MEGA SQUARE SDN. BHD.

BUSINESS CODE OF CONDUCT

MSSB-001 REV.02.202306

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

OVERVIEW

Mega Square Sdn. Bhd.’s Business Code of Conduct (the “Code”) is developed to provide you
information regarding the standards of business conducts which are critical for each and every one of us
to comply and the general guidelines policies and procedures affecting your employment. This Code is
subject to modification, amendment or revocation by Mega Square Sdn. Bhd. at any time and without
prior notice.

None of the policies or guidelines in this Code is intended to give rise to contractual rights, or to be
construed as a guarantee of employment for any specific period of time, or any specific type of work.
This Code complements your employment contract or the relevant contract for services and in case of
discrepancy, the provisions of your employment contract (or the contract for services) shall take
precedence.

What Mega Square Sdn. Bhd. expects from you



This  Code  is  applicable  to all  employees  of Mega  Square  Sdn.  Bhd.  You  are  expected  to  read,
understand and  comply  with  all provisions  stipulated in this  Code  and display good judgment,
diplomacy and courtesy in your professional relationships with members of Mega Square Sdn.
Bhd.’s Board of Directors, Managers, Executives,  Customers, Suppliers, Vendors, staff, and the
general public.



Reference to “we” or “you” or “employee” in this Code includes directors, officers and
employees of Mega Square Sdn. Bhd., where the context applies to your role as an employee
and/or as a line manager (i.e. leaders, supervisors, head of departments, directors).



If you are a contractor, intern, agent, supplier or consultant working with Mega Square Sdn.
Bhd., we ask that you act consistently with this Code and apply similar standards at the course
of your work or service provision to Mega Square Sdn. Bhd., where applicable.



You have a duty to report any suspected wrongdoing in breach of the Standards of business
conducts and/or this Code. You will not suffer any form of reprisal or retaliation for reporting
any actual or suspected wrongdoing, Disciplinary action will be taken for conduct that breaches
the Standards of business conducts or this Code or is illegal.



If you have any queries related to this Code or you are not sure how to apply the provisions
stipulated in this Code, you are encouraged to consult the Personnel & Administration Manager
as higher management, where applicable.

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

A. REPORTING PROCEDURE

Anyone working for or with Mega Square Sdn. Bhd. who is concerned about actual or suspected
wrongdoing at work should report the wrongdoing. Examples of wrongdoing include:



criminal acts, including theft, fraud, bribery and corruption



endangering the health or safety of an individual or damaging the environment



bullying, harassment (including sexual harassment) and discrimination in the workplace, or
other human rights abuses



accounting malpractice or falsifying documents



other breaches of the Standards of Business Conducts or this Code



failing to comply with any legal obligation, by act or omission



concealing any wrongdoing



Fighting, arguing or attempting to injure another



Destroying or willfully damaging the personal property of another or Mega Square Sdn. Bhd.



Breach of confidentiality



Misuse or misappropriation of any confidential information obtained on the job for personal
gain



Gambling in any form within working hours and/or on the Mega Square Sdn. Bhd. premises



Dishonesty



The possession, use, sale or being under the influence of drugs or other controlled
substances or alcoholic beverages during working hours or on the Mega Square Sdn. Bhd.
premises at any time

Employees may raise their concern about an actual or suspected wrongdoing to the relevant
Supervisor, the Head of Department and/or the Personal & Administration Manager. The Supervisor
and the Head of Department shall attend to every concern or complaint raised. The Employee may
raise such concern via the Grievance Procedure as set out in Section C of this Code.

Cases  of  minor  wrongdoing  or  unsatisfactory  conduct  are  usually  best  dealt  with  informally.  An
informal discussion between the employee and his/her line manager is often all that is required to
improve an employee’s conduct or behaviour. In some cases additional training, coaching and advice
may be what is needed.

If an informal approach does not bring about an improvement, or the wrongdoing or unsatisfactory
conduct  is  considered  too  serious  to  be  classed  as  minor,  the  line  manager  (i.e.  the  Supervisor
and/or  the  Head  of  Department)  shall  raise  the  said  concern  or  complaint  to  the  Personal  &
Administration Manager, or higher management, where appropriate. The Personal & Administration
Manager  or  higher  management  shall  asses  the  concern  or  complaint  raised  and  adopt  the
Disciplinary Procedure as set out in Section C below, where appropriate.

The identity of the employee who reported the wrongdoing will be kept confidential as we fairly and
objectively investigate the wrongdoing. Employee will not suffer any form of reprisal or retaliation
for reporting the actual or suspected wrongdoing. Any such reprisal or retaliation is itself a breach of
this Code and will be treated as a disciplinary matter in accordance with the Disciplinary Procedure
as set out in Section C below.

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

B. STANDARDS OF BUSINESS CONDUCTS

I. NO EXPLOITATION OF LABOUR

We are committed to ensuring our operations are free from slavery and forced, bonded, involuntary, or
unlawful  migrant  labour.  We  will  ensure  that  the  employment  agencies  or  the  relevant  third  parties
acting on behalf of Mega Square Sdn. Bhd. will not require workers to pay  recruitment fees or other
related fees for their employment. Also, all migrant workers shall have the access to their identification
documents  (e.g.  passport) at  all  times  and the  workers  are  not  prevented  from  free  association.  The
recruitment  of  foreign  worker  is  subject  to  Mega  Square’s  Foreign  Worker  Recruitment  and
Employment Policy

Employees are free to decline overtime work or terminate their employment in accordance with their
employment  contract  and  shall  not  face  any  discrimination  or  penalties  for  exercising  this  right.
Employees  are free  to leave  the workplace  at the  end of the  working shift, free  to move  around the
workplace, such as going to the washroom or taking water breaks, without any undue restrictions.

All  employees  are  expected  to  cooperate  fully  in  implementing  and  complying  with  this  policy.  In
particular, any employee who believes that any other employee of Mega Square Sdn. Bhd. may have
violated this policy should report the possible violation to the Supervisor, the Head of Department, or
the Personnel & Administration Manager, where appropriate.

II. NO CHILD LABOUR

We are committed to ensure our operations are free from child labour. As such:



the minimum age for work should not be below the legal age for finishing compulsory schooling
and, in any case, not less than the age of 18;



where applicable, any apprenticeship program or temporary contract employment involving
young person shall not be used to avoid paying full wages or benefits..

Any employee who believes that any other employee of Mega Square Sdn. Bhd. may have violated
this policy shall report the possible violation to the Supervisor, the Head of Department, or the
Personnel & Administration Manager, where appropriate.

III. EQUAL EMPLOYMENT OPPORTUNITY

We are dedicated to providing equal opportunities to all our employees and to creating an inclusive
workforce by promoting equal remuneration for work of equal value and employment equality. We
shall  not  allow  race,  color,  religion,  national  origin,  sex,  age,  marital  status,  disability,  political
affiliation, or any other characteristic protected by law to influence our judgment when it comes to
the  recruitment,  development,  advancement,  disciplinary  actions,  salary  administration
or retirement  of  any  employee.  The  general  recruitment  principles  are  set  out  in  Mega  Square’s
Hiring Policy.

All employees are expected to cooperate fully in implementing  and complying with this policy. In
particular,  any  employee  who  believes  that  any  other  employee  of  Mega  Square  Sdn.  Bhd.  may
have  violated  this  policy  shall  report  the  possible  violation  to  the  Supervisor,  the  Head  of
Department, or the Personnel & Administration Manager, where appropriate.

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

IV. POLICY AGAINST WORKPLACE HARASSMENT AND BULLYING

All aspects of bullying and harassment are completely unacceptable. We are committed to removing
any  such  attitudes  or  actions  from  the  workplace.  Harassment  and  bullying  includes,  but  is  not
limited to, any form of sexual, verbal, non-verbal and physical behavior (whether express or implied)
which  is  intimidating,  humiliating,  offensive,  hostile  or  abusive;  or  has  the  purpose  or  effect  of
unreasonably  interfering  adversely  with  an  individual’s  work  performance  or  equal  employment
opportunities.

This  policy  applies  to  all  work‐related  settings  and  activities,  whether  inside  or  outside  the
workplace,  and  includes  business  trips  and  business‐related  social  events.  All  employees  are
expected  to  cooperate  fully  in  implementing  and  complying  with  this  policy.  If  we  witness  or
experience  such  behavior, we shall  report  it  to  the  Supervisor,  the  Head  of  Department,  or  the
Personnel & Administration Manager, where appropriate.

V. ANTI BRIBERY, CORRUPTION & WHISTLE BLOWING POLICY / CONFLICT MINERAL POLICY

Mega  Square  Sdn.  Bhd.  is committed to  conducting  its  business  in  an ethical and  honest manner,
and  is  committed  to  implementing  and  enforcing  policies  that  ensure  bribery  or  corruption  is
prevented.

For  further  details,  please  refer  to  Mega  Square  Sdn.  Bhd.’s  Anti-Bribery  Policy  &  Anti-Corruption
Policy & Whistle-Blowing Policy. All employees are expected to cooperate fully in implementing and
complying with this policy.

VI. RESPONSIBLE SOURCING OF MINERALS

Mega Square Sdn. Bhd is committed to sourcing materials and minerals (i.e. tin, tantalum, tungsten
and gold) from companies that share our values around human rights, ethics and environmental
responsibility. We expect all of our suppliers to comply with applicable legal standards and
requirements. Please refer to Mega Square Sdn. Bhd.’s Conflict Minerals Policy Statement

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

VII. ENVIRONMENT, HEALTH AND SAFETY

We strive to provide a safe  environment for the  benefit of the health and safety of all employees
and workers. Appropriate health and safety rules and procedures are in place and displayed at the
relevant  work  area,  office  or  entrance.  Good  environmental  health  and  safety  practices  are  a
responsibility of all employees. You must:



Following all health and safety rules and procedures and machinery or equipment operating
instructions



Reporting hazardous conditions to your supervisor or EHS officer or Personnel &
Administration Manager



Wearing or using prescribed protective equipment in accordance with the health and safety
rules and procedures



Reporting any job-related injury / Covid-19 related symptoms or illness of yourself, your co-
workers or others to your supervisor or Personnel & Administration Manager and seeking
treatment promptly where appropriate.

All Heads of Department must enforce safety rules to their department and to give full support of all
safety  procedures,  activities  and  programs.  The  relevant  Supervisor  or  the  Head  of  Department
must  report  to  the  EHS  officer  or  Personnel  &  Administration  Manager  of  any  health  and  safety
incidents  and/or  irregularities  and  adopt  the  relevant  emergency  management  procedures  as
appropriate.

For further details, please refer to Mega Square’s Safety and Health Policy and Environment policy.

VIII. NON‐DISCLOSURE OF CONFIDENTIAL INFORMATION AND DATA PRIVACY

Any information (including personal data*) that an employee learns about Mega Square Sdn. Bhd.,
or its subsidiaries, its suppliers or customers or any relevant third parties as a result of working for
Mega  Square  Sdn.  Bhd.  that  is  not  otherwise  publicly  available  constitutes  confidential
information.  All  employees  must  ensure  that they  handle  personal  data  in  accordance  with  local
data protection laws. Employees shall not disclose confidential information to anyone who is not
employed by Mega Square Sdn. Bhd. and to other persons or third parties engaged or contracted
by  Mega  Square  Sdn.  Bhd.    who  do  not  need  to  know  such  information  to  assist  in  rendering
services or perform tasks related to the internal operations of Mega Square Sdn. Bhd.

All employees shall cooperate fully in implementing and complying with this policy and the Privacy
Policy. Any employee who discloses confidential Mega Square Sdn. Bhd. information will be subject
to disciplinary action (including possible separation), even if he or she does not actually benefit from
the disclosure of such information.

*Personal data is information that directly or indirectly identifies an individual.

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

IX. PROTECTION OF CORPORATE ASSETS, INTELLECTUAL PROPERTY AND OTHER PROPERTIES

We must ensure the assets and properties are not damaged, misused, misappropriated or wasted
and  must  report  their  abuse,  theft  or  misappropriation  by  others.  We  are  all  responsible  for
safeguarding  and  making  appropriate  use  of  the  assets  and  properties  in  accordance  with  the
relevant  instructions  and  permitted  scope.  Assets  and  properties  include  funds  (cash,  money
advanced  to  any  employee,  company  credit  cards  held  by  employee  and  etc.),  physical  and
intellectual property, time, proprietary information, corporate opportunity, equipment, machinery,
vehicles and facilities.

We must protect all intellectual property owned by or licensed to Mega Square Sdn. Bhd. For assets
of  third  party,  we  must  never  knowingly  infringe  valid  patents,  trade  marks,  copy  rights  or  other
intellectual  property  in  violation  of  third  parties  rights  or  perform  unauthorized  activities  which
adversely impact the relevant third party.

RETURN OF PROPERTY

Employees are responsible for Mega Square Sdn. Bhd. equipment, property and work products that
may be issued to them and/or are in their possession or control, including but not limited to:



Telephone/mobile SIM cards,



Credit cards,



Identification badges,



Office/building/personal storage/lockers keys,



Office/building security passes,



Computers/laptop, computerized portable storage, and



Intellectual property (e.g., written materials, work products).

In the event of resignation, dismissal or termination of employment, or immediately upon request
by the Personnel & Administration Manager or his or her designee, employees must return all Mega
Square Sdn. Bhd.’s equipment, property and work product that are in their possession or control.
Where permitted by applicable law(s), Mega Square Sdn. Bhd. may withhold from the employeeʹs
final paycheck the cost of any property which is not returned when required. Mega Square Sdn. Bhd.
also may take any action deemed appropriate to recover or protect any such property.

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

C. DISCIPLINARY AND GRIEVANCE PROCEDURE

I. DISCIPLINARY PROCEDURE

1. Purpose and scope

Mega  Square  Sdn.  Bhd.’s  aim  is  to  encourage  improvement  in  individual  conduct  or  code  of
practice. The disciplinary procedure sets out the action which will be taken when an employee is
alleged with suspected or actual wrongdoings  in which the informal approach as stipulated in
Section A does not improve the said employee’s conduct or practices. Disciplinary procedure will
also be applicable to the suspected or actual misconduct at work, for example, habitual lateness
in  reporting  for  duty,  absence  from  work  without  Supervisor's  consent  or  approval,
insubordination,  non-performance  or  other  conduct  that  contravenes  the  company’s  rules  or
the employment contract, where appropriate.

2. In the event there is any security or physical searches is required for the investigation of the

wrongdoings or complaint, the P&A Manager shall ensure that it is done in a non-intrusive
manner, in a private space (where possible, under video surveillance) and done by an opposite
sex without causing distress or discomfort to the employee.

3. Disciplinary procedure is available at www.megasquare.com.my/publications/..

II. GRIEVANCE PROCEDURE

The Grievance  Procedure  is applicable to  a problem or concern that an employee has about  their
work,  working  conditions,  career  progression,  relationships  with  colleagues  or  managers  or  any
other  problem/concern  encountered  at  work  (including  any  harassment,  bullying  or  any  other
wrongdoings as per Section A).  The procedure shall be adopted by all employees and the relevant
line  manager,  the  Head  of  Department  or  the  Personnel  &  Administration  Manager  and  the
Management team.

The Employee will not suffer any form of reprisal for reporting or raising a grievance, concern, issue.

1.  Dealing with grievances informally

If an employee has a grievance or complaint or would like to whistle blow, such employee
should, wherever appropriate, start by talking it over with his/her leader, supervisor or his/her
head of department. Such employee may be able to agree a solution informally between he/she
and the leader, supervisor or his/her head of department.

2. Formal grievance

At the discretion of the employee, the employee may choose to initiate whistle blow or raise the
grievance or complaint through other channel (i.e. not through the leader, supervisor or his/her
head of department), such employee may choose to raise the grievance or complaint through
the following options:

a) Anonymous option: the Company’s “Let’s Talk” portal available through QRCode scan (available on

the departmental notice boards or accessible by URL: https://megasquare.com.my/publications/ );

b) speak or send an email to the Personnel & Administration Manager ( 05-5951555 /

sahul@megasquare.com.my);

c) speak or send an email to the General Manager ( 05-5951523 / sywai@megasquare.com.my); or
d) speak or send an email to the Managing Director ( 05-5951510 /

mfwai@megasquare.com.my

); or

e) send an email to concern@megasquare.com.my.

MEGA SQUARE SDN BHD

MSSB BUSINESS CODE OF CONDUCT

Document No. : MSSB-001

REV.02

3. Receipt of grievance, concern, issue raised by employee

No matter how the employee chooses to raise the grievance, issue, or concern, his/her identity
will be kept confidential by the management team and investigation will be conducted fairly and
objectively without the involvement of anyone whom the grievance, issue or concern is related
to or is in conflicted interest.

All grievance, concern, issue raised by employee, the progress and outcome of the investigation
will be reported to and/or reviewed by the top management team.

4. Grievance hearing

If the Company is able to contact the employee, a meeting with the concerned employee within
2 weeks will be arranged to discuss and investigate the grievance raised , unless such grievance
is raise anonymously which the Company is not able to contact the employee. The concerned
employee has the right to be accompanied by a colleague at this meeting. Upon conclusion of
investigation and the action plan, the P&A Manager or the relevant HOD will communicate the
outcome and action plan following the investigations to the concerned employee.

5. Appeal

If  the  employee  who  raises  a  concern  under  this  procedure  is  unhappy  with  the  decision  and
such  employee  should  appeal  through  the  channels  provided  in  section  2  above.  An  appeal
meeting will be arranged and attended by a more senior manager, e.g. the General Manager or
the Managing Director. After the meeting, a decision will be provided and the decision from the
appeal meeting is final.

If you have any questions regarding any of the policy guidelines listed above, please contact your

Supervisor, your Head of Department or the Personnel & Administration Manager.