At CMC, we act professionally in our business dealings. We conduct ourselves in honestly, integrity and are accountable for our actions. We are guided by the CMC Code of Ethics and Business Conduct, as follows:
It is the policy
of the CMC Engineering Sdn Bhd (“CMCE or the “Company”) to provide our Code of
Ethics and Business Conduct, which will serve as a guide to proper business
conduct for all employees. We expect all employees to observe the highest
standards of ethics and integrity in their conduct. This means following a
basic code of ethical behaviour that includes the following:
Build Trust and Credibility
The success of
our business is dependent on the trust and confidence we earn from our
employees, customers and shareholders. We gain credibility by adhering to our
commitments, displaying honesty and integrity and reaching company goals solely
through honourable conduct. When considering any action, it is wise to ask:
will this build trust and credibility for CMCE? Will it help create a working
environment in which CMCE can succeed over the long term? Is the commitment I
am making one I can follow through with? The only way we will maximize trust
and credibility is by answering “yes” to those questions and by working every
day to build our trust and credibility.
Respect for the Individual
We all deserve
to work in an environment where we are treated with dignity and respect. CMCE is
committed to creating such an environment because it brings out the full
potential in each of us, which, in turn, contributes directly to our business
success. CMCE is an equal employment / affirmative
action employer and is committed to providing a workplace that is free of
discrimination of all types from abusive, offensive or harassing behaviour. Any
employee who feels harassed or discriminated against should report the incident
to his or her manager or to the Human Resources Department.
Create a Culture of Open
and Honest Communication
At CMCE everyone
should feel comfortable to speak his or her mind, particularly with respect to
ethics concerns. Managers have a responsibility to create an open and
supportive environment where employees feel comfortable raising such questions.
We all benefit tremendously when employees exercise their power to prevent
mistakes or wrongdoing by asking the right questions at the right times. CMCE
will investigate all reported instances of questionable or unethical behaviour.
In every instance where improper behaviour is found to have occurred, the
company will take appropriate action. We will not tolerate retaliation against
employees who raise ethics concerns in good faith.
Uphold the Law
to integrity begins with complying with laws, rules and regulations where we do
business. Further, each of us must have an understanding of the Company
policies, laws, rules and regulations that apply to our specific roles. If we
are unsure of whether a contemplated action is permitted by law or Company
policy, we should seek the advice from the resource expert. We are responsible
for preventing violations of law and for speaking up if we see possible
We are dedicated
to ethical, fair and vigorous competition. We will provide services and sell
products based on their merit, superior quality, functionality and competitive
pricing. We will make independent pricing and marketing decisions and will not
improperly cooperate or coordinate our activities with our competitors. We will
not offer or solicit improper payments or gratuities in connection with the
purchase of goods or services for CMCE or the sales of its products or
services, nor will we engage or assist in unlawful boycotts of particular
clients or customers.
It is important
that we respect the property rights of others. We will not acquire or seek to
acquire improper means of a competitor’s trade secrets or other proprietary or
confidential information. We will not engage in unauthorized use, copying,
distribution or alteration of software or other intellectual property.
We will not
selectively disclose (whether in one-on-one or small discussions, meetings,
presentations, proposals or otherwise) any material non-public information with
respect to CMCE, its business operations, plans, financial condition, results
of operations or any development plan. We should be particularly vigilant when
making presentations or proposals to customers to ensure that our presentations
do not contain material non-public information.
Avoid Conflicts of Interest
We must avoid
any relationship or activity that might impair, or even appear to impair, our
ability to make objective and fair decisions when performing our jobs. At
times, we may be faced with situations where the business actions we take on
behalf of CMCE may conflict with our own personal or family interests because
of the course of action that is best for us personally may not also be the best
course of action for CMCE. We owe a duty to CMCE to advance its legitimate
interests when the opportunity to do so arises. We must never use CMCE property
or information for personal gain or personally take for ourselves any
opportunity that is discovered through our position with CMCE. Determining
whether a conflict of interest exists is not always easy to do. Employees with
a conflict of interest question should seek advice from management. Before
engaging in any activity, transaction or relationship that might give rise to a
conflict of interest, employees must seek review from their managers or the
Human Resources Department.
courtesies offered to us in the course of our employment are offered because of
our positions at CMCE. We should not feel any entitlement to accept and keep a
business courtesy. Although we may not use our position to obtain business
courtesies, and we must never ask for them, we may accept unsolicited business
courtesies. Employees who award contracts or who can influence the allocation
of business, who create specifications that result in the placement of business
or who participate in negotiation of contracts must be particularly careful to
avoid actions that create the appearance of favouritism or that may adversely
affect the company’s reputation for impartiality and fair dealing. The prudent
course is to refuse a courtesy from a supplier when CMCE is involved in
choosing or reconfirming a supplier or under circumstances that would create an
impression that offering courtesies is the way to obtain CMCE business.
1.10.Meals, Refreshments Entertainment and Gifts
We may accept occasional
meals, refreshments, entertainment, gifts and similar business courtesies that
are customary and conform to reasonable ethical practices of the marketplace,
They are not inappropriately
lavish or excessive.
The courtesies are not frequent
and do not reflect a pattern of frequent acceptance of courtesies from the same
person or entity.
The courtesy does not create
the appearance of an attempt to influence business decisions, such as accepting
courtesies or entertainment from a supplier whose contract is expiring in the
The employee accepting the
business courtesy would not feel uncomfortable discussing the courtesy with his
or her manager or co-worker or having the courtesies known by the public.
business entertainment is proper however, impropriety results when the value or
cost is such that it could be interpreted as affecting an otherwise objective
business decision. Employees with questions about accepting business courtesies
should talk to their manager or the Human Resources Department.
1.11.Offering Business Courtesies
Any employee who
offers a business courtesy must assure that it cannot reasonably be interpreted
as an attempt to gain an unfair business advantage or otherwise reflect
negatively upon CMCE. An employee may never use personal funds or resources to
do something that cannot be done with Company resources. Accounting for
business courtesies must be done in accordance with approved company
procedures. Other than to our government customers, for whom special rules
apply, we may provide non-monetary gifts (i.e., company logo apparel or similar
promotional items) to our customers. Further, management may approve other
courtesies, including meals, refreshments or entertainment of reasonable value,
The practice does not violate
any law or regulation or the standards of conduct of the recipient’s
The business courtesy is
consistent with industry practice, is infrequent in nature and is not lavish.
The business courtesy is properly
reflected on the books and records of CMCE.
1.12.Reporting Results Accurately
1.12.1. Accurate Public Disclosures
We will make
certain that all disclosures made in financial reports are full, fair,
accurate, timely and understandable. This obligation applies to all employees,
including all financial executives, with any responsibility for the preparation
for such reports, including drafting, reviewing and signing or certifying the
information contained therein. No business goal of any kind is ever an excuse
for misrepresenting facts or falsifying records. Employees should inform the
Human Resources Department if they learn that information in any filing or
public communication was untrue or misleading at the time it was made or if
subsequent information would affect a similar future filing or public
1.12.2. Corporate Recordkeeping
retain and dispose of our company records as part of our normal course of
business in compliance with all CMCE policies and guidelines, as well as all
regulatory and legal requirements. All corporate records must be true, accurate
and complete, and company data must be promptly and accurately entered in our
books in accordance with CMCE’s and other applicable accounting principles. We
must not improperly influence, manipulate or mislead any audit, nor interfere
with any auditor engaged to perform an independent audit of CMCE books,
records, processes or internal controls.
Each of us is
responsible for knowing and adhering to the values and standards set forth in
this Code and for raising questions if we are uncertain about company policy.
If we are concerned whether the standards are being met or are aware of
violations of the Code, we must contact the Human Resources Department. We take
seriously the standards set forth in the Code, and violations are cause for
disciplinary action up to and including termination of employment.
Integral to our
business success is our protection of confidential company information, as well
as non-public information entrusted to us by employees, customers and other
business partners. Confidential and proprietary information includes such
things as pricing and financial data, customer names/addresses or non-public
information about other companies, including current or potential suppliers and
vendors. We will not disclose confidential and non-public information without a
valid business or legal purpose and proper authorization.
1.12.4. Use of Company Resources
resources, including time, material, equipment and information, are provided
for company business use. Nonetheless, occasional personal use is permissible
as long as it does not affect job performance or cause a disruption to the
workplace. Employees and those who represent CMCE are trusted to behave
responsibly and use good judgment to conserve company resources. Managers are
responsible for the resources assigned to their departments and are empowered
to resolve issues concerning their proper use.
will not use company equipment such as computers, copiers and fax machines in
the conduct of an outside business or in support of any religious, political or
other outside daily activity.
Company employees by non-employees is prohibited at all times. Solicitation by
an employee of another employee is prohibited, while either the person is doing
the soliciting or the person be solicited is on working time and or Company
property. Distribution of materials by employees in work areas or on working
time is prohibited. In order to protect the interests of the CMCE network and
our fellow employees, we reserve the right to monitor or review all data and
information contained on an employee’s company-issued computer or electronic
device, the use of the Internet or CMCE’s intranet. We will not tolerate the
use of company resources to create, access, store, print, solicit or send any
materials that are harassing, threatening, abusive, sexually explicit or
otherwise offensive or inappropriate.
these principles is an essential element in our business success. Our Human
Resource Department is responsible for ensuring these principles are communicated
to and understood and observed by all employees. Day to day responsibility is
delegated to all management members who are responsible for implementing these
principles, if necessary through more detailed guidance. Assurance of
compliance is monitored and reported each year.
the code is subject to review by the board and subject to audit review.
Employees are expected to bring to management’s attention any breach or
suspected breach of these principles. Provision has been made for employees to
be able to report in confidence.
From time to
time, employees will likely have questions as to how this Code of Ethics and
Business Conduct apply in particular situations. We expect all employees with
such questions to discuss the exact circumstances with our Head of Human
Resources. Should the Head of Human Resources be uncertain on what actions
should be taken to ensure compliance with this Code of Ethics and Business
Conduct, he/she will obtain further guidance by consulting with the management.
1.14.Violations of the Business Ethics and Conduct Policy
If the head of
the organisation or governing body has reasonable cause to believe that any
employee subject to this policy has failed to disclose actual or possible
conflicts of interest, it shall inform the employee of the basis for such
belief and afford the individual an opportunity to explain the alleged failure
hearing the response of the party subject to this policy and making such
further investigation as may be warranted in the circumstances, the head of the
organization or governing body determines that the volunteer/employee has in
fact failed to disclose an actual or possible conflict of interest, it shall
direct that appropriate disciplinary and corrective action is taken.
If you have any inquiry or other matters in relation to the Code of Ethics and Business Conduct, please send an email to firstname.lastname@example.org. All incoming information will be treated with highest confidentiality. Thank you.