Our Policy
Generic Policy Statement
PELABURAN HARTANAH BERHAD GROUP (“PHB Group”) is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. It is the Group’s policy to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice, wherever it operates throughout the world, of not engaging in bribery or corruption.
Policy Statements
It is the Company’s Policy to ensure that all business activities are conducted in an honest and ethical manner. PHB group takes a zero-tolerance approach to bribery and corruption while maintaining its professional ways of doing business.
Anti-Bribery and Corruption (ABC)
Directors and Employees are prohibited from accepting or soliciting, giving or offering any form of gratification as an inducement or reward to do or forbear any act in relation to any matter in which any business partners, friends or Families has an interest whether directly or indirectly.
Business partners such as Joint-venture companies, are also prohibited from offering and/or giving any form of gratification to PHB Group’s Directors and Employees, as an inducement or reward, to use PHB Group’s office or position when making any decision, or take any actions in relation to any matter in which the business partners, friends or families have an interest whether directly or indirectly. Likewise, Directors and Employees and other PHB’s stakeholders are also prohibited from offering and/or giving any form of gratification to the joint-venture Partners that is against this Policy.
Gift and Hospitality
This Policy does not prohibit any business hospitality that is given for purpose of improving the Company’s image, promoting the Company’s investment properties and product or establish friendly relations with third parties to achieve business objectives.
Having said of the above, all gifts and hospitalities:
Hospitality, Entertainment and Sponsored Business Travel
Directors and Employees are strictly prohibited from providing or offering to provide entertainment with a view to improperly cause undue influence on any party in exchange for some future benefit or result. Any acts of this nature, whether provided directly or indirectly through an intermediary, may be construed as an act of bribery and contrary to the general values and principles of Code of Business Conduct and Ethics.(CoBE).
Factory Acceptance Test (FAT) Any travelling or participating to event related to contractual requirements such as Factory Acceptance Test (FAT) or business development related matters, must be in accordance to the specification and requirements of the contract and reports must be produced to the Management on the activities held during the course of traveling/ event. produced to the Management on the activities held during the course of traveling/ event.
Contribution Related to Corporate Social Responsibility (CSR)
All local charities or provide sponsorship, for example, sports, community or cultural events must be justified, approved by the Group Managing Director and within the amount/ value that has been determined and approved by the Board.
The activities/ events have to be legal and ethical under the laws.
All documents pertaining to the donation, contribution and sponsorship must be recorded and such records must be made available for auditing purposes.
Providing and Accepting of Facilitation Payments
The Company prohibits making and accepting, facilitation payments or kickbacks of any kind. Facilitation payments refers to payments made to secure or expedite a routine action by an official. Any request for facilitation for a facilitation payment must be rejected and reported in accordance to the Whistleblowing Policy and Whistleblowing Reporting Procedures.
Conflict of Interest and Potential Abuse of Position for Personal Gains
Business decisions and actions must not be motivated by personal interest, considerations or relationships. Relationships with prospective or existing business partners, customers, competitors or regulators must not affect the status of independence (for directors) and sound judgment on behalf of PHB Group.
Directors and Employees are expected to exercise basic common sense in avoiding any conflict of interest and to act in a manner consistent with this Policy. On occasions, however, the question of whether or not conflict of interest exists may be less clear and open to interpretation. Whenever such a case arises, consultation from the Integrity & Governance Unit (IGU) or, where appropriate PHB’s Board and Senior Management, must be sought.
Outside Business Appointments, Directorships/Undertakings
Money Laundering
Money laundering occurs when the criminal origin or nature of money or assets is hidden in legitimate business dealings or when legitimate funds are used to support criminal activities, including financing terrorism.
PHB Group strongly objects to practices related to money laundering, including dealing in the proceeds of criminal activities.
Political Funding and Dealing with Government Official
A 'public or government official’ that includes, without limitation, candidates for public office, officials of any political party, and officials of state-owned enterprises other than PHB Group.
Directors and Employees are prohibited from paying for non-business travel and hospitality for any government official or his/her family/household members.
In addition, this Policy prohibits:
A 'public or government official’ that includes, without limitation, candidates for public office, officials of any political party, and officials of state-owned enterprises other than PHB Group.
Directors and Employees are prohibited from paying for non-business travel and hospitality for any government official or his/her family/household members.
In addition, this Policy prohibits:
Wilful Blindness
If Director(s) or Employee(s) wilfully ignores or turns a blind eye to any evidence of corruption or bribery, action will also be taken against them.
Every person, to this Policy is applicable to, is encouraged to raise their concerns about any bribery issue or suspicion of malpractice at the earliest possible stage. If he / she is unsure whether a particular act constitutes bribery or corruption or if he / she has any other queries, these should be raised in accordance with PHB Group’s Whistleblowing Policy.
Reporting Channel
The Board and Management is required to establish an effective, adequate and secured Whistleblowing Reporting Channels for directors, employees, vendors, business partners and external parties, including public to report any suspected fraud, corruption, criminal activity or unethical conduct/behaviour in the workplace without facing any adverse consequences such as retaliation.
Whistle-blower must be accorded with protection under the Policy. Such protection is accorded even if the investigation later reveals that the whistle-blower is mistaken as to the facts as well as the rules and procedures involved.
Record Keeping
Employees must ensure all expenses claims related to hospitality, gifts or expenses incurred to third parties are submitted in accordance with PHB Group’s expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memorandum, other documents and records relating to dealings with third parties should be maintained with strict accuracy and completeness. No accounts will be kept “off-book” to facilitate or conceal improper payments and effective monitoring and auditing mechanisms must be established accordingly.
Employees must follow all the procedures laid out in other policies (available in the respective intranet portal) which help in anti-bribery and corruption due diligence on suppliers, potential joint venture parties, clients and any other third and external parties.
At PHB, we recognize the increasing importance of corporate governance in today’s business landscape. It is essential that our operations align with the highest ethical standards. The PHB Code of Conduct and Ethics (PHBCCE) establishes the key ethical principles that govern the behaviour of all employees and directors within the PHB Group of Companies.
The PHBCCE promotes integrity and ethical conduct in our interactions with all stakeholders, including employees, co-workers, suppliers, customers, government and regulatory authorities, shareholders, and the general public.
While the PHBCCE provides guidance on key ethical matters, it does not cover every possible situation employees may face. In circumstances where ethical questions arise that are not explicitly addressed in the PHBCCE, employees are expected to use their best moral judgment. For guidance, employees are encouraged to consult their immediate supervisor, department head, or the Human Resources Department.
