Policy

Policy

GIFTS, DONATION AND SPONSORSHIP POLICY

1. Introduction

Establishing a gift policy is crucial for companies to maintain transparency, ethical standards, and trust with stakeholders.

2. Purpose

Below are the key purposes for a company to establish a gift policy:

2.1 Prevent Conflicts of Interest

  • Ensures that gifts do not influence business decisions or create biases.
  • Protects employees and the company from situations where personal gain could conflict with professional responsibilities.

2.2 Maintain Ethical Standards

  • Reinforces the company’s commitment to ethical behavior and integrity.
  • Demonstrates a zero-tolerance approach to bribery, corruption, or unethical practices.

2.3 Ensure Compliance with Laws and Regulations

  • Helps the company adhere to legal requirements, such as anti-bribery laws.
  • Reduces the risk of legal penalties or reputational damage due to non-compliance.

2.4 Promote Fairness and Equality

  • Ensures that all employees, clients, and partners are treated equally, without favoritism or unfair advantages.
  • Prevents situations where gifts could create an uneven playing field.

2.5 Protect the Company’s Reputation

  • Builds trust with clients, partners, and the public by demonstrating transparency and accountability.
  • Avoids negative perceptions or scandals that could arise from improper gift-giving.

2.6 Provide Clear Guidelines for Employees

  • Offers employees clear rules on what is acceptable and unacceptable regarding gifts.
  • Reduces ambiguity and helps employees make informed decisions in line with company values.

2.7 Mitigate Risks of Bribery and Corruption

  • Establishes boundaries to prevent the exchange of gifts that could be perceived as bribes.
  • Protects the company from being implicated in corrupt practices.

2.8 Foster a Culture of Transparency

  • Encourages open communication and accountability within the organization.
  • Ensures that all gift-related activities are documented and disclosed appropriately.

2.9 Strengthen Relationships with Stakeholders

  • Builds trust with clients, vendors, and partners by demonstrating a commitment to ethical practices.
  • Ensures that relationships are based on mutual respect and professionalism, not on material incentives.

2.10 Streamline Decision-Making

  • Provides a framework for evaluating and approving gifts, reducing the need for ad-hoc decisions.
  • Saves time and resources by having a clear policy in place.

2.11 Avoid Internal Disputes

  • Reduces the potential for misunderstandings or conflicts among employees regarding gift-giving practices.
  • Ensures consistency in how gifts are handled across the organization.

2.12 Align with Corporate Social Responsibility (CSR) Goals

  • Reflects the company’s commitment to ethical business practices and social responsibility.
  • Enhances the company’s image as a responsible and trustworthy organization.

3. Gifts, Entertainment and Hospitality

3.1 As general principle, MSDDI directors and employees are prohibited from directly or indirectly receiving personal gifts from or providing gifts to any customer(s) and any other External Parties.

3.2 However, accepting a gift on behalf of MSDDI is allowed in very limited circumstances:

  • The gift is symbolically meant for the organisation (e.g in the form of a book or a commemorative plaque); or
  • The value is not exceeding the amount permitted under this SOP (value less than RM300).

3.3 For Exceptional Cases (In Very Limited Circumstances And Subject To Approval)

  • In the event that a gift of a value exceeding RM300.00 is received by any member of the Company from external parties while carrying out his/her duties or if received from any party the Company has a relationship with, that member of the Company shall make a declaration to the HR Department with his / her respective HOD’s acknowledgement and seek approval from the Management.
  • Such gifts and hospitality shall fulfil ALL the following conditions prior to approval:
    • They do not have or perceived to be affecting action(s) or decision(s) of the receiving party;
    • There shall be no expectation of any specific favour, benefit or advantages from the intended recipients; and
    • There shall not be any corrupt/ criminal intent.

4. Donation & Sponsorship

4.1 All sponsorships and donations shall not be used for the intention of bribery or contributing to any public or private official.

4.2 To uphold our values of integrity and transparency, all sponsorships and donations shall comply with the following:

  • Ensure such contributions are allowed by applicable laws;
  • Obtain prior approval from Management;
  • Be made to well established entities having an adequate organisational structure;
  • Be accurately stated in the company’s accounting books and records; and
  • Not to be used as a means of bribery.

4.3 Donations and sponsorships are only permissible with prior approval by the Management. All donations and sponsorship payment shall be supported with an official letter of request/announcement/notice from the requesting external party and proof of receipt.

5. Review and Monitoring

This policy will be reviewed periodically to ensure its effectiveness and to adapt to any changes in business or regulatory environments. All employees will be reminded of the policy on an annual basis, and training may be provided to ensure understanding and compliance.

6. Conclusion

MSDDI is committed to maintaining an ethical and transparent working environment. Employees, officers, and directors are expected to act in a manner that preserves the integrity of the company’s operations.

CODE OF CONDUCT POLICY

1. Introduction

1.1 MSD Digital Intelligence Sdn Bhd (MSDDI) is committed to maintaining the highest standards of ethical behavior, integrity and professionalism in all aspects of its operations. This Code of Conduct outlines the expected behaviour and ethical standards that all directors, employees, officers and representatives must follow to ensure a positive and productive working environment.

1.2 By adhering to this policy, we aim to build a company culture that fosters trust, respect and accountability in our interactions with colleagues, clients and stakeholders.

2. Purpose

The purpose of this Code of Conduct is to:

  • 2.1 Provide guidance on the ethical standards expected of all individuals associated with MSDDI;
  • 2.2 Promote an organisational culture based on mutual respect, fairness and professionalism;
  • 2.3 Ensure compliance with applicable laws, regulations and company policies; and
  • 2.4 Safeguard the reputation of the company and enhance its credibility amongst stakeholders and the industry.

3. Scope

3.1 This policy applies to all directors, employees, officers, contractors, consultants and anyone representing MSDDI in any capacity.

3.2 It applies during work hours, at company events and in any situation where employees are representing the company, including social media and personal interactions that may affect the company’s reputation.

4. Core Principles and Ethical Standards

We expect all individuals, including directors, employees, officers, contractors, consultants and anyone representing MSDDI in any capacity (hereinafter referred to as Parties), to adhere to the following core principles and ethical standards:

4.1 Compliance with laws

  • 4.1.1 All Parties are required to observe the company’s policies and the laws of Malaysia and play an active role to ensure the company’s compliance to laws governing the company and it’s legal obligations.
  • 4.1.2 All Parties are expected to be ethical and responsible while discharging their duty and uphold highest standard of ethics.

4.2 Respect in the Workplace

  • 4.2.1 Employees must respect their colleagues and be professional in the day-to-day dealings be it in the workplace or outside.
  • 4.2.2 The Company does not allow any kind of discriminatory behaviour, harassment or victimisation.
  • 4.2.3 Employees should conform with our equal opportunity policy in all aspects of their work, from recruitment and performance evaluation to interpersonal relations.

4.3 Professionalism at the Workplace

  • 4.3.1 Employees shall observe the highest standard of professional conduct and always conduct themselves with integrity and decorum and must not under any circumstances commit any act or omission that would bring damages to the Company, its property, reputation or general interest.
  • 4.3.2 The Company does not tolerate behaviour that interferes with the employee’s ability to perform his or her duties.
  • 4.3.3 Use or effects of alcohol or illegal drugs are not acceptable.

4.4 Company property and proprietary information

  • 4.4.1 Employees shall treat all company’s property, whether material or intangible and all its intellectual property with respect and care and shall not disclose the same to any party without approval from the Management.
  • 4.4.2 Maintain confidentiality and proprietary information such as product data, pricing, financial data, customer names/addresses or non-public information about other companies, including current or potential supplier and vendors.
  • 4.4.3 Avoid misuse of company equipment or using it frivolously and avoid damage or vandalism. Safeguard and prevent abuse and unauthorise use of the company’s intellectual properties and materials.

4.5 Dress Code

  • 4.5.1 All employees must be clean and well-groomed. Grooming styles dictated by religion and ethnicity is allowed so long as it is appropriate and does not offend others.
  • 4.5.2 All clothes must be work-appropriate and must project professionalism. Clothes that are too revealing or inappropriate are not allowed.
  • 4.5.3 All clothes must be clean and in good shape and all employees shall maintain good personal hygiene at all times.
  • 4.5.4 Employees must avoid clothes with logos, graphics, symbolism, stamps or words that are offensive or inappropriate. Work clothes shall not indicate or carry any political affiliation.

4.6 Sexual Harassment

The following are prohibited by the Company:

  • 4.6.1 Commenting on somebody’s appearance, sexual orientation, or gender in a derogatory or objectifying way, or in a way that makes them uncomfortable.
  • 4.6.2 Proposing, demanding or insinuating sexual favours.
  • 4.6.3 Sexual assault.
  • 4.6.4 Creating, posting or viewing sexually offensive materials in the workplace
  • 4.6.5 Flirting with somebody or pursuing them persistently against their will.
  • 4.6.6 Using obscene comments, gestures, pranks, and jokes that degrade or demean.
  • 4.6.7 Sending or displaying sexually explicit objects or messages.
  • 4.6.8 Invading somebody’s personal space, for example by touching them inappropriately.
  • 4.6.9 Threatening, coercing, stalking, or intimidating somebody to pressure them to engage in sexual acts.

4.7 Conflict of interest

Employees shall adhere to the Conflict of Interest & Gifts Policy as set out by the Company (please refer to the said document).

4.8 Gifts or Entertainment

Employees shall adhere to the Conflict of Interest & Gifts Policy as set out by the Company (please refer to the said document).

4.9 Whistleblowing

  • 4.9.1 The Company encourages employees to report or disclose any improper conduct by any employee, supplier, business partner, clients or any parties that has come to their knowledge which includes but not limited to:
    • a) Fraud
    • b) Bribery
    • c) Abuse of Power
    • d) Conflict of Interest
    • e) Theft or Embezzlement
    • f) Misuse of Company’s Property
    • g) Non-Compliance with Procedure
  • 4.9.2 Whistleblowers are encouraged to report in good faith or to raise a concern about any attempted, suspected and/or actual bribery or corrupt practices that violates any law, policy, guideline or SOP at the earliest possible stage using the reporting channel provided.
  • 4.9.3 All reports made under this policy will be treated with the utmost confidentiality.
  • 4.9.4 MSDDI values transparency and integrity and encourages a workplace culture where individuals feel comfortable raising concerns about unethical behavior. We are committed to maintaining a safe and ethical work environment and will take appropriate action to address any misconduct or unethical practices.
  • 4.9.5 For further details, please refer to the Whistleblowing Policy as set out by the Company.

4.10 Work hours and tardiness

  • 4.10.1 Employees must report for work at the assigned/scheduled work hours. Immediate superior must be notified immediately if the employee is late to work.
  • 4.10.2 Employees are prohibited from leaving work prior to the end of work hours without prior approval of immediate superior.
  • 4.10.3 Follow strictly meal/break period.
  • 4.10.4 An employee shall be deemed to have broken his contract if he/she has been continuously absent from work for more than two consecutive working days without prior leave, unless with a reasonable excuse for such absence and has informed or attempted to inform his employer of such excuse prior to or at the earliest opportunity during such absence.

4.11 Safety, health and environment

  • 4.11.1 The company strives to ensure high standards of compliance with regards to safety, health and environment practices.
  • 4.11.2 It is everybody’s responsibility to ensure a safe work environment.
  • 4.11.3 The below incidents and activities must be reported immediately to the company via established channel:
    • a) Accidents and potential hazards
    • b) Potential safety hazards and faulty equipment or facilities.
    • c) Report any activity that you recognise as an unsafe work practice or failure to comply with the established procedures
    • d) Any company activities or individual behaviour or acts that compromise safety.

4.12 Disciplinary action

  • 4.12.1 Employees shall adhere to the company’s policies and the code of conduct.
  • 4.12.2 Failure to comply to the above shall results in disciplinary action including dismissal, suspension, demotion or any other action deemed suitable based the company’s processes.
  • 4.12.3 Action may also be pursued in cases of corruption, theft, embezzlement or other unlawful behaviour.

4.13 Grievance Management

  • 4.13.1 Employees are advised to lodge a grievance report if they are being unfairly treated or are/were subjected to any forms of treatment that is inconsistent with the company’s code of conduct and business ethics or is inconsistent with fair and equal treatment of employees.
  • 4.13.2 All grievance report shall be handled with utmost confidentiality and care throughout the process and shall be dealt with promptly. The employee shall be keep informed on the progress and outcome of the investigations and actions taken. The Company endeavours to resolve all grievances within fourteen (14) working days, failing which, the employee shall be kept notified.
  • 4.13.3 Should the employee be unsatisfied with the action taken by the Company, the employee may lodge a report with the CEO and/or to the Board of Directors.

5. Review and issuance of further policy / guidelines

5.1 The Company reserves the right to amend this policy from time to time and shall notify all employees when such amendment has been made and has been approved by the Management.

5.2 The Company will, from time to time, issue further policy and/or guidelines to complement and elaborate on the provisions of this Code of Conduct e.g. Conflict of Interest Policy, Gifts, Donation and Sponsorship Policy, Whistleblowing Policy etc.

CONFLICT OF INTEREST

1. Introduction

1.1 MSD Digital Intelligence Sdn Bhd (MSDDI) is committed to maintain the highest standards of integrity, professionalism and ethical behavior.

1.2 This Conflict of Interest Policy aims to prevent situations where personal interests could interfere with the objective exercise of judgment by employees as against the company’s interests. This document shall complement the Code of Conduct issued by MSDDI.

1.3 All directors, employees, officers and any individuals representing the company shall be bound by this policy to ensure that their actions reflect the best interests of MSDDI.

2. Purpose

2.1 The purpose of this policy is to:

  • a) Ensure that individuals involved in decision-making processes act in the best interests of the company.
  • b) Identify, disclose and manage any potential or actual conflicts of interest.
  • c) Protect the reputation and integrity of the company by maintaining transparency and accountability.

3. Definition of Conflict of Interest

3.1 A conflict of interest arises when an individual’s personal interest, relationship(s) or activities could interfere with their ability to act in the best interests of MSDDI. Conflicts of interest can occur in various ways, including, but not limited to:

  • a) Financial interests or investments in a competitor, supplier, or customer of MSDDI.
  • b) Relationships with individuals or organisations that could influence business decisions.
  • c) Personal interests that interfere with the responsibilities or duties at the company.
  • d) Outside employment, business or other interests that might impair judgment or loyalty to the company.

4. Types of Conflicts of Interest

Examples of conflicts of interest include:

  • 4.1.1 Financial Conflicts: Holding a financial interest in a company that competes with, supplies or is a customer of MSDDI.
  • 4.1.2 Family and Personal Relationships: A personal relationship with a colleague, client or supplier that could influence business decisions unless officially declared to and approved by the Company.
  • 4.1.3 Outside Employment: Holding a second job or business interest that could conflict with the responsibilities at MSDDI.
  • 4.1.4 Gifts and Entertainment: Accepting or offering gifts or entertainment that could influence or appear to influence decision-making.

4.2 Employees are strongly prohibited from:

  • 4.2.1 Using their position in the company for personal advantage.
  • 4.2.2 Engaging in activities that brings direct or indirect profit to a competitor.
  • 4.2.3 Owning shares in a competitor.
  • 4.2.4 Carrying out side-line activities with other companies / entities and carrying out side-line jobs with other companies during work hours.
  • 4.2.5 Using connections obtained through their position in the company for private purposes.
  • 4.2.6 Engage in any acts that is not in the company’s fundamental interest either directly or indirectly.

5. Outside Business Activities

Employees must disclose any outside business activities, including self-employment or involvement with other organizations, that could potentially conflict with their duties at MSDDI. Approval must be sought before engaging in such activities to ensure there is no conflict.

6. Disclosure of Conflict of Interest

6.1 All employees, officers, and directors must disclose any actual, potential, or perceived conflicts of interest as soon as they arise. The disclosure should be made to the Head of Department (HOD) and Human Resource (HR Department), and the following details should be included:

  • a) The nature of the conflict.
  • b) Any related individuals or entities involved.
  • c) The potential impact on company operations or decision-making.

6.2 The company will review the disclosure and determine whether the conflict needs to be managed, mitigated, or eliminated.

7. Managing Conflicts of Interest

When a conflict of interest is identified, the company will take appropriate steps to manage, mitigate, or resolve the conflict. This may include:

  • a) Requiring the individual to recuse themselves from decision-making processes related to the conflict.
  • b) Establishing guidelines for disclosure and reporting of the conflict.
  • c) In extreme cases, reassignment of roles or termination of employment or relationship with the company.

8. Consequences of Non-Disclosure

Failure to disclose a conflict of interest may result in disciplinary action, up to and including termination of employment or contract. The company reserves the right to take appropriate legal action if a conflict of interest results in harm or loss to the company.

9. Confidentiality

Any information disclosed under this policy will be treated with confidentiality. The company will only share information on a need-to-know basis to manage or address the conflict.

10. Review and Monitoring

This policy will be reviewed periodically to ensure its effectiveness and to adapt to any changes in business or regulatory environments. All employees will be reminded of the policy on an annual basis, and training may be provided to ensure understanding and compliance.

11. Conclusion

MSDDI is committed to maintaining an ethical and transparent working environment. Employees, officers, and directors are expected to act in a manner that avoids conflicts of interest and preserves the integrity of the company’s operations.

WHISTLEBLOWING POLICY

1. Introduction

1.1 MSD Digital Intelligence Sdn Bhd (MSDDI) is committed to maintaining the highest standards of fairness, honesty, openness, decency, integrity and respect in all of its operations. We encourage employees, contractors and other stakeholders to report any concerns regarding unethical, illegal, or improper conduct that may be occurring within the company.

1.2 This policy is designed to provide clear guidance on how to report such concerns and ensure that whistleblowers are protected from retaliation.

2. Purpose

The purpose of this Whistleblowing Policy is to:

  • 2.1 Enable employees and stakeholders to report concerns about unethical, illegal, or improper conduct.
  • 2.2 Encourage an open and transparent environment where all individuals feel safe and supported in reporting their concerns.
  • 2.3 Protect whistleblowers from retaliation or adverse action for reporting concerns in good faith.

3. Whistleblowing Measures

3.1 MSD encourages openness and transparency in its commitment to the highest standard of integrity and accountability.

3.2 MSD encourages the reporting of integrity-related issues and concerns which includes, but is not limited to, the following:

  • 3.2.1 Allegations of fraud, corruption, unethical behaviour or misconduct
  • 3.2.2 Concerns regarding questionable business practices and or plans
  • 3.2.3 Warning about particulars risk areas going unchecked
  • 3.2.4 Non-Compliance observed with regard to company policy or the law
  • 3.2.5 Discrimination, harassment, or bullying

4. Definition of whistleblower

4.1 This policy provides an avenue for all employees of MSD including Directors, Shareholders, Customers, Consultants, Vendors, Contractors, agencies or any parties (individually or collectively to be known as “whistleblower(s)”) with a business relationship with the MSD to disclose any unethical conduct or malpractice in accordance with the procedures as provided under this SOP

4.2 MSD shall take all necessary measures to ensure that the identity and personal information of the whistleblower shall be protected at all times and be kept, confidential to the extent reasonably practicable unless otherwise required by the law, or for the purpose of any proceedings by the company.

5. Reporting Channel for Whistleblowing

5.1 Whistleblowers are encouraged to report in good faith or to raise a concern about any attempted, suspected and/or actual bribery or corrupt practices that violates any law, policy, guideline or SOP at the earliest possible stage using the reporting channel as stated below:

Designated Whistleblower Helpline: If for any reason you do not feel comfortable reporting the issue to your supervisor, you may contact the whistleblower hotline. Contact details are as follows:

  • a. Whistleblower Hotline: (As announced by HR); or
  • b. Anonymous Email: suara@msd.net.my

5.2 Protection will be accorded even if the investigation later reveals that the whistleblower is mistaken as to the facts and the rules and procedures involved.

5.3 Any anonymous disclosure will be entertained provided that the information / …

6. Protection of Whistleblowers

6.1 MSDDI is committed to ensuring that individuals who report concerns in good faith are protected from retaliation, including:

  • a) Disciplinary action
  • b) Harassment
  • c) Discrimination
  • d) Unfair treatment

6.2 Any individual who retaliates against a whistleblower for reporting a concern in good faith will be subject to disciplinary action, up to and including termination of employment.

7. Confidentiality

All reports made under this policy will be treated with the utmost confidentiality. MSDDI will only share information on a need-to-know basis. However, in some cases, confidentiality may not be possible due to legal or regulatory requirements.

8. Investigation and Follow-up

Once a report is made, the company will conduct a prompt, thorough, and impartial investigation. All reports will be investigated in accordance with applicable laws, company policies, and best practices. Whistleblowers will be kept informed of the progress and outcome of the investigation, as appropriate.

9. False Allegations

While we encourage reporting of genuine concerns, individuals who knowingly make false or malicious claims may be subject to disciplinary action. However, anyone who reports concerns in good faith, even if their concerns are not substantiated, will not be penalised.

10. Conclusion

10.1 MSDDI values transparency and integrity and encourages a workplace culture where individuals feel comfortable raising concerns about unethical behavior. We are committed to maintaining a safe and ethical work environment and will take appropriate action to address any misconduct or unethical practices.

10.2 If you have any questions regarding this policy or need further guidance, please contact HR accordingly.

10.3 The Company reserves the right to amend this policy from time to time and shall notify all employees when such amendment has been made and has been approved by the Management.