Image Magic Printing Sdn Bhd
Introduction
Image Magic Printing Sdn Bhd (refer as “Imagic”) is committed to meeting or exceeding all laws and regulations wherever we conduct our business activities. Imagic expects all employees understand legal and policy requirements that apply to their job and all business activities and to conduct them with uncompromising honesty and integrity.

This Code of Ethics and Conduct sets out the acceptable practices and ethics that guide the employees of the Imagic Group of Companies (“Imagic Group / Company/ Imagic”).

Imagic reserves the right to add, amend, vary or modify the provisions set out in this Code of Ethics and Conduct as and when it deems necessary and in the best interest of the Company. Employees will be notified of any changes made to the Code of Ethics and Conduct.

Scope
All employees, including temporary employees, must comply with this Code of Ethics and Conduct and agree to comply with its terms throughout their employment or tenure with the Company.

This Code of Ethics and Conduct applies to all business activities with suppliers, contractors, clients, customers, shareholders and employees in Malaysia and overseas.

The Code must be read in conjunction with the relevant company policies.

Compliance with Laws and Regulations
Imagic and its directors, officers and employees, regardless of their role and position, must be aware of and comply with, the duties and obligations which apply to them under any laws, legislation or regulations relevant to their work, role and responsibilities.

Enforcement
An employee who disregards or violates a provision of this Code of Ethics and Conduct, condones or knowingly fails to report a possible violation, deliberately makes a false report or fails to cooperate fully in any investigation of any violation, will be subject to disciplinary action, up to and including the punishment of dismissal. In addition, disciplinary action may also be taken against any employee who through lack of diligence or supervision, fails to prevent or report violations.

Business Communication
All employees of the Imagic Group are expected to exercise due care, diligence and etiquette in all work-related communications, be it in written form, verbal or otherwise, and to ensure that the contents are clear, truthful, courteous and accurate.

Imagic is committed to have zero tolerance policy for any communications made by its employees over the course of business and/or using Imagic’s resources that contain any material found to be discriminatory, defamatory, offensive, contains sexual connotations, pornographic, misleading and/or any other communications of a similar nature.

Fair Dealing
Imagic aims to maintain the highest standard of ethical behaviour in business dealings and to behave with integrity in all its dealings with customers, clients, shareholders, government, employees, suppliers and the community.

Each of us must ensure that our actions, and the actions of those who report to us, deal fairly with Imagic's customers, clients, suppliers, competitors and employees. Our aim is that Imagic acts honestly and fairly in all its business dealings.

Each of us must always in full compliance with all applicable antitrust, competition and fair dealing laws.

Employees are encouraged to familiarise themselves with the legal requirements applying to fair dealing and when in doubt, employee shall undertake training or attend seminars to develop and maintain their knowledge, so that they can act in accordance with these requirements.

Conflict and Interest
Conflicts of interest arise in situations where there is a personal interest that might be considered to interfere with that person’s objectivity when performing duties or exercising judgement on behalf of the Imagic. Employees should avoid or deal appropriately with situations in which personal interest could conflict obligations or duties. Employees must not use their position, official working hours, Imagic resources and assets for personal gain or to the Imagic’s disadvantage.

It is Imagic’s policy that employees should not permit private interests to conflict, or to appear to conflict with their duties and responsibilities.
• Employees are to be guided solely by the best interest of the Company when conflicts or appearances of conflict may present themselves.
• Employees are also expected to observe and maintain high standards of ethical conduct in their relationship with all parties they deal with.
• Employees must avoid situations where their personal interests could conflict with the interests of Imagic.

The following are the overall ethical tenets:
• No employee may benefit directly or indirectly from Imagic's dealings with others.
• No employee may serve business interests that compete with Imagic.
• No employee may involve in any political activities or public official unless they have prior written approval from their line manager and Company.
• No employee should allow outside business or work activities interfere with their Imagic job performance.

Imagic sets out the procedures on how to deal with conflicts of interests arising with a selected group of individuals and entities, including:
i. Dealing with suppliers, contractor, customers, client, agents and competitors;
ii. Personal dealings with suppliers, clients and customers;
iii. Outside employment and activities outside the Company ;
iv. Board membership;
v. Family members and close personal relationships; and
vi. Investment activities.

Commercial Bribery
Commercial bribery is illegal and against the laws. Even in some situation where such activity may not, technically speaking, be illegal, it is absolutely prohibited by Company policy.

The actual or attempted use of any form of bribery either directly or indirectly on the Imagic’s behalf to advance personal or business interests is strictly prohibited. A bribe may be in the form of cash, gifts, entertainment, hospitality, travel perks or special favours or privileges.

Employees must not give, offer, promise, accept, request or authorize a bribe whether directly or indirectly, on behalf of, or for the benefit of the Company.

Anti Money Laundering
Under the Malaysian anti money-laundering law, money laundering is deemed, inter alia, as “act of a person who engages directly or indirectly in a transaction that involves proceeds of an unlawful activity.” The Company shall apply such similar definition in all its operations whether locally or otherwise.

All employees are strictly prohibited and shall not at any time during the employment with the Company assist, abet, involve whether directly or indirectly in any activity in connection to money laundering. All employees are expected to exercise high level of due diligence in all business transactions and when entering into business relationship to prevent and detect possible money laundering activities.
An employee who is involved and/or commits a money laundering activity will result in disciplinary action being taken against him/her, including the punishment of dismissal.

Gifts, Entertainments and Gratuities
Imagic is conducting business on the basis of the superior value of goods and services we buy and sell. Imagic’s policy on gifts, entertainment and gratuities is designed to preserve and maintain a work environment where trust is of paramount importance. All Imagic Group companies, and/or their employees shall refrain from offering, giving, demanding or receiving bribes and/or any other improper gratification.

Receiving gifts, entertainment or other gratuities from people with whom we do business is generally not acceptable because doing so could imply an obligation on the part of the Imagic and potentially pose a conflict of interest.

If, under any circumstances, refusal appears impossible or would create business repercussions, then on relatively rare occasions gifts may be accepted, but their ultimate disposition should then be discussed as soon as possible with your line manager. In some cases, you can avoid the conflict by donating the gift to charity or having it become Company property.

Fraud and Dishonesty
Employees must not enter into fraudulent activities. Fraud is an intentional act or omission designed to deceive another or the Company to achieve a personal gain.

Engaging in any act that involves fraud, theft, embezzlement or misappropriation of any property, including that of the Company, or any of its employees, suppliers or customers is strictly prohibited.
 
Some examples of fraudulent conduct/activities are:
a. Falsification or manipulation of accounting records or documents;
b. Misappropriation of company assets for personal gain;
c. Embezzlement;
d. Acceptance or payment of bribes or kickbacks

In the event that evidence of a fraud or crime by or involving an employee against the Company is established, his/her employment may be terminated, following proper investigations and due inquiries in accordance with established employment practices and legislation. The Company may also consider reporting the matter to the authorities as well as initiating legal proceedings to recover any loss suffered by the Company as a result of the fraud, dishonesty or crime.

All employees play an important role in the prevention and detection of fraudulent activities. It is the Company’s policy to ensure that incidents of fraud are promptly investigated, reported and, where appropriate and authorized by applicable law, prosecuted. If an employee suspects that a fraud or fraudulent activity is being committed, the employee should report to Line Manager or The Audit Committee.

Personal Behavior In The Workplace
Imagic is ensuring that human rights are upheld across our operations and committed to ensuring that all employees work in an environment that promotes diversity and where there is mutual trust, respect for human rights and equal opportunity, and no unlawful discrimination or victimisation. Imagic and its employees must do to ensure that all workplaces maintain such an environment.

Imagic is committed to compliance with all applicable laws and regulations relating to equal employment opportunity, non-discrimination, and similar employee-related matters. We also committed to provide equal employment opportunity to all types of jobs and at all levels of the work force. It is our policy to provide a workplace free from any kind of discrimination, harassment or intimidation because of race, color, descent, religion, gender, age, place of birth, citizenship, sexual orientation or disability or any other basis as gross violation of ethics. Harassment of any kind, foul language, derogatory remarks and profanities are to be avoided to maintain good relationships. Line managers are directly responsible for the general well being of employees in their charge.

Where an employee feels that he or she has been subjected to any unwanted conduct of a discrimination, harassment or intimidation, the following procedure will apply:
i) Employee raises complaint through fill up e-form
ii) The Audit Committee will then proceed to investigate the complaint discreetly.
iii) The investigation may lead to a domestic inquiry that can result in the dismissal of the employee found guilty of such misconduct.
Imagic will promptly investigate all allegations of harassment, bullying, victimisation or discrimination and will take appropriate corrective action. All complaints will be treated seriously, sympathetically, quickly and privately. Strict disciplinary action for violations of this policy will be taken, including termination of employment.
 
Responsibility on Company's Property
Employees must take proper care of Company’s equipment, tools or property which are under the care of the employees and must not neglect, abuse, use the equipment in an unauthorized manner or steal property that belongs to Company.

All employees shall bear in mind that all Company’s equipment such as, photocopy machine, telephone, computer, printer, fax machine, etc, and stationery including all papers and envelopes are Company’s property and should not be misused for personal usage unless with approval.

Computer Sustems - Security and Control
All Company’s computer systems, network, equipment (including portable equipment and mobile facilities), software, data network, electronic and digital storage as well as data and information contained therein shall be the property of the Company.

The primary usage of Company’s computer system, email and internet is for business purposes only. Although the Company permits the occasional personal use of the computer system, employees are expected to limit such usage within a reasonable purpose and it should not interfere with the execution of their job functions. The Company will retain the right to access its computer system (including all back-up Company data using external storage) and emails.

The Company may search and monitor employees’ emails and internet usage, conducted through the Human Resource department and or outsource supplier. Any communications sent and received by an employee using the Company’ computer or any communication devices should not be deemed to be private and confidential. Employees should not use the Company’s computer system, email or network to access, view, create, transmit, retrieve or store any improper material that is discriminatory, derogatory to any persons, defamatory, harassing, obscene, threatening or any illegal materials, regardless of its format.

The Company monitors its computer system and network to prevent improper usage and/or security violation. Under no circumstances should an employee modify the Company’s computer system or equipment, whether by installation of hardware, software, or any other means, without the express written approval by the Company.

Employee should not send or receive copyrighted materials, trade secrets, proprietary financial information or similar information and/or material without the authorization of the Company.

Employees must be alert at all times for phishing emails, online scams and other suspicious emails. Employees are required to do proper validation and verification before reply or perform any action requested from a sender using suspicious emails address. Employees should not open any suspicious emails or any attachment or links contained therein. If employee receive material or email that violates this policy from any persons outside the Company or from an internal sender but with suspicious email address through the Company’s computer system, employee should promptly delete the offending material or email and escalate the case to the Human Resource department.

Employee should not send or receive copyrighted materials, trade secrets, proprietary financial information or similar information and/or material without the authorization of the Company.

Employees must use approved Company software at work. Employees may not duplicate Company software (other than for backup and archival purposes) for business or personal use. This includes proprietary or internally developed software. The policy applies to employees at all locations.

Use of the Company’s computer systems and networks in violation of this policy will result in disciplinary action, up to and including the penalty of dismissal.

Password - Security and Control
Passwords are the customary means to control access to computer systems. In most cases, a password is unique and known only to the individual authorized to use it. It authenticates the individual's identity and validates that the access is authorized. Properly administered, password control systems provide accountability for each access and for the manner the access, once gained, is used.

Accordingly, since passwords are essential safeguards of vital assets, employees who without authority, disclose their own passwords to others or who possess or attempt to obtain the passwords of others, may be charged with or suspected of improper computer use and would be liable to disciplinary action including dismissal.
 
Private and Confidential Data
Data and text can be reproduced and/or copied with great speed. This increases the risk of misappropriation or improper disclosure. All employees should ensure that data (whether in computerized or printed form) private to an individual or confidential to the business are not easily compromised by disclosure or misappropriation. For example, sensitive computer printouts should not be left in the open or haphazardly discarded.

Using personal business computers to process or produce sensitive information is a matter of particular concern, because the storage medium, external hard disk, pen drive, can be easily appropriated or quickly copied. Employee should store computer, laptop, any form of storage devices containing sensitive information in a locked location or off mode when not in use.
If you have questions concerning your security and control responsibilities, or desire guidance in meeting them appropriately, contact the Human Resource Department.

Personal Information and Privacy
Every employee’s personal information is important to us and when we collect, process, use and disclose personal information in accordance to the Company’s Privacy Policy, we must ensure it is the minimum necessary, for our business needs, such as to meet specific human resources or legal purposes.

All personal information obtained during the course of your employment is deemed to be confidential information and sharing of any of such information to third parties, including employees, are strictly prohibited.

All employees must respect other employees’ privacy. Employees must not divulge, disseminate or share any personal information and/or sensitive information of other employees, business associates or customers to unauthorized persons in or outside the Company.

Use of Social Media
Employees are to exercise good judgement and personal responsibility whenever using personal social media sites and tools. Employees are strictly prohibited from disclosing the Company’s non-public or confidential information and/or engaging in rumours or speculations about the Company in your personal social media activities.

Employees are expected to be respectful and professional when using a personal site or account that may identify you as an employee of the Company.

Whistleblowing
Imagic encourages employees to raise genuine concerns, including the reporting of unlawful, unethical or questionable behaviour, in confidence and without risk of reprisal
This policy covers, but is not limited to
a. Abuse of Power;
b. Bribery;
c. Breach of law;
d. Criminal Activity;
e. Conflict of Interest;
f. Danger to health and safety or the environment;
g. Fraud
h. Overpayment to suppliers or under any contract;
i. Miscarriage of justice;
j. Misuse of any property belonging to the YTL Group;
k. Negligence;
l. Theft or embezzlement; and/or
m. Non-compliance with Imagic (or any company under the Imagic Group) policies, including cover-up of any of the above in the workplace.

If any employee has concerns about any of the matters set out above or that the integrity of the Imagic Group is being compromised in any other way, or have any information with respect to any violation or suspected violation, the employee should report such information to your superior or bring the matter to the attention of the following where appropriate:
• Line Manager
• Human Resources Department
• The Audit Committee

All such submissions will be treated confidentially, to the extent reasonably practicable. To assist and encourage the prompt reporting of suspected violations, Imagic will accept reports made on an anonymous basis.

Employees must exercise sound judgment to avoid baseless allegations. Employees who intentionally file false reports will be subjected to disciplinary action and possible termination.

Child Labor and Worker Policy
Imagic does not permit to use child or forced labour in any operations or facilities. We comply to local legal minimum working age and do not tolerate unacceptable worker treatment, such as exploitation of children, physical punishment or labour, or involuntary servitude. We expect our suppliers, business partner, contractors with whom we do business to uphold the same value and standards. Whenever there is a pattern of violation of these principles become known to Imagic and not be corrected, Imagic will discontinue the business relationship.

Health, Safety and Environmental
Imagic is committed to maintaining a healthy and safe working environment for its employees. All appropriate laws and internal regulations must be fully complied with. Everyone have obligations to assist in ensuring that this situation is well maintained. Misusing controlled substances or alcohol or selling, manufacturing, distributing, possessing, using or being under the influence of illegal drugs or when using medication improperly on the job will not be tolerated.

Employee must be aware of Imagic's Health and Safety relevant procedures to ensure the workplace is safe and without risk to the health of others and yourself and follow any lawful and reasonable instructions consistent with those procedures.

Fair Competition
Imagic believes in vigorous yet fair competition because we all benefit from fair, free and open markets. Imagic and employees will conduct their operations in comply with the principles of fair competition and all applicable regulations.

All employees must at all times adhere to the following rules:
a. Commercial policy and prices will be set independently and will never be agreed, formally or informally, with competitors or non-related parties, whether direct or indirectly.
b. Customers and suppliers will be dealt with fairly.
c. Collecting competitive information through proper public or other lawful channels but do not use information that was obtained illegally or improperly by others, including through misrepresentation, invasion of property or privacy, or coercion.
d. Do not disparage the products or services of a competitor.
e. Take care that participation in industry or trade associations events and related contacts are not used for anti-competitive purposes; this also applies to less formal meetings or events that involve competitors, such as awards ceremonies or associated social contacts.
f. Report incidents of inappropriate discussions immediately to line manager.

Continuous Improvement Process
The Company highly values "Continuous Improvement Process", innovation and teamwork for its further progress and continuity. To encourage employees to keep on looking for improvements in whatever they do, all line managers are expected to have regular consultation, counselling and coaching interactions with employees in their charge. Line Manager are also expected to encourage employees to pursue their selfimprovement and development.

Disclaimer
This Code of Ethics and Conduct is a statement of certain fundamental principles, policies and procedures that govern actions in the conduct of Imagic's business. It is not intended to, and does not create, any rights in any employee, client, customer, supplier, competitor, security holder or any other person or entity.