### CODE OF CONDUCT AND ETHICS Hong Leong Manufacturing Group Sdn Bhd and its subsidiaries and/or associated companies (where applicable) (collectively, the “Group”) is committed to a high standard of professionalism, ethics and integrity in the conduct of our business and professional activities as set out in this Code of Conduct and Ethics (the “Code”). The Code applies to all colleagues who work in the Group – including but not limited to permanent, part-time and temporary employees. The Code also applies to any other persons permitted to perform duties or functions within the Group – including but not limited to contractors, secondees, interns, industrial attachment and agency staff. Each of the above-mentioned person (each a “Party”) is responsible for fully understanding and complying with the Code. Each Party may be required to undertake training as may be necessary, and provide an affirmation that he has read, fully understood and will comply with the Code, annually. Reference to “Company” in this Code shall mean the relevant company within the Group with whom each Party has a contractual relationship. The Code also forms part of the terms and conditions of employment/engagement. Any failure to comply with the Code, or Group policies will be treated very seriously by the Group. Such failure shall constitute misconduct and may result in disciplinary action, up to and including termination of employment (for employees) or termination of relationship with the Company (for contractors and others). **1. Commitment ** Each Party is required to observe and adhere to the following: a. To faithfully and diligently perform duties and accept responsibilities as may, from time to time, be assigned by the Company. Each Party is expected to promote and advance the interests of the Company at all times. b. To perform duties in respect of the Company as well as any other Company within the Group. **2. Compliance with Laws, Regulations, Internal Policies and Procedures** a. The Parties shall always observe and ensure compliance with all applicable laws, rules and regulations to which they are bound to observe in the performance of their duties. b. The Parties shall always observe and comply with all policies, practices and procedures of the Group and the Company, whether expressed or implied. **3. Confidential and Proprietary Information** a. Each Party shall keep and maintain the secrecy of all confidential and proprietary information, including those received pursuant to non-disclosure agreements with third parties (“the Confidential Information”) which comes into his knowledge as a result of his employment/engagement by the Company. Such Confidential Information shall include any information relating to the Company’s and Group’s business, operations, processes, plans, intentions, product information, know-how, design rights, drawings, blueprints, charts, techniques, sources of supply, formulae, analyses, reports, methods of working, data and specifications, trade secrets, price lists, cost information, computer programmes, market opportunities, customer information, financial information, business and research plans and other commercially valuable information of any kind which the employee shall have access to while in the employment/engagement of the Company. b. The Party shall not copy, reproduce or reduce in writing any part of the Confidential Information thereof except as may be reasonably necessary for the purpose of performing his duties. Any copies, reproductions or reductions to writing shall be the property of the Company. c. The Party shall apply thereto no lesser security measures and degree of care to protect the confidentiality and secrecy of the Confidential Information, than those which he would apply to his own personal propriety information. d. The Party shall not at any time either during his employment/engagement or after he ceases to be in the employment/engagement of the Company, use for himself or disclose to other parties or cause to be published any part of the Confidential Information without the prior consent of the Company. e. The Party shall deliver to the Company, upon leaving his employment/engagement for any reason whatsoever and/or any time the Company may so request, all such Confidential Information and other property constituting or relating to the employee’s work for the Company, including any handbooks or materials provided by the Group. f. If the Party is found to have divulged or have caused to divulge or to have failed to use his best endeavours to prevent the publication or disclosure of such Confidential Information, the Group or Company reserves the right to terminate the contract of employment/engagement forthwith without notice and/or to take the appropriate legal action against the defaulting Party. g. Any Party who receives a subpoena or other requests seeking disclosure of Group/Company information is to contact his immediate superior (for employees) or the Company (for contractors and others) for guidance. **4. Intellectual Property ** a. Any invention, improvement, literary rights, copyrights, trademarks, patents and/or new discoveries (“the Intellectual Property”) which originates from or is conceived by the employee, whether alone or with any person or persons while in the employment of the Company, which relates either directly or indirectly to the Company, shall belong to and be the absolute property of the Company. b. The employee shall promptly disclose to the Company all such Intellectual Property made by him alone or with any person or persons and shall hold them in trust for the Company. c. The employee shall assign and hereby agrees to assign to the Company any and all rights to the Intellectual Property, as and when directed by the Company and further agrees that the Company and its successors and/or assigns shall have the absolute right to use experimentally or commercially the Intellectual Property or any part thereof. d. The employee shall at the request and expense of the Company do all things necessary or desirable to substantiate the rights of the Company as mentioned here. e. This provision shall not apply to any invention for which no equipment, supplies, facilities, know-how or trade secret information of the Company was used and which was developed entirely on the employee’s personal time and which does not relate to the business of the Company, directly or indirectly, or the Company’s actual or demonstrated anticipated research and/or development, or which does not result from the work performed by the employee for the Company. **5. Usage of Company E-Mail Facility ** a. The Company maintains and provides an electronic mail (e-mail) system (“Company E-Mail System”) to assist in the conduct of business within the Company. The use of the Company E-Mail System is reserved solely for the conduct of business at the Company. It may not be used for personal business including but not limited to the soliciting or proselytizing of commercial ventures, religious or political causes, outside organisations or other non-job-related solicitations. b. All messages composed, sent, or received on the Company E-Mail System are and remain the property of the Company. The Company reserves and intends to exercise the right to review, audit, intercept, access and disclose all messages created, received or sent over the Company E-Mail System for any purpose. c. Each Party must handle e-mail as private and direct communication between the sender and the recipient. Notwithstanding the Company’s right to retrieve and read any e-mail messages, such messages should be treated as confidential by other Parties and accessed only by the intended recipient. Parties are not authorised to gain access, retrieve or read any e-mail messages not intended for them unless with the permission of the recipient. d. The Company E-Mail System shall not be used to send or forward any information on the Company’s or the Group’s customer, business, operations, policies, notifications or circular intended for internal use to any party outside the Company via e-mail without the prior approval from head of department (for employees) or the Company (for contractors and others). e. The Company E-Mail System must not be used to create any offensive or disruptive messages i.e. any messages which contain sexual implications, racial slurs, gender-specific comments, or any other comment that offensively addresses someone’s age, sexual orientation, religious or political beliefs, national origin or disability. f. Any Party who discovers a violation of the e-mail usage policy shall notify his or her superior (for employees) or the Company (for contractors and others) immediately. g. Illegal Software – Parties are prohibited to install, load or download any illegal software into the Company’s personal computers. **6. Employee’s Use of Social Media** a. Employees must always be aware that all Group personnel are always viewed as ambassadors of the Hong Leong brand, credible spokespersons of the Group and technical/industry experts. Thus, at all times no member of the Group shall approve or support any action or activity that in any way brings the organisation into ill repute or create negative publicity for the organisation. As an ambassador of the Group, staff must consistently act with honesty and integrity and be mindful of the implications of their actions or activity on the Group. b. Employees are expected to maintain the same high standards of conduct and behaviour online as would be expected elsewhere and/or outlined in the Code. This includes but not limited to: • being apolitical and professional • behaving with respect and courtesy, and without harassment • dealing appropriately with information, recognising that some information needs to remain confidential • being sensitive to the diversity of Malaysia • taking reasonable steps to avoid conflicts of interest **7. Press Release and Public Statement** a. No Party is authorised to make any public statement, either orally or in writing or in any form, on the internal policies, financial information, internal affairs or corporate affairs of the Company or the Group, or circulate any such statement made either by him or anyone else to the media or public except with the approval of the Company’s GMD/President, and in case of matters concerning the Group, with the prior approval of the President; or in accordance with item (b) below. b. Only the head of departments or units responsible for sales, marketing, customer services, public relationship or other similar functions, GMD or President, and senior executive with the explicit approval of the GMD or President for specific topics of interest, and the Chairman’s appointed spokesperson for Group concerns are authorised to make or release any statements on the Company or Group (as the case may be) to the media or the public, provided that they are for the purpose of communicating sales, marketing, customer services or public relationship and related information in accordance with the existing Company’s and Group’s policies on such matters with the prior approval of the GMD/President. c. A Party shall inform the GMD and President or the Group Human Resource Department if he is approached by a member of the media to comment on any matters pertaining to the Company or Group. **8. Public Appearance as a Guest Speaker ** a. No employee of the Company is allowed to participate as a speaker in talks, seminars, conferences that are not organized by the Company or Group without the prior approval of his GMD/President. b. When applying for approval from his GMD/President, the employee concerned is required to submit the intents and contents (or full text, if otherwise requested) of his talk or speech to be delivered for consideration and approval. c. Unless otherwise authorized, the employee shall in no circumstance, disclose, divulge or implicate any confidential information pertaining to the Company’s or Group's business, operations and policies. **9. Restraint and Conflict of Interest** An employee shall devote his whole time, attention, energy, and skill solely to the business of the Company or Group and shall not be concerned or interested directly or indirectly in any business or work other than of the Company or Group. Without the written approval or permission of the Company or Group (approval should be granted only where the interest of the Company or Group is not prejudiced), no employee is allowed, during the period of the employee’s employment with the Company or Group: a. To take up employment, whether paid or unpaid, of another employer; or b. To engage or concern himself or be interested in any other business, whether or not the business belongs to him or to any member of his family or any other person or corporation; or c. To have proprietary or pecuniary interest in the business of any other company, firm or individual, business of which is in whole or in part similar to any trade or business carried on by the Company or Group; or d. To trade with any company or firm in which the employee or his family or any other members of the staff are interested directly or indirectly; or e. To have any outside interest which is in direct conflict with the business of the Company in which the employee manages. f. To allow any conflict of interest, bias or undue influence of others to override business and professional judgement. Every employee must not be influenced by friendship or association in performing his or her role. Any employee found to be so employed, engaged, invested, traded, concerned or interested in business will be regarded to have wilfully breached a condition of employment and the Group or Company reserves the right to terminate the contract of employment forthwith without notice or to take other action as the Group or Company deems fit. ** 10. Bribery and Corruption** a. Parties shall not in any manner offer or receive an offer of graft or a bribe for his own benefit or for any other person(s), with intent to influence his conduct in relation to the Company’s affairs. b. Parties must at all times comply with local anti-bribery and corruption laws and regulations. In Malaysia, the main legislation is the Malaysian Anti-Corruption Commission Act 2009. c. Any employee found to have committed such an act shall be subject to disciplinary action which may include dismissal. Severe penalties, including heavy fines and imprisonment, can be applied to any person found guilty of bribery or corruption. d. An employee must promptly declare any gift or entertainment which they give or receive, and all employees are strictly prohibited from giving or receiving a gift or entertainment which is, or which appears to be inappropriate or excessive, taking into account all relevant facts and circumstances. This prohibition includes where the gift or entertainment, regardless of its value, is given or received for the purpose of obtaining any personal or business advantage, or that may influence the employee’s objectivity in carrying out his employment/business. **11. Abuse of Power** a. All employees are not to use their position to influence other employees, current and potential customers, suppliers or business partners of the Company or Group (collectively, “Other Persons”), to act in such employees’ personal interest or in the interest of any of the Other Persons or anyone else. All employees shall always act only in the interest of the Company. b. All employees are not allowed to use the Company’s or Group’s name or facilities, their position and/or connection with the Company or Group to gain personal advantage and preferential treatment or to engage in activities or unethical arrangements for personal or mutual gains. **12. Employee Behavior ** a. All employees are expected to conduct themselves professionally and in accordance with accepted standards of behavior in Malaysia. b. Use of abusive language and physical violence will not be tolerated. c. An employee who is detained in police custody, whether on a criminal charge or otherwise, shall inform the situation to the Company. **13. Personal Finances** a. Any improper handling by an employee of his personal finances could undermine his credibility and the reputation of the Group. It could also cause others to question his decision-making on the job or task that he is handling. Therefore, the employee must handle his personal finances responsibly, with integrity, and in compliance with all relevant laws and regulations. He must not promote or participate in illegal financing schemes, tontine schemes (kootu funds) and otherwise carry on illegal activities for his own personal gain or the gain of others. b. The Company reserves the right to carry out checks of an employee’s past, as well as present financial activities and patterns. Where an employee fails to fulfil his financial obligations as and when they fall due or has been the subject of a judgement debt which is unsatisfied, either in whole or in part, the Company may take appropriate action, including: • Removing the employee from certain positions or roles e.g. position of authority, cash handling, etc; and • Termination of employment if the employee is declared bankrupt and is no longer suitable to be employed by the Group. An employee’s career advancement may also be impacted as a result of his poor financial standing such as his promotion being withheld. **14. Integrity of Records** a. Employees must not make entries or allow entries to be made for any account, record or document of the Company that are false or would obscure the true nature of the transaction as well as to mislead the true authorized limits or approval by the relevant authority of such transactions. b. Employees should report to their superior immediately upon discovery of any unauthorized copying, entries, deletions or alterations in the Company’s or Group’s records. **15. Insider Trading** a. No Party shall deal or influence any other person to deal in the securities of any company listed or pending listing on a stock exchange at any time when he is in possession of information obtained as a result of his employment by, or his connection with the Company or Group, which is not generally available to the public and which, if it were so available, would likely to have a material effect in the market price or market activity of the shares. b. Parties who are in possession of market sensitive information are not allowed to trade in securities of the relevant listed company within the Group if that information has not been made public. Parties are also prohibited from disclosing any non-public price sensitive information to any third party. **16. Anti-Money Laundering and Counter Terrorism Financing** a. All Parties must abide by the laws and regulation pertaining to Anti-Money Laundering and Counter Financing of Terrorism. b. Employees should always ensure that they are conducting business with legitimate counterparties and for legitimate business purposes. If from any factual circumstances, an employee knows or has reason to believe or has reasonable suspicion of money laundering activities, they should take reasonable steps to ascertain whether the property or funds involved are legitimate and report it to their respective Head of Department or the relevant person designated by the Company.