Our Commitment

HICOM AUTOMOTIVE MANUFACTURERS (MALAYSIA) SDN BHD (HA) is committed to upholding the highest standards of ethical conduct, integrity and accountability in all its business activities and operations. HA has a zero-tolerance policy towards any form of bribery and corruption by its Employees or any persons or companies acting for or on behalf of HA. Anti-Corruption Policy reflects HA’s commitment to fight any corrupt and unethical practices while conducting business, by:

1. Providing, practicing and maintaining a working environment free from bribery and corrupt practices for all Employees and stakeholders;
2. Complying with all anti-bribery and anti-corruption related laws, acts, rules and regulations, procedures and other instructions;
3. Providing an avenue and to encourage all Employees and stakeholders to report on bribery and corrupt practices as stipulated in the “DRB-HICOM’s Whistleblowing Policy”;
4. Imposing the appropriate action to any party proven to be guilty of being involved in bribery and corrupt practices; and
5. Implement and enforce effective and robust policies and procedures to prevent, monitor and eliminate bribery and corrupt practices.

DRB-HICOM Berhad (“DRB-HICOM”, “Company”, “we”, “us” or “our”) has established conduct standards for its business relationships that reflect our shared values of excellence, decorum, teamwork, integrity, innovation, quality, as well as transparency. All companies under the DRB-HICOM (collectively known as “DRB-HICOM Group of Companies”) are expected to ensure that its Vendors share and embrace this commitment to regulatory compliance.

The VCOC applies to all vendors supplying goods and services (“Vendor”, “Vendors”, “your” or “you”) to DRB-HICOM Group of Companies.

Vendor Responsibility & Compliance to VCOC

1. While Vendors are independent entities from DRB-HICOM, the business practices and actions of the Vendors, when conducting business with or on behalf of the Company, may significantly affect and reflect our Company. Therefore, DRB-HICOM expects all Vendors and their employees, agents and subcontractors to abide by our high ethical standards set forth in this Vendor Code of Conduct (“VCOC”) guidelines, while conducting business with us or on our behalf.
2. As reflected in the DRB-HICOM’s VCOC, the Company is committed to high standards of integrity and sustainability. DRB-HICOM has a “zero tolerance” policy when it comes to unethical business behaviour, such as bribery, corruption, and forced labour. We expect all of our Vendors to adhere to similar standards and to conduct their business ethically.
3. As Vendors of DRB-HICOM, you must comply with all applicable laws and regulations, the requirements set out in this VCOC and your respective contractual obligations to us.
4. DRB-HICOM may take necessary and appropriate action for any breach of the VCOC, which may include but is not limited to debarment and preclusion from proposing any work to DRB-HICOM for a pre-determined period. In addition, all legal rights of DRB-HICOM are reserved notwithstanding any action undertaken by DRB-HICOM in respect of this clause.

VCOC Main Principles

This VCOC defines the main principles underlying your business activities as one of our Vendors. The following three (3) principles ensure sustainable development in our supply chain:

a. Environment

b. Social

c. Governance & Ethics

a. Environment

(a) Safety, Health and Environmental

1. Vendors shall be responsible for the safety of all persons who may be affected by their activities and shall comply with the Company’s safety regulations and procedures.
2. Vendors shall ensure that all works undertaken complies with all the safety, health and environmental regulations and guidelines of Malaysia.
3. Vendors shall comply with all applicable local authority requirements and regulations, with all permits and records obtained, kept and properly recorded.
4. Vendors are encouraged to supply less environmentally- and socially-damaging products which consider all phases of the products lifecycle i.e. production, transportation, maintenance and disposal.
5. DRB-HICOM encourages Vendors to institute effective environmental management systems which details the process of managing their environmental impacts and implement as appropriate.

b. Social

(a) Professional Conduct

1. Vendors shall respect the personal dignity, privacy and rights of each individual.
2. Vendors shall not engage or be involved in any type of harassment and violence.
3. Vendors shall not commit prohibitive behaviour including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative.
4. Vendors shall not engage or be involved in any activities that may be categorized as a crime that is punishable under Malaysian law.

(b) Wages & Working Hours

1. Vendors shall ensure that their employees are fairly compensated and that, at a minimum, they comply with all applicable wage and hour laws, or industry standard.

(c) Labour standards and protection

1. Vendors shall ensure fair labour conditions, and that all immigration regulations in Malaysia are adhered to with respect to the employment and work permits of their employees.
2. Vendors shall ensure fair labour condition for their employees, and compliance to all relevant laws and regulations including but not limiting to prohibition of human trafficking, child labour, forced labour, bonded labour, indentured labour, involuntary prison labour, slavery or human trafficking.
3. In hiring and practices such as promotions, rewards, and access to training, Vendors shall not engage in discrimination based on race, colour, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status.

(d) Community Engagement

1. Vendors are encouraged to help foster social and economic development and contribute to the sustainability of the communities in which it operates.

(e) Working and Living Conditions

1. Where applicable, DRB-HICOM expects all Vendors to comply with The Workers’ Minimum Standards of Housing and Amenities Act 446 (Amendment) 2019. The act has been extended to all employment sectors providing housing and accommodation for workers, and also seeks to improve the Guidelines for Foreign Workers Accommodation 2018 by the Department of Labour of Peninsular Malaysia (JTKSM). This covers the minimum standard accommodation space, basic facilities for workers’ accommodation and elements of security and hygiene.
2. Vendors are to provide a safe and healthy work environment. Adequate steps shall be taken to minimise the causes of hazards inherent in the working environment and establish a hygienic work environment.

(f) Responsible Sourcing of Materials

1. DRB-HICOM expects all Vendors to obtain materials with full deliberation and care to avoid the sourcing or usage of materials which are unlawful or obtained through unethical or unacceptable means (such as sourcing of conflict minerals* or manufactured by using slave, forced or child labour). DRB-HICOM expects our suppliers to undertake similar measures with their own suppliers to ensure elimination of conflict materials across the supply chain.

*Minerals originated from conflict regions that directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses

c. Governance & Ethics

(a) Anti-Bribery & Corruption

1. Vendors shall strictly observe and comply with applicable anti-bribery and anti-corruption laws and regulations, which may include, but are not limited to the Malaysian Anti-Corruption Commission Act, 2009 (Act 694) and its amendments.
2. Vendors shall strictly observe and comply with DRB-HICOM’s Anti-Bribery and Anti-Corruption Policy, Group Procurement Policy, this VCOC as well as any other relevant policies, standard operating procedures, and work instructions.
3. DRB-HICOM expects the Vendors to implement anti-bribery and anti-corruption management systems or put in place adequate and appropriate controls to enable DRB-HICOM or any other organisations manage the risks of bribery and corruption that may reasonably arise in business dealings and/or relationships.
4. DRB-HICOM requires Vendors to demonstrate full commitment to preventing bribery and corruption in the business dealings and/or relationships.
5. Vendors must conduct business in the most ethical manner and shall avoid any practices that could be construed as bribery, corruption or business malpractices.
6. Vendors shall not engage or involve in any acts of bribery or corruption. The giving or agreeing to give or promising or offering of any gratification as an inducement or a reward to any person with the view to influence the placing of any order/award/contract will result in the instant revocation/termination of any award/contract.

(b) Intellectual Property Rights

1. Data of any kind, such as sketches, drawings, models and the likes shall be returned to DRB-HICOM as soon as they are no longer necessary for the completion of works.

(c) Maintain Accountability

1. Vendors shall maintain full accountability for services rendered / goods supplied and honour their commitments on a timely basis and in accordance with their obligations under the specific agreements and undertaking with DRB-HICOM.

(d) Gift & Entertainment

1. Vendors are not permitted to offer or sponsor any social entertainment or personal trips for employees of DRB-HICOM.
2. During a tender / RFQ process, Vendors shall refrain from entertaining or treating any employees of DRB-HICOM or their family members who involved in the evaluation such as providing special invitation to events or offering a vacation.

(e) Fair Dealings & Integrity

1. Vendors shall conduct all procurement and business relationships with honesty, integrity, respect and fair manner.
2. Vendors shall endeavour to deal fairly and should not take unfair advantage of anyone through the manipulation, concealment, abuse of privileged information, misrepresentation of material fact or any other unfair business practices.

(f) Honest Representation

1. Vendors shall provide honest and open representation of their organisation, its qualifications, experience and capabilities.
2. Vendors shall disclose accurate references of previous work or engagements which they have undertaken.

(g) Conflict of Interest

1. Vendors shall declare any potential or actual conflicts of interest to DRB-HICOM even if it happens after the appointment, and/or to immediately address the conflict as soon as it is known.
2. If in doubt, Vendors shall highlight the conflict to DRB-HICOM immediately.
3. Vendors shall disclose if any of DRB-HICOM employee or family members has an interest in the Vendor’s business.

(h) Confidentiality of Information & Data Protection

1. Vendors must undertake that all confidential information shall not be disclosed, given access to, procured, gathered, collected, received or handled by any third party without written consent from the Company.
2. Vendors shall not make use the DRB-HICOM employee’s name or the Company name for publicity purposes without the written consent of the employee or Company.

Two-way Engagement

DRB-HICOM looks forward to hold regular engagement sessions with its Vendors in order to achieve compliance to this VCOC and to understand Vendors’ concerns. Should Vendors have difficulties in implementing the principles of the VCOC, DRB-HICOM is willing to work with the Vendors towards achieving full compliance.

Self-Monitoring & Self-Assessment

Suppliers are responsible for self-monitoring their compliance with this VCOC. DRB-HICOM may ask the Vendors to assess their compliance by answering the on-line VCOC self-assessment questionnaires.

If and when any situation arises that causes the supplier to operate in violation of this VCOC, supplier should inform DRB-HICOM’s key contact as soon as possible. Suppliers are expected to cooperate fully in any investigation.

On-Site Audits

DRB-HICOM and/or an authorized third party acting on our behalf may verify compliance to the VCOC on site.

Raising Concerns / Whistle Blowing

DRB-HICOM encourages the Vendors to report or disclose any attempted, suspected, and actual improper conducts or business malpractices through the established whistleblowing channels as follows:

Any report or disclosure will be dealt in confidential manners, to protect the identity of the whistleblower or reporter, and of others involved or reference in the report.

Improper conduct among others include:

1. Suspected or actual incidents of fraud or corruption, breaches in any law or regulations in Malaysia, Company’s policies, procedures or legal obligation and misleading or deceptive conduct of any kind
2. Auditing matters, including non-disclosure or any subversion of the internal or external audit process
3. Breach of confidentiality obligations
4. Abuse of authority
5. Criminal breach of trust
6. Criminal offence
7. Embezzlement / misappropriation of company’s funds
8. Profiteering based on inside knowledge of the Group’s activities
9. Misuse of company information
10. Forgery / alteration of any document or account within the Group
11. Procurement fraud / suspicious dealings
12. Negligence
13. Impersonation of officials
14. Money laundering
15. Workers compensation fraud
16. Asset misappropriation
17. Customer complaints about the Group’s services and/or complaints received through the Public Complaints Management System (“SISPAA”)
18. Any other detrimental wrongdoings and improper conduct

Complaint Types

A Whistleblower’s complaint is information relating to improper conduct of any staff, consultant or contractor of DRB-HICOM Group of Companies.

Whistleblowing Procedure

Purpose

The DRB-HICOM Group’s Whistleblowing Policy outlines the Company’s commitment to ensure that employees are able to raise concerns regarding any illegal conduct or malpractice without being subjected to victimisation, harassment or discriminatory treatment, and to have such concerns properly investigated.

The Whistleblowing Policy sets out the mechanism and framework by which employees, business associates, and third parties can confidently and anonymously, if they wish, voice concerns/complaints in a responsible manner without fear of discriminatory treatment.

Required Information

Your complaint has to be submitted together with the following information:

Type of activity / conduct

1. Details of suspected personnel involved
2. Details of incident (including place, date and time of incident, as well as names of those involved)
3. Transaction amount and type (if it is known)
4. Any document, information or physical evidence relating to the complaint

Protection

All disclosures made under this policy will be dealt with in a confidential manner.

The identity of all complainants will be kept confidential and protected.

Whistleblowers are protected under the Laws of Malaysia Act 711:

The Whisteblower Protection Act 2010

Making a complaint under the Whistleblowing Policy does not shield the complainant from consequences if it is found that the person is also involved in the same / other improper conducts or unlawful activity under the Policy.

How to Report?

All complaints and improper activity reports can be made through these channels:

1.Call the Whistleblowing Hotline

1-800-88-2005

2.Send an e-mail to

whistleblowing@drb-hicom.com

3.Post a letter to

Group Internal Audit & Integrity Division

Level 5, Wisma DRB-HICOM,

No. 2, Jalan Usahawan U1/8,

Seksyen U1, 40150 Shah Alam,

Selangor Darul Ehsan, Malaysia

4.Drop your complaint into the

Whistleblowing Box located at Level 1 and Level 5 of Wisma DRB-HICOM

All these channels lead to the Chairman of the Board of Directors, Chairman of the Board Audit Committee and/or the Chief Internal Audit & Integrity Officer based on the following matrix

For mailed in reports, they must be placed in a sealed envelope labelled “Strictly Confidential. To be opened by Addressee only.” on the top left-hand corner.

All information received from the Whistleblower will be treated with utmost confidentiality.