Competing Fairly

Anti-trust and fair competition

Anti-trust and fair competition laws are designed to promote healthy competition and protect consumers from unfair and unlawful business practices.

Failure to comply with these laws will result in severe penalties which includes either one or both of the following:

• Financial penalty - Pursuant to Section 40(4) of the Competition Act 2010, the Competition Commission may impose a financial penalty up to 10% of the turnover of an enterprise
• Prison sentence - By virtue of Section 61 of Competition Act 2010, the Competition Commission may sentence an offender for an imprisonment term not exceeding five years

You must avoid from being involved in communicating with competitors to set or control prices, rates, trade practices, market policies or to allocate markets or customers. You must not engage in transactions where a customer is required to purchase or provide a product or service in exchange of another. All employees are expected to be familiar and comply with antitrust and anti-competition policies and laws that exist in Malaysia.

If a competitor or customer attempts to discuss the topics that raise concerns about anti-competitive conduct, you must stop all such discussions immediately and escalate the matter through the channels highlighted in the CoC.

Insider trading

Insider trading is defined as when an employee in possession of material and non- public information obtained through involvement within the company:

• uses that information to make decisions to purchase, sell, or otherwise trade in securities of the Company or another company, or
• provides that information to others outside the company to enable such trading

This results in significant effect (either positive or negative) on the price of the related shares or related securities, which creates unfair advantage and undermines the financial system. Insider trading is not only a violation of our policies, it is also against the law. Violations of insider trading policies and laws will result in significant fines and imprisonment for the individuals and companies involved.

Under the Capital Market and Services Act 2007, Criminal prosecution may be instituted against the insider and if convicted of insider trading, he/she may be penalised with imprisonment for a term not exceeding ten (10) years and to a fine of not less than One Million Malaysian Ringgit (RM1,000,000.00).

If you have come into possession of non-public information, you must not execute any trade in the securities of the subject company without first consulting with our legal counsel, who will then determine whether such a trade will violate any related policies or applicable laws.