Everyone at AmBank Group is expected to act in a way that reflects our commitment to integrity and responsible business behaviour.
Conflicts of interest arises when an employee places his or her personal interests before the interests of AmBank Group and where such personal interests unduly influence the employee’s business judgments, decisions, or actions.
You must ensure that personal and business affairs do not conflict with or appear to be conflicting with AmBank Group’s interest. Any potential conflict observed during your day-to-day interactions at the Group must be reported immediately.
All employees must strictly adhere to AmBank Group’s Anti-Bribery and Corrupt Practices Policy and related Policies e.g. No Gift Policy.
A gift is defined as anything of value including items such as money, securities, business opportunities, goods, services, entertainment, company sponsored events, food, drink or vacations.
Our customers and suppliers are vital to AmBank Group’s success. Hence, it is imperative that these relationships remain objective, fair, transparent and free from conflict.
As an employee of AmBank Group, you should not:
AmBank Group is supportive to contribute towards charitable organisations. However, you should perform relevant due diligence procedures prior to dealing with them.
This is necessary to prevent contributing to charitable organisations which may be engaged in terrorism, money laundering or other criminal activity.
Any charitable contribution that could influence business decisions, should be avoided at all cost. This includes contribution requested by or made to an employee, customer, supplier, government official or business partner. Charitable contributions of a political nature are not allowed.
All charitable contributions made on behalf of AmBank Group should be approved in accordance with the Group’s Capital & Operational Authority Delegation Policy.
All employees must declare any involvement in business activities outside of AmBank Group in order to prevent potential conflict of interest. Employees shall not, without prior written consent of the Group, directly or indirectly carry on or be engaged, concerned or interested in any other business activities or occupation which:
Employees must not hold appointments as director, officer, administrator, trustee or hold direct or indirect financial interest as partner or shareholder with AmBank Group’s customers and vendors without prior approval from the Group.
Examples of outside business activities include the following :
As employees are expected to devote their time to fulfil their employment obligations with the Group, we should not be involved in any outside employment or business dealings, including any part-time or after-hours work or business dealings.
We should not undertake any outside business dealings with the Group’s auditors or with existing or prospective customers and suppliers to avoid actual or potential conflicts of interest.
Prior approval from the Group is required if the employee intends to be involved in any outside employment or business dealing.
Approval from the Group is required if an employee intends to hold an external position responsible for the oversight, management or direction of an outside business or organisation. This includes being a director, office-bearer or any industry-related appointments in a trade, industry or professional organisation (e.g. Asian Institute of Chartered Bankers, Malaysian Institute of Accountants).
AmBank Group approval is required if an employee intends to own an outside business, whether as a sole proprietor, partner or shareholder. Holding of shares in listed companies are not required to be declared unless management considers the interest to be material based on the following criteria:
a) Holdings of five (5) percent or more of the voting shares;
b) The employee / shareholder has influence over the board of directors’ composition, appointment and decision making; or
c) The financial interest of the employee in the listed companies is considered likely to impair the objectivity of the employee concerned.
While the Group does not discriminate against employees based on their political affiliation, employees must ensure that their political involvement does not impact their work or cause any potential conflict of interest. Any political activities must be performed in the employee’s personal time and outside of the workplace. The employee must not solicit other AmBank Group employees, customers or vendors to participate in the political activities.
Employees should abstain from approving any Group’s transactions relating to an estate if the employee is an administrator, executor, guardian or trustee of the estate and is also a beneficiary to the estate.
AmBank Group approval is required if an employee intends to serve as a board member or an officer of any non-profit, community or charitable organisation.
As employees are expected to devote their time to fulfil their employment obligations with the Group, we should not be involved in any outside employment or business dealings, including any part-time or after-hours work or business dealings.
Employees may hold or inherit shares in family-related companies for purpose of estate planning. We should obtain the Group’s approval for the ownership interest, of which approval should not be unreasonably withheld.
AmBank Group reserves the right to request for you to discontinue your involvement in any of the above if the Group observes any conflict of interest.
In general, a family member and personal friend should not have any business dealings with you or with anyone who reports to you in AmBank Group.
Conflict may arise if:
You should notify AmBank Group of your involvement where you or your family member have personal financial connections, financial interests or decision-making influence. AmBank Group has the right to ask you to discontinue your involvement in such dealings or reassign you to another job function if they perceive any conflict of interest.