultivating a great working environment for yourself and those around you Acting in an appropriate way at work covers a wide range of activities. Part of this is your dedication to meeting work performance targets, carrying out tasks as designated by a superior and creating the right environment that is conducive to you and others so that you may always work with honesty, integrity and respect. Disciplinary action is something we wish to avoid, but at times may be necessary when problems arise. Abide by all relevant laws and regulations at all times. Conduct yourself and the business in the right way. Work with agility, be bold in execution and succeed. If you do not do the right thing, and break the law, this can result in large fines, restrictions on the Company s standard operations, damage to our reputation, criminal prosecution against GAB and may result in dismissal for you. 4

5 2.2. Responsible Drinking We are ambassadors for our brands and are committed to promoting a culture of responsible drinking. Responsible drinking is at the heart of our business and we understand our duty to act as a role model for consumers. We are proud of the way we carry out our business and will not act in a way that damages GAB s reputation. We promote responsible drinking by: Setting standards for responsible marketing and innovation. Working with stakeholders and partners on initiatives to reduce alcohol related harm. Sharing what responsible drinking means and make related information easily available and accessible We should never allow alcohol to affect our performance at work or put others at risk. As part of our commitment to both safe and ethical work practice and responsible drinking habits, GAB has created some guidelines around responsible drinking practices An employee s performance at work should never be restricted by alcohol. You are responsible for ensuring that your alcohol consumption never threatens safety, breaches law or puts you or others at any type of risk You should not be forced to work with anyone who has consumed alcohol if you feel that they are putting you or others at risk. If you find yourself in that situation, immediately report it to your line manager or Head of Department. If you feel a co-worker is not performing their job well as a result of alcohol consumption, it should also be reported If you or anyone you know has trouble meeting the requirements of the alcohol policy, then we want to encourage you to seek professional advice and support. GAB is here to support you if you need this help Any conviction for drink driving, whether on company business or not, is a serious breach of GAB rules Employees are not obligated to drink as part of their work. It is a personal choice to do so When attending corporate functions or company evening promotions that may involve drinking alcohol, you or your line manager should ensure a designated driver is available. Alternatively, arrangements can be made for company funds to cover the cost of a taxi If you are caught in an unplanned drinking session for company matters or business on behalf of the company, you should take a taxi home and collect your car the following day. Otherwise someone who has not been drinking should drive you home or you may make the decision to stay the night locally Honesty, integrity and respect apply to drinking too. Remember this and follow the law. At all times, it is the responsibility of each individual to comply with the law. The law states that it is an offence to drive or even attempt to drive if a person s alcohol level is over 80 mg per 100 ml of blood Any breach of the alcohol policy may lead to disciplinary action including dismissal. 5

6 Read and follow GAB s Alcohol policy, which is available in the Document Depository Portal. Always demonstrate a responsible attitude towards drinking. Always obey alcohol related laws and never put yourself or others at risk by drinking and driving. Seek medical advice or counselling if you are dealing with an alcohol related problem Harassment & Discrimination You have the right to expect that your dignity and equal rights will be respected and you will be treated fairly GAB is committed to a free and fair workplace. Each employee is treated equally regardless of race, religion, age, disability, gender or marital status Honesty, integrity and respect should apply to how you treat your fellow workers. Harassment of any kind should be reported. If you are aware of discrimination, then contact Human Resources Department or make a report through the SpeakUp platform GAB will not influence your personal beliefs. As such, you must not use the work place to promote your own personal beliefs, be they political or religious. You may not use GAB funds to support these personal beliefs unless it is in accordance with Donation and Sponsorship Guidelines or if you have the prior consent of the Managing Director Sexual harassment of any kind may lead to serious disciplinary procedures. This includes both using your authority to harass a fellow employee and acting in such a way that you are offensive, hostile or intimidating to the recipient Where situations of sexual harassment occur, GAB will protect the rights of any employee who is a victim of such harassment. We will do this with confidentiality and respect. Any persons involved in a sexual harassment procedure must likewise respect this confidentiality. If in doubt, please contact your line manager or Head of Department. Ensure you never discriminate against any individual or group based on factors that are irrelevant to their ability to do their job. Never engage in any form of harassment or abuse, or behave in a way that could be viewed as offensive, intimidating, malicious or insulting. Make sure that our business partners are aware of our commitment to diversity and equal opportunity Privacy & Confidentiality You must always respect the confidential nature of any personal data that you handle and protect it. This includes data about current, past and potential employees, customers, suppliers, consumers and other individuals. This information may be held in systems, Human Resource systems and marketing databases. 6

7 Personal data which we hold must only ever be used for GAB business purposes Any confidential information you gain through your work must not be shared with others or used for personal gain The scope for confidential information is wide. Broadly speaking, you should not reveal any information that you have access to as a result of your job, if you would not have access to this information by other means. This includes details of wages or personal circumstances of fellow employees. This applies even after you have left employment with GAB You must ensure that you do not provide confidential information to friends or family, including when using social media or other online platforms To prevent insider trading, it is important not to reveal insider information (such as the company s new products prior to launch) to anyone you might reasonably know to have a stake in this knowledge, or the ability to use it for gain. Ensure all personal data for which you are responsible is fairly and lawfully obtained and managed. Comply with our Personal Data Protection policy. Stop and ask yourself if it is really necessary before copying or circulating personal data. 7

8 3. Our Consumers What our consumers think of our brand and reputation is important. We must never put our brand and products in a negative light. Here is a guide on how to protect GAB s reputation at all times Brand Integrity Our mission is to brew great moments with great drinks; you are a part of that. The quality and image of our brands are incredibly important, and you are an important part of upholding that image It is especially important to maintain the safety and quality of GAB s products. This means not letting others take advantage of the good reputation we have worked so hard to build. It is essential that you take all steps available to prevent others from exploiting our name and that of our products Our trademarks, copyrights, patents, trade secrets and domain names are our assets and must be protected. Infringing products are those that lead people to mistakenly believe they are GAB products (e.g. they have similar names, logos, packaging shapes or designs). Counterfeit products are products that falsely claim to be GAB products If you learn of any person or party copying or exploiting our brands or products, or know of any safety or quality issues with our products, you should report it to your supervisor as soon as possible. (Any knowledge of person(s) or entity copying or exploiting any unique aspect of GAB s brands should immediately be reported to GAB s Corporate Relations & Legal Department). Report any suspected counterfeit or product infringement to your line manager or speak directly to the Corporate Relations & Legal Department or Internal Audit Department. Consult the Corporate Relations & Legal Department to ensure proper contracts are in place to safeguard confidential information and intellectual property rights when you work with suppliers who are creating intellectual property on our behalf Product Quality Product quality and safety are among the most important aspects of our business. You must do everything you can in your position at GAB to ensure that we maintain a safe and high quality product Customers want products of the highest safety and quality standards. They want to know that when they select GAB products, they can rely on us to brew great moments with great drinks The quality and image of our brands are incredibly important, and you are an important part of upholding that image If you know of any safety or quality issues with our products, you should report it to your supervisor as soon as possible. 8

9 Do everything you can in your position at GAB to ensure that we maintain safe and high quality products. Ensure that our brands and products are safe for our employees, customers and consumers. If you know of any safety or quality issues with our products, you should report it to your line manager as soon as possible Responsible Marketing Brewing great moments with great drinks using honesty, integrity and respect that is what we do. As we strive towards being Malaysia s most celebrated drinks company, we have a responsibility to achieve utmost standard in our marketing communications too We want GAB s marketing and promotional activities to be recognised as the best in the country To ensure that our marketing and promotional activities enhance our reputation, we must make sure we advertise and market our brand responsibly. Apply the Marketing and Digital code to all activities that communicate about and market our brands. Ensure all marketing activities are in keeping with both the letter and spirit of our local laws. Ensure third parties engaged in marketing and promotional activities on GAB s behalf apply the Marketing and Digital code. 9

10 4. Our Business Partners GAB has many business partners from vendors and distributors to outlet owners. Hence, it is important that we understand what is expected and how we should be behaving in such interactions. We understand that at times the expectations from our culture and society may seem to be in conflict with GAB s own policies and expectations in these cases, please contact your line manager / Head of Department for clarification immediately Conflicts of interest Your personal interest should never interfere with your loyalty to GAB. Where your personal, social, financial or political activities could interfere with your loyalty to GAB, a conflict of interest may exist Even the appearance of a conflict of interest can be damaging or potentially lead to a hostile working environment. Conflicts can arise in many ways: If you or a relative is involved with a customer, supplier, or relative this might cause a conflict. Using company assets inappropriately could also be seen as a conflict of interest. Most conflicts can be resolved in an acceptable way for both you and GAB As an employee of GAB, you must never take part in any business activity that may conflict with GAB s business activity. This means any business which may lead to personal gain for you or your family. If you are unsure, then any interest you may have should be declared in writing You should not use your own influence to arrange business for a friend or family through GAB. This is, of course, unless the business is in the best interest of GAB and you yourself have no financial interest in the business of your friend or family. Please approach the line manager to get clearance before proceeding with this business Any situation that would be a conflict of interest for you would also constitute a conflict of interest for a family member If in doubt with regard to a possible conflict of interest, you should speak to your line manager When working with business partners, the manager responsible for those instructions should seek to advise said partner of our Code of Conduct and how it might impact our work together. Think about your situation and whether there is anything which could cause a conflict of interest. Avoid situations where a conflict of personal interest may arise. Never use your position for personal benefit or to benefit your family member. Disclose any or potential conflicts of interest to your line manager in writing and Control Compliance & Ethics team if you have a situation or potential situation of conflict of interest. Keep a record of any conflicts of interest that you have notified and any agreed actions. Safeguard GAB property and technology and do not use it irresponsibly or for your personal use. 10

11 4.2. Gifts & Entertainment Under no circumstances are you allowed to receive gifts in the form of cash or financial securities, regardless of amount Giving and receiving gifts and entertainment is an accepted part of building business relationships. However, they should not be used as a means of gaining personal influence. You must never give or receive gifts of a significant value. If in doubt, speak to your line manager Generally GAB discourages the acceptance of gifts, except where there is a business purpose Always consider whether accepting these gifts could imply an obligation and be aware that other organisations our business partners work for may have different rules on gifts from our own Any and all gifts given or received must be recorded. Please refer to Gifts & Entertainment policy for all gifts and entertainment, regardless of recipient. (Ensure details of all gifts and entertainment received from or given to any Government official are recorded on a Gifts & Entertainment Register, irrespective of the value. The Gifts & Entertainment Register is maintained by each Department and/or Region Office Pre-approved limits for gifts or entertainment that may be given to or paid for on behalf of any Government officials are as follows: All Department Budget Holders RM 1,200 per annum. As a guidance, the amount incurred should not exceed RM500 per occasion Government officials: Obtain prior written approval from the before providing gifts, entertainment or sponsorship to any Government, public or military official on behalf of GAB. Keep transparent and accurate records of all gifts and entertainment in the register if you give or receive from Government officials. Gifting: Obtain your line manager s prior written approval if, in a financial year, the value of the gifts you intend to offer or receive will exceed RM500. Always consider whether the gift being given or received could lead to or imply any obligation. Entertainment: Obtain your line manager s prior approval before accepting or offering any entertainment that could be regarded as excessive. Read and follow our Gifts & Entertainment policy Competition Law Competition law is as important as any of our other legal requirements. You are responsible for understanding this law as it relates to your work. Any breach by you may results in a fine to the Company and compromise our policy of honesty, integrity and respect. Employees must familiarise themselves with and always follow all guidelines, policies and directives issued by GAB from time to time regarding compliance with the Malaysian Competition Act ( Act ) You are required to comply with all laws intended to protect and promote competition. 11

12 This Competition law regulates how you deal with third parties, including competitors, customers and distributors You must not discuss our products, prices or share information with our competitors. Likewise, you must not request customers to show you proposals from our competitors It is important you do not provide competitive information to customers, particularly relating to business arrangements we have with other customers If you are put in a situation during a meeting or event where competitively sensitive information is discussed, you should object and leave immediately. This should then be reported You should not agree to any exclusive business arrangements on behalf of GAB without prior approval from your respective manager, superior or Head of Department who may then refer the matter to GAB s Management or Corporate Relations & Legal Department for approval. Where applicable, please refer to the relevant policies and procedures if there are any exclusive business arrangements made on behalf of GAB Be aware of how you say things with regard to competition law. You should never use language that may be in breach of this law If you have any questions about competition law, please speak to your manager. Ensure you understand and follow the law. If in doubt, speak to the Legal team. Dealing with Competitors Never agree or come to any understanding to: fix prices, divide up markets, set production levels or refuse to deal with particular customers or suppliers. Never discuss details of: pricing, trading terms, sales & strategy, production. Inform Legal whenever a competitor attempts to discuss or share information on any of these issues. Dealing with Customers Never discuss with a customer: the terms of another, or details of another customer s resale pricing. Never agree with one customer that you will try to encourage another customer to increase or decrease its resale price. Never use customers to pass commercially sensitive information to competitors. Never extract commercially sensitive information from customers. 12

13 5. Our Government Below are guidelines to help you uphold GAB s reputation as a respectable brand and company that succeeds on merit through efforts made by its people, especially for interactions with the Government and its representatives. In keeping with our principles of honesty, integrity and respect, we also define our expectations for your personal political activity and beliefs Bribery, Corruption & Fraud GAB will not condone, under any circumstances the offering or receiving of bribes. This includes payments known as facilitation payments Bribery is illegal under Malaysian law. Breaking these laws may result in severe penalties (including prison sentences) for the company and individuals involved You must not at any time for any reason offer or receive bribes from any person including Government officials. This means nothing should be given, or promised to be given, to gain or provide influence or business advantage You should be particularly careful of the rules around giving or receiving gifts with Government officials. This must be done with prior approval from the line manager. All gifts given and/or received must be recorded Pre-approved limits for gifts or entertainment that may be given to or paid for on behalf of any Government officials are as follows: All Department Budget Holders RM 1,200 per annum. As a guide, the amount incurred should not exceed RM500 per occasion Fraud is an act for personal gain that causes loss or damage to GAB. Fraud can include gaining advantage for others as well as for yourself. Any such activities should be reported immediately. Never offer, promise or give bribes or make any other form of improper payments with the intention of obtaining an advantage for GAB. Be extremely careful when you deal with Government, military or other public officials. Get the written approval of the before giving anything to or paying for anything on behalf of any such official. If your job requires you to provide entertainment or gifts to Government officials, please obtain the necessary pre-approval and note the limits: o < RM500 Head of Department to pre-approve o > RM500 per occasion pre-approval from Head of Department and Corporate Relations & Legal Director o > RM1,200 in total expenditure of gifts to Government per annum seek approval from All pre-approvals must be in writing and recorded in the prescribed Department Register. Before engaging any third party to act on GAB s behalf, check their background by conducting due diligence. The third party is not allowed to give or offer bribes. 13

14 5.2. Political Activity GAB does not look to influence your personal beliefs. As such, you may not use the work place to promote your own personal beliefs, be they political or religious. Any activity intended requires prior approval by the Managing Director You should not engage, on GAB s behalf, with Government or political organisations or individuals, without prior approval This applies to your dealings with Governments, public interest groups, industry associations and a broad range of other bodies Everyone has the right to participate as an individual in political activities but these must be kept separate from your work at GAB GAB will not involve itself in any political or religious activity that incites extremism or undermines cultural diversity and equal opportunity. Talk to the Corporate Relations & Legal Department before engaging in any GAB business with regulators, legislators, political candidates, Government employees or public interest groups. Never make payments to political parties on candidates on GAB s behalf without prior approval from the. Keep personal political activities separate from work activities, and ensure it cannot be open to misinterpretation that it is undertaken on GAB s behalf Money Laundering Money laundering is the criminal practice of filtering money: It usually goes through a complex series of transactions to clean the funds and give the impression it comes from legitimate sources. Making sure we have up to date and accurate information on our customers is critical to ensuring we are not used by a third party to launder money You must have Know your Customer procedures to determine the identity and legitimate operations of customers, and maintain procedures to prevent acceptance of suspicious payments. Knowing your customer is a continuous process and, as a minimum, customer data must be reviewed once a year You need to be vigilant of circumstances that may indicate improper transactions or what are referred to as red flags. These would include occasions when a customer is unwilling to provide personal or business background information, wishes to receive or disburse funds into or from multiple accounts, wishes to pay with large amounts of cash or appears unconcerned with price, commissions or other transaction costs It is GAB s policy not to accept any cash payment for goods or third party payment. Payments from customers must be drawn on bank accounts titled in the name of the invoiced customer Similarly, it is GAB s policy that any payment by GAB to a vendor, supplier or customer must be made to a bank account titled in the name of the contracted vendor, supplier or customer. 14

15 You must abide by Anti-Money Laundering Act and follow the Know Your Customer procedures. Look out for signs of potential money laundering, such as customers or suppliers who are unwilling to provide us with requested information or want to pay you with large amounts of cash. Do not accept payment of third party cheques or cash from customers. Any payment to suppliers must be made to a business bank account. Look out for any sudden or unusual changes in customers or suppliers details or circumstances and inform the Corporate Relations & Legal or Finance team. 15

16 6. Our Community We must always keep in mind what it means to be a responsible member of the community from the people who live and work around us, to the people we do business with, and finally the environment in which we operate. It is our duty to respect and engage our community whilst doing our best to protect the environment to ensure a sustainable future for all Engaging the community GAB is a company that does the right thing for the communities we operate in. We care for the people around us and actively support a variety of community organisations We believe that the communities in which we operate should benefit from us being there All charitable contributions must be transparent, and we must only give to bona fide charities ensuring our donations are only used for charitable purposes. Follow the procedures for charitable contributions; when in doubt seek advice from the Corporate Relations & Legal Team. Obtain any required approvals before agreeing to make a donation. Donations to Government officials must be approved in advance by the Corporate Relations & Legal Director. Record charitable contributions in the relevant GAB accounting system Caring for the environment GAB strives to constantly reduce the impact of our activities on the environment: We aim to comply with the spirit as well as the letter of the law with regards to the environment. We consider the potential environmental impact of every major business decision we take. We will aim to reduce our environmental impact in using resources efficiently, transport planning, and reducing waste and emissions Please be aware of your environment and carry out your work and our business in the most environmentally friendly way possible. Support any environmental initiatives being undertaken by GAB. Challenge unsustainable activities if they occur e.g. wasteful use of water and other natural resources, failure to consider environmental impacts in business decisions. For further information see our Environment Policy. 16

17 7. Our Workplace We want all our employees to be safe, and we rely on you to protect yourselves, each other and company property Health & Safety GAB takes all practical steps to ensure that the premises where we work are secure and provide a zero accident environment You need to understand and follow health and safety laws, regulations and standards that apply to where you work Always challenge any behaviours which you see and you think are unsafe. Refresh your knowledge of the emergency procedures at GAB We want GAB to be a safe environment for you to work in, and for that we need your help You are expected to follow all health and safety requirements relating to your work. This includes informing any customers or visitors to our site and helping them to follow these rules also. Suggestions for improving these requirements are always welcome. Follow the Occupational Health & Safety procedure. Ensure you are fully trained to safely carry out your role. Understand the risks associated with your job and those of your colleagues, and work together to manage these responsibly. Make sure you and your colleagues know what to do if an emergency occurs at work. If you are aware of any situation that breaches our health and safety rules, please alert the Human Resources Department or the Site Services Manager immediately Information Management & Security GAB s information is critical to everything we do. From the s and conversations we have, to our advertisements and marketing collateral, information is a valuable company asset which we must protect and manage effectively. Failure to do so may impact our brands, revenues and reputation and impact on our ability to operate effectively You must take reasonable steps to prevent unauthorised access to information you are responsible for or entrusted with, by keeping your user IDs secure, creating strong passwords and using systems responsibly. You should also protect GAB s information assets from accidental or unauthorised disclosure and classify all information not in the public domain The information you create and hold should be accurate, well organised and easy to access. We should take particular care when people join, move or leave the Company that their information access requirements are correctly provided, changed or removed. 17

18 GAB may monitor aspects of its computer systems, including Internet activity. To the extent allowable by applicable law, GAB has the right to inspect all material stored on its computer systems We are required by laws, regulations and for business purposes to keep certain types of information for specific periods of time and these requirements are set out in our retention schedules which we must follow Occasionally, we need to suspend the normal disposal of specific information because it might be relevant to pending or on-going litigation, regulatory or tax investigation, often described as legal hold. When this happens, legal department will notify those holding the information and they must comply with the instructions received. Keep your user names and passwords private, and only use hardware and software that has been approved by IT. Manage sensitive and classified information with care; keep it protected, and dispose of it securely. Keep information you create or are responsible for, organised, identifiable and accessible. Be familiar with and apply the relevant retention schedules for your area of the business Company Assets Various office equipment and assets, such as telephones, mail services and supplies, have been purchased to assist GAB in carrying out our business. Please use these with the honesty, integrity and respect we expect you to conduct yourself with in all aspects of your work GAB wants to maintain a friendly and co-operative work environment. As such, the occasional use of these items for personal reasons is understandable and accepted where it does not interfere with business needs. Please do not abuse this privilege. Any such abuse could lead to disciplinary action. Use office equipment and assets only for official GAB purposes. Take care when handling GAB office equipment and assets in order to protect and preserve the items. If absolutely unavoidable, you may use GAB assets for personal reasons but please keep such use to a minimum and ensure it does not interfere with business needs. Never use GAB equipment or assets for any reasons that are illegal or unethical. 18

19 8. Our Reporting As we all have access to and provide important information in our daily tasks, we have provided guidelines to help you manage the information responsibly. It is key to our business that all information provided to GAB and by any representative of GAB are true, complete and accurate at all times Accurate Reporting Record-keeping is an important part of running our business honestly. You must ensure that you maintain accurate records of all transactions and contracts, including the relevant authorisations. o Any data, information or records which we create must be correct and accurate. This includes our travel and expense claims. o Any activity that inflates or shifts sales or profit between reporting periods leads to inaccurate reports and is unacceptable All information provided to Government authorities and GAB auditors must be accurate, complete and not misleading All company accounting records and the reports produced from those records must be kept and presented in accordance with all applicable laws and relevant accounting standards Maintaining accurate records is a vital part of honesty, integrity and respect. All information supplied to our auditors must be accurate, complete and not misleading in order to help maintain this honesty and integrity. Make sure any data or information you are responsible for is complete and accurate. Make sure your travel and expense claims are accurate and relate to legitimate business expense. Read the Authorisation Policy and Procurement Policy for your function and ensure that any contractual commitments you make on behalf of GAB are within the scope of what you are permitted to do. Report any potential fraud or misrepresentation of GAB accounts, records or data Insider Information Trading of GAB securities on the basis of inside information is a criminal offence: o Inside information is information about any listed company which is not generally available to the public and could affect the market price of the company s securities (stock or bonds). o Trading on the basis of inside information or misuse of inside information could result in civil or criminal sanctions against both the Company and the individual concerned You must ensure that you do not provide commercially viable information that is not publicly available to friends or family, including when using social media or other online platforms. This means you should not knowingly be involved in any business account relating to a friend or family member. 19

20 It is also important not to reveal insider information to anyone you might reasonably know to have a stake in this knowledge, or the ability to use it for gain We are committed to clear communication. If you receive any requests for information from members of the public or journalists, you should refer them to the Company Secretary of GAB If you are contacted for a non-regular request by a Government agency seeking an interview or information, you should advise that we at GAB take our legal obligations seriously, and then refer the caller to the Corporate Relations & Legal Department. All such situations must be reported. Never use or share information which is not publicly known to inform decisions about buying and/or selling GAB securities. Never spread false information which could manipulate the price of securities. Check with Company Secretary if you intend to deal in GAB securities. If you are uncertain as to whether you are in possession of insider information or other information of price sensitive nature about GAB, you should contact the Company Secretary. 20

21 9. Your Right to Speak Up We value each of you as members of GAB, and take your opinions and concerns seriously. We believe that as a responsible corporation, we must provide the necessary platforms for you to voice opinions and concerns relating to GAB without consequence The most important part in maintaining a culture of honesty, integrity and respect is your freedom to Speak Up. If you suspect or witness a breach of this code or any laws or regulations relating to GAB s business, you should report this via the SpeakUp platform. It is a confidential service run by an independent third party for GAB employees to raise any concerns in complete confidentiality (and, if need be, total anonymity). As we encourage a culture of honesty, there will be no reprisal or punishment to those who use SpeakUp for genuine concerns This system of reporting should not be abused. We take a serious view of anyone who maliciously spreads false information or raises trivial complaints As with all complaints, any reporting of breaches of codes or laws will be kept confidential. Always report promptly any potential or actual breaches of the Code, policies or standards to your line manager, Control Compliance & Ethics, Internal Audit, Corporate Relations & Legal or HR Department or use the SpeakUp platform. If in doubt, please ask for help and guidance from your manager or the Corporate Relations & Legal team. For more information, please refer to the SpeakUp policy. 21

22 10. Recap: Key Messages & Contact List Key Messages Our Vision: GAB is Malaysia s Most Celebrated Drinks Company Our Mission: Brewing great moments with great drinks Our Values: We have a Passion for Winning: o At GAB, we are focused on our business goals and we understand the role each of us plays in driving the company towards achieving those goals. We Value and Respect Each Other: o We are a team of professionals, always conducting ourselves in a manner befitting a representative of GAB. We show Integrity in everything that we do: o Our actions and attitude at work are strongly tied to our values and we all have a responsibility to protect GAB s reputation by always following the code. We are committed to Service Excellence: o We take ownership of our actions, always doing what is necessary and right. We provide Enjoyment: o We brew great moments with complete honesty, integrity and respect. 22

23 10.2. Contact List Sections Content Policy Owner Our People Day-to-Day Behaviour Human Resources Director Sensible Drinking Harassment & Discrimination Human Resources Director Privacy & Confidentially Our Consumers Brand Protection Product Quality Supply Chain Director Responsible Marketing Marketing Director Our Business Partners Conflicts of Interest Human Resources Director Gifts & Entertainment Competition Law Our Government Bribery & Corruption Political Activity Money Laundering Finance Director Our Community Engaging Community Caring for the Environment Supply Chain Director Our Workplace Health & Safety Supply Chain Director Information Management & Security Finance Director Our Reporting Accurate Reporting Finance Director Insider Information Sections Content Content Owner Our People Day-to-Day Behaviour Human Resources Director Sensible Drinking Harassment & Discrimination Human Resources Director Privacy & Confidentially Our Consumers Brand Protection Product Quality Supply Chain Director Responsible Marketing Marketing Director Our Business Partners Conflicts of Interest Human Resources Director Gifts & Entertainment Competition Law Our Government Bribery & Corruption Political Activity Money Laundering Finance Director Our Community Engaging Community Caring for the Environment Supply Chain Director Our Workplace Health & Safety Supply Chain Director Information Management & Security Finance Director Our Reporting Accurate Reporting Finance Director Insider Information 23