CODE OF BUSINESS CONDUCT - AIRB

CODEOF

BUSINESSCONDUCT

ALIRAN IHSAN RESOURCES BERHAD

First Release 2021

GlossaryBreach of Code of Business Conduct

External Business Engagement

Records Integrity and ConfidentialityUnethical PracticesConflict of InterestWork Place

Values

Introduction of Our Code of Business

Conduct

CONTENTSIntroduction of Our Code of Business Conduct

A Message From Adam Saffian Ghazali

Overview

Framework

Objectives

Employee’s Value

Employee’s Responsibilities

1

2

3

3

3

3

Conflict of InterestGeneral Rules

Be Transparent

Outside Hiring

Involvement of Family Members

External Activities

Personal Transaction with company’s

client, supplier and vendor

6

7

7

8

8

8

Work Place ValuesRespect

Fair & Equality

Bullying

Sexual Harassment

Substance Abuse

4

4

5

5

5

Records Integrity and Confidentiality

General Rules 13

Unethical PracticesMisuse Equipment for Personal Use

Bribery & Corruption

Gift Policy

Entertainment Policy

Comply to LOA

Acknowledge

Asking for Favour

Complicity & Accusation

10

10

11

11

12

12

12

12

External Business EngagementGeneral Rules

Insider Trading

Accountable Marketing

Political Activities

Association with Outsiders(Media/Investors/Analysts)

14

15

16

17

18

Breach of Code of Business Conduct

General Rules 19

Glossary 20

A Message from Adam Saffian Ghazali

Ethics values have always been at the core of Aliran Ihsan Resources Berhad (AIRB) strategy anddevelopment. This code reflects what we value as professionals and establishes expectations forwork based on principles of duty, accountability, fairness, and responsibility.

This Code of Business Conduct is a framework and focused guide for employees in support of day-to-day decision making related to professional conduct. The Code is partly obligatory anddisciplinary and partly aspirational and descriptive in that it defines the employees’ role.

The preservation of the highest standards of integrity and ethical principles is vital to theresponsible discharge of obligations by employees and is necessary in order to achieve ourambition to be the leader in the water and wastewater industry.

This Code of Business Conduct also sets forth the fundamental principles and rules consideredessential to this purpose and is to all AIRB’s employees.

It is crucial that all employees fully comply with the Code. I expect each of you to refer to thiscode and to ensure that it is complied with, in order to contribute together to the success of theCompany.

Thank you,A S G

1 | ALIRAN IHSAN RESOURCES BERHADCODE OF BUSINESS CONDUCT

Introduction of Our Code of Business Conduct

Work Place Values

Conflict of Interest

Unethical Practices




Glossary


OVERVIEW

Aliran Ihsan Resources Berhad (AIRB) has leading in water andwastewater business in Malaysia with interest in water treatment –from operations, maintenance and rehabilitation of water facilities totreatment of water.

As AIRB is a wholly owned subsidiary of MMC Corporation Berhad, wealso adopt the MMC’s Code of Ethics as a guide for our employees tocommit and help us to drive the values of integrity, honesty,professionalism, responsibility and pioneering into practice.

Our Code of Business Conduct plays a key role in setting out how weseek to ensure compliance with laws and regulations to protect ourreputation and also to prevent harm to people and the environment.

The Code provides a comprehensive framework of “The Do’s” and “TheDont’s’ designed to be readily applied by all includes Directors,employees and other stakeholders in their day-to-day work. They aremandatory for all employees and others working for AIRB and apply toall its subsidiaries, and our Group’s Board of Directors, MMCCorporation Berhad, and also which AIRB has management control.

FRAMEWORKThis code applies to all Employees (Executive and Non-Executive) of AliranIhsan Resources Berhad (“Company” or “AIRB”) and its subsidiaries known asAliran Utilities Sdn. Bhd.(AUT), Aliran Utara Sdn. Bhd. (AUSB), Aliran WaterServices Sdn. Bhd. (AWS), and SWESB MMCES JV Sdn. Bhd. (SWE-JV) (“AIRBGroup”).Our external partners such as vendors, contractors, consultants and clientsAIRB has no management control are not applicable but they are encouragedto implement the code.

OBJECTIVEThe objective of this code is to set out a clear, transparent and standard codeof business conduct required for all our employees. It is to ensure the businesscontinuity is fully aligned with our core values, mission and vision that areapplicable to the country and MMC’s laws and regulations.

EMPLOYEE’SVALUES

Assurance of quality and reliability, Practice the business ethics integrity, Risk-based thinking towards opportunity and Be proactive.

EMPLOYEE’SRESPONSIBILITY

It is the duty and responsibility for the employees to hold the company’s valueand practise good ethics in order to ensure a healthy, happy workenvironment. Employees shall take an ownership of every duty given with fullresponsible and propriety aligned with the Code of Business Conduct at alltimes to reflect the good standing of the image and reputation of theCompany.3 | ALIRAN IHSAN RESOURCES BERHAD

CODE OF BUSINESS CONDUCT


Work Place Values


Unethical Practices




Glossary


WORK PLACE VALUESIntroduction of Our Code of Business Conduct

Work Place Values


Unethical Practices




Glossary

Employee Shall :

RespectEach of employees shall be responsibleto respect other’s privacy, dignity,choice, human rights, and treateveryone equally because we work indiversity backgrounds where multipleraces and religions work together todrive the business.

Fair and EqualityTreat colleagues, co-workers, superiorsand everyone in the workplace includesub-contractors, clients andstakeholders with the same respect weexpect to receive in return withoutdiscrimination, fairly and equally withrespect, regardless their gender,orientation, marital status, race, age,skin colour, disability and also politicalviews.

A happy work place and positiveenvironment cultivate a productiveimpact in employees. This is what AIRBpractises and dedicated to provide asafe, happy work place for everyonebecause we believe happy employeesare more innovative and productive.

Works can be stressful and tensesometimes, so it is important for thecompany to hold this code for businessgrowth and development. Hence, thiscode of business conduct sets outemployees to promote the diversity andpractise no unlawful discrimination orvictimisation when dealing business.

AIRB clearly states in code’s work placevalues that company practises businessethics’ integrity and all employees willbe treated with respect and dignity. Anyabusive conducts and mistreatment willnot be tolerated.

AIRB believes that fair and equaltreatment to all employees andstakeholders lead a healthycompetitive environment and fostera progressive improvement onemployee’s performance. This alsoincludes consideration forrecruitment, promotion, reward andbenefits shall be made based onemployee’s performance withoutprejudice and favouritism.

Managers, Superiors and Supervisorsare always reminded to be tolerantwith co-workers and employees.

Make communication as a priorityand always be present and reachableduring working hour, either throughemail, phone calls and virtualmeetings as communication is thekey of successful understanding andcompetency.


WORK PLACE VALUES(…cont’d)


Work Place Values


Unethical Practices




Glossary

Physical

Hitting, pushing or any physical assaultacts that is not limited to incidents thatmight occur. Physical bullying alsoincludes cause of damage to person’sproperty.

Act of Exclusion

Isolate someone from work-relatedactivities or exclude them socially.

Belittling someone’s opinion. Cold treat and make them feel

invisible.

Sexual Harassment

Employee strictly prohibits sexualharassment of any kind that is consideredas sexual assault, includes an act ofbehaviour either physically, verbally orgestures.

Employee Shall Not :

BullyingBullying is considered as an abusiveconduct that can affect victim’semotional, social life and lead todistress.

Bullying includes verbal, physical, andact of exclusion that are repeated overtime.

Verbal

Discriminate, humiliate, threats,insult and make jokes on a person’sbackground, orientation, physicalappearance and any offensiveremarks that is hurtful andpsychologically insulting.

Constantly criticize, yelling andexcessive performance monitoringalso considered as bullying.

Verbal assault frequently caused ofoffense, insulting sounds/words,rude jokes or humiliation regardingsex, race, orientation, appearance,marital status or any negativestereotyping.

Physical assault includes any act orgesture of unwanted physical contactthat creates an intimidating andoffensive environment. Distributionof explicit media graphics alsoconsidered as harassment.

Substance Abuse

Abuse / misuse / consume drugs andexcessive alcohol, except prescribedby the certified medical practitioner,are strictly prohibited to beconsumed.

Employee also are prohibited tosupply, distribute or sell alcohol anddrugs within the AIRB’s premises, orto influence other to consume


Work Place Values


Unethical Practices




Glossary


CONFLICT OF

INTEREST

A situation can be recognized as a conflict of interest when anemployee allows their actual, perceived or potential personal, eitherfinancial or non-financial interests to influence their objectivity whenperforming job at AIRB. It is vital for an employee to avoid anysituation that may lead to a conflict of interest when the employeepersonal interest indicates unfavourably on the employee’s integrity orto be in conflict with the company’s interest.

The company’s effectiveness and reputation will suffer a significantnegative impact towards its business and people when such situationoccurred.

When making business decisions or judgements, employees areanticipated to make in the best interest of AIRB and avoid at all timebeing in a situation of conflict.


CONFLICT OF INTEREST(…cont’d)


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Glossary

Employee Shall :

Be Transparent

To emulate the process outlined in the company toimmediately disclose an actual, perceived or potentialconflict of interest to manage when the situationoccurred.

To follow the same process if there is an interest intaking up a proposed directorship (in a personalcapacity) in any other organization, regardless not-for-profit or commercial as well as roles for public bodies orin trade associations.

Employee may have external commitments but not:

To derogate an employee from their actualcommitment and contribution to AIRB.

To offer access to sensitive information relating toactual or potential AIRB competitors.

To create any responsibility for AIRB when take up aposition on his/her personal basis.

Employee Shall Not:

Outside Hiring

To accept position of responsibility or holding asubstantial interest in any competitor Company.

To participate in any other company or in a managementposition and capacity for or as a consultant to anyorganization or firm.

To employ, contract or engage any person ororganization without verifying they are free of conflict ofinterest with AIRB.

To undertake an employee’s immediate family memberof membership on the board of directors of anyorganization which is or is going into business with theCompany or as a consultant or adviser to any such boardof directors or to the management of a firm, person ororganization which is or is going into the same businessas the Company.


CONFLICT OF INTEREST(…cont’d)


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Glossary

External Activities

To take, or divert to others, any businessopportunities that arise in the course ofdoing their job at AIRB that could be ofinterest to AIRB.

To misuse his/her position to advancepersonal interests.

To have a direct or indirect competitionby an employee with the Companythrough outside business activities.

To lend and borrow money, guaranteeingdebts in lieu from licensed financialinstitutions or other licensed moneylenders or to accept extravagant gifts/benefits in any parties to put theemployee under a compulsion to thethird-party having business dealings withthe Company.

Involvement of Family Members

To provide preferential treatmenttowards his/her immediate familymember owning a substantial interestin any organization or firm, which has orcurrently seeking to conduct businessdealings with the Company.

To involve family members in decisionmaking process of a business activitywithin AIRB. An employee shall berequired to disclose their relationship ifthe situation arise.

To use the Company’s personnelequipment supplies or otherresources by an employee for his/herpersonal benefit differing to thepolicies and procedures of theCompany.

Personal Transaction with AIRBClients, Suppliers and Vendors

To put any favourable terms thanthose offered in public by anemployee in any transaction withAIRB’s clients, suppliers and vendor,directly or indirectly.


Work Place Values


Unethical Practices




Glossary


UNETHICALPRACTICES

Misuse Company Equipment for Personal Use

Company’s property is defined as any facilities, assets, work areas, hardware,internet, vehicles and equipment that are owned by AIRB and its subsidiaries.It is either in the custodial care of the company or by any employee that isappointed to take the responsibility of its ownership. Any company’s propertyis intended to be used for work and business purposes only.

Misuse of company’s property is usually related to personal use purposes.Excessive misuse for personal use can be threats to the company as it canimpact on employee’s performance, where employee that use company’sproperty for personal task during working time can lead to morale problems.It also potentially can cause property damage.

Company reserves the right to require employee to pay the cost to repair orreplace the missing / damaged property. Company also reserves the right toissue disciplinary act if employee is excessively abusing the equipment.



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Glossary

Bribery &Corruption

As our Group’s Company, MMC Corporation Berhad has zero tolerance towardsbribery and corruption, AIRB is also adhere to the laws and regulations. Thecompany is committed in doing business with integrity and avoid any actionsthat leads to bribery and corruption which may result in bad reputation.

Bribery includes the act of offering, giving, requesting, soliciting, receiving,promising or agreeing on something of value for the purpose of influencing anaction, especially in dealing with business tender, contract, procurement,appointment and gratifications.

GiftPolicy The purpose of this policy is only to establish a symbol of appreciation and

uniformity in the gifting culture within the organization and extendedstakeholders. All employees under AIRB shall ensure that any gift does notlead to an unfair competition, favoured treatment or has any conflicts ofinterest.


Work Place Values


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Glossary

EntertainmentPolicy

For any trips and entertainment conducted for the sake of company’sreputation, public and clients’ relations, employees shall refer to FinanceManager for approval.

For any hospitality (includes meal, accommodation, and transportation)employees being offered or to offer to stakeholders, employees need toensure hospitality is only accepted or offered that related to customerrelations such as event ceremony, festive occasions, and social parties.

Any hospitality offered that is intended or might be seen to influencebusiness decisions or create an obligation to do something in return,employees are advised to decline in order to avoid conflicts of interest.


UNETHICAL PRACTICES(…cont’d)

All expenses receipts are compulsory to berecorded and kept by employees forinspection or audit purposes.

Employee Shall Not :

Misuse Work Facilities

Using computer/laptop, Internet and/orany other properties that are owned bythe company for personal and non-business purposes during/after workingtime.

Using company’s vehicles without superior/ company’s consent. Any employee that isdriving company’s vehicle must beauthorized, and fully responsible on itscondition and safety. Employee shall reportand sign vehicle log as the log will be theevidence to support any inconvenience.

Asking for Favour

To accept or receive unreasonable value ofgift and present or any other favours whichare intended or might be seen to influencebusiness decisions.

Employee Shall :

Comply to LOA

The expenses shall according to Limits ofAuthority (LOA) given by MMCCorporation Berhad and subject toApproval’s Limit of Authority (LOA).

LOA Clause 12.0 Donation and CorporateGiftsCorporate Charitable Donations/Community Projects/ Sponsorships/Corporate Gift and HampersOnly up to RM 10,000 with CEO Approval

LOA Clause 13.0 Entertainment

Client or Business Parts (per transaction)Only up to RM 5,000 with CEO Approval

Acknowledge

Any gift received that is edible in natureshould be shared amongst all theemployees that present during that time.

In circumstances where the gift involvesgifts such as meals or trips, theemployees may accept this only with theprior permission of the CEO. However,such actions should not influencebusiness decisions.

To solicit any gift, presents, food,merchandise, vouchers, discount or moneyfrom any agencies, sub-contractors,vendors or clients with whom theemployees deal with on official basis.

Not to declare to CEO or management orHR when accepting or receiving gifts. Anygifts received shall be disclosed eitherverbally or via email prior approval.

Complicity and Accusation

Employee shall be considered as aaccomplice although he/she does notactually commit the crime as it has theelement of helping / encouraging someonecommit crime / unethical behaviour.

Do not remain silent when seeing otheremployee commit crime / unethicalbehaviour. Speak up, seek opinions and getperspective from higher position than the“doer” regarding the crime.

Make accusations without evidence andwitness. Employee is advised to talk tocolleagues to get perspective on thesituation and do not slander and makespeculation which can lead to defamationethic.12 | ALIRAN IHSAN RESOURCES BERHAD

CODE OF BUSINESS CONDUCT


Work Place Values


Unethical Practices




Glossary


Work Place Values


Unethical Practices




Glossary

RECORDSINTEGRITY & CONFIDENTIALITY

Records integrity is a critical issue in document governance. The integrity of recordscan be interpreted as the records are authentic and complete with no alteration, addedor deleted as it represents exactly as what as has created by the owner.

Confidentiality can be regarded as protection of personal information. In a businessperspective, confidential business information is any information that a business ownerwants to be kept as secret. Business confidential information carries economic benefitto business as well as the business owner.

Records integrity and confidentiality are one of AIRB’s most valuable business assets.Therefore, the Company is devoted to protect and safeguard the company’sinformation and any other information entrusted to AIRB.

Employee Shall :

To manage the Company’sinformation, document and record inaccordance with AIRB Control ofRecord.To use the confidential waste bin orcross-cut shredder in the companyworkspace for Company documentdisposal.

Employee Shall Not:

To disclose AIRB’s informationexternally to third parties unless inaccordance with MMC CorporateDisclosure Policies and Procedures2014.To use AIRB’s information for anythingother than a legitimate businesspurposes or as prerequisite by law.To share personal data andinformation of the Company to thethird parties unless in line withPersonal Data Protection Act 2012.



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Glossary

EXTERNALBUSINESS

ENGAGEMENT

External business engagement can be simply defined as businessoutside activities or any activities that being engaged by anemployee outside of their employment with the Company. It mayinclude anything from volunteer positions to positions of influence ina side business such as but not limited to service as an officer,director, employee or consultant with any profit or non-profitorganization.

AIRB and its employees need to demonstrate the same ethicalstandards when engaging with people externally as when dealingwith colleagues in the Company. Below are the important pointswithin the scope of external business engagement.



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Glossary

InsiderTrading

Any practice of transaction (purchasing or selling) a company’s securities while inpossession of material information that is not yet being exposed as public informationis considered as an Insider Trading.

Material information refers to any and all information that may result in a substantialimpact on the decision of a client, suppliers or vendor regarding whether to continuethe business engagement or not. An employee is prohibited.

Employee Shall :

Transparency

Employee shall be honourconfidentiality of all company’sinformation that they acquired duringand after his/her employment.

Faithfully and diligently performhis/her duty without any intention ormight be seen to influence businessdecisions or create an obligation to dosomething in return.

Employee Shall Not:

To involve in the practice of InsideTrading under the Capital Marketand Services Act 2007, CompaniesAct 1965, the Bursa MalaysiaSecurities Berhad Main MarketListing Requirements and otherrelevant laws and guidelines.

Dealing in Securities of theCompany.

Dealing in Customer of Suppliers’Securities.

Dealing in Merger/ AcquisitionSituations.



Work Place Values


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Glossary

AccountableMarketing

As a pioneer of water and wastewater related areas company, AIRB is committed toconduct business that is in line with the governing law and anticipate its businesspartners to adhere the similar principles and values that are consistent with theCompany.

A fair business competition needs to be empowered among the clients, suppliers orvendor to ensure an equitable competition between the parties involved.

Employee Shall :

Business Goals

To align business and marketing with acost and makes marketing effortsaccountable for leads and sales in thesame way a business development’semployee is accountable. It isimportant to set company’s goal,metrics, and direction to achievetargets in line with laws andregulation.

Employee Shall Not:

Non-involvement

To directly or indirectly agree, discussor exchange information with thecompetitors matters that relating to:

The price or terms of sale forproducts and/ or services anddemanded from suppliers.

The co-ordination or allocation ofbids or quotes.

Limitations on production or sales.



Work Place Values


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Glossary

PoliticalActivities

The participation of an employee in the political process is important. However, if anemployee intends to hold a position or responsibility in a political party, he/she isrequired to seek for the CEO’s office approval. Ultimately, an employee should separatebetween personal political activities and their responsibilities with AIRB from anyfuture misunderstandings and legal difficulties.

Employee Shall :

Professionalism

Employee has the right to involve inpolitics but it does not reflect thecompany’s principles and limit tocertain behaviour while on duty.

Employee Shall Not:

Influence

To create a conflict of interest,encourage or influent other employees’choice through their participation in thepolitical activities.



Work Place Values


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Glossary

Association with Outsiders

Association with Outsiders (Media/Investors/Analysts)

Any communication between the employees and the outside communityneed to be executed carefully. Only specific authorized individual maycommunicate or associate with outsiders including to respond to mediaenquiries.

It is advisable for the employee to comply with any conditions imposedby the Company as well as to seek consultation before he/she can deliverthe message. Employees shall not to associate/respond to enquiries,conversations or provide opinion from outsiders without authorization ofthe Company.


BREACH OF CODEOF BUSINESS CONDUCT


Work Place Values


Unethical Practices




Glossary

The disclosure or misuse ofconfidential information, document,trade secrets or breach of any of theprovision in the MMC CorporateDisclosure Policies and Procedures2014.

Activities in violation of the Code ofBusiness Conduct, including withoutlimitation, the Code of Ethics ofMMC Group Companies.

The violation or breach of anymaterial provision in any applicableemployment contract or agreement.

The violation or breach of any of theprovision in the Code of BusinessConduct and the Code of Ethics ofMMC Group Companies.

A violation or breach of conduct can begenerally explained as activities,performance of or failure to perform anobligation which constitutes a seriousbreach of conduct. A situation isrecognized as breach of conduct whenany conduct on the part of employeewho is inconsistent with the faithfuldischarge of his duties, or any breach ofthe express or implied duties of anemployee towards his employer.

It is also known as a form of improperbehaviour or an intentional wrongdoingor a deliberate violation of a rule orstandard of behaviour as determined bythe Executive Handbook including butnot limited to:

The conduct of corruption andbribery or any other activitiesstated in the Malaysian Anti-Corruption Act 2009 and MMCAnti-Bribery and Anti- CorruptionPolicy and Framework.

Engaging in activities whichadversely affect or which arecontrary or harmful to theinterests of the Company whicheither criminal or civil penaltiesmay be sought.

The determination of breach ofconduct shall be determined by theExecutive Handbook in good faithand in its sole discretion with theapplication of Employment Act 1955.


GLOSSARYIntroduction of Our Code of Business Conduct

Work Place Values


Unethical Practices




Glossary

CODERefer to AIRB’s Code of Business Conduct, encompasses thecode for business ethics and the consequences of breachingthe code.

IMMEDIATE FAMILY MEMBERThe employees’ parents, children, siblings, relatives, by bloodor by marriage or any other person under the employee’sguardianship.

CLIENTAn organization/company that receives a water treatmentservice from AIRB in return for payment.

VENDOR/SUPPLIERAn organization/company that sells, supplies or provides AIRBneeded such as products, service, commodities, and goods.

SUBCONTRACTORAn organization/company that carries out work for AIRB on aproject which the AIRB has agreed to perform with client.


EMPLOYEESAn individual who was hired by Aliran Ihsan Resources Berhad(“Company” or “AIRB”) and its subsidiaries known as AliranUtilities Sdn. Bhd.(AUT), Aliran Utara Sdn. Bhd. (AUSB), AliranWater Services Sdn. Bhd. (AWS), and SWESB MMCES JV Sdn.Bhd. (SWE-JV) (“AIRB Group”), includes Executive and Non-Executive.

BREACH OF CODEWhen an employee fails to deliver according to the terms ofthe agreement, which refer to this code.

Documents

CODE OF BUSINESS CONDUCT - AIRB