This Code sets the minimum standards of ethical and professional conduct expected at Image Magic Printing Sdn Bhd (“Image Magic”). It applies to directors, permanent and temporary employees, interns, agency personnel and other persons acting on behalf of Image Magic. Suppliers, contractors and business partners are expected to uphold compatible standards when working with us.

The Code applies to conduct in the workplace, at customer or supplier premises, during deliveries and events, when using company systems, and whenever a person represents or could reasonably be associated with Image Magic.

• Read this Code together with employment terms, departmental procedures, safety instructions, the Privacy Policy and other company policies.
• Ask a supervisor, Finance & Human Resources, or the Managing Director when a requirement is unclear.
• Choose the lawful, honest and responsible course when a situation is not specifically covered.
• Where a law, customer contract or internal rule is stricter than this Code, follow the stricter requirement.

Our values guide daily decisions, from customer service and artwork handling to production, purchasing, delivery and financial administration.

Everyone must comply with applicable laws, company policies, approved procedures and lawful contractual commitments relevant to their role. No employee is expected or permitted to break a law, safety rule or this Code to meet a sales target, deadline or instruction.

Management responsibilities

• Lead by example and communicate that ethical conduct is part of job performance.
• Provide reasonable guidance, training, resources and supervision.
• Do not pressure, reward or ignore conduct that breaches this Code.
• Respond promptly to questions, hazards and reported concerns.
• Escalate serious issues instead of trying to conceal or privately settle them.

Individual responsibilities

• Understand the requirements relevant to your duties.
• Complete assigned training and follow approved work instructions.
• Raise questions before acting when a decision may create legal, ethical, safety or reputational risk.
• Report known or reasonably suspected serious misconduct in good faith.

Image Magic communicates clearly and deals fairly with customers, suppliers, employees and other stakeholders. Information must not be intentionally false, incomplete or misleading.

• Describe products, materials, quantities, finishing, production times and delivery estimates accurately.
• Issue quotations, invoices, credits and receipts based on approved prices and genuine transactions.
• Disclose material errors promptly and take reasonable steps to correct them.
• Do not hide charges, make unsupported quality or environmental claims, or promise a deadline that has not been accepted.
• Do not create false reviews, impersonate a customer, manipulate complaint records or suppress legitimate feedback.
• Handle complaints respectfully and apply published policies consistently.

A conflict of interest exists when personal, family, financial or outside business interests could influence—or appear to influence—an Image Magic decision. Employees must disclose actual, potential or perceived conflicts promptly and must not make or influence the affected decision until guidance is received.

• Disclose close personal or family relationships with a customer, supplier, applicant, contractor or employee where you can influence a decision.
• Do not receive undisclosed commissions, rebates, referral fees, personal discounts or other benefits connected to company business.
• Do not use company time, customer information, equipment, purchasing power or opportunities for an outside business or personal gain.
• Outside employment must be lawful, must not compete with Image Magic, and must not interfere with work or create confidentiality risks.
• Personal political activity must be conducted in a personal capacity, outside working time and without company resources, pressure on colleagues or an implication of company endorsement.
• Withdraw from a decision when management requires recusal.

Image Magic has zero tolerance for bribery and corruption. No director, employee, agent, contractor or person acting for Image Magic may directly or indirectly offer, promise, give, request, receive or authorise anything of value to improperly influence a decision or obtain or retain business or an advantage.

• Bribes, kickbacks, secret commissions or personal rewards.
• Cash or benefits provided through an agent, supplier, consultant, relative or other intermediary.
• Facilitation or “speed” payments intended to secure a routine action.
• False invoices, inflated charges, sham services or hidden funds used to disguise an improper payment.
• Retaliation against a person who refuses to pay or accept a bribe.

Reasonable due diligence should be carried out on agents, suppliers and other associated persons according to the level of risk. Anti-bribery controls must be properly implemented, recorded, communicated and reviewed—not merely written on paper.

Gifts and hospitality must never create an obligation, influence a decision or appear to be a reward for favourable treatment. When uncertain, disclose the offer and obtain written approval before accepting or providing it.

If immediate refusal would cause genuine embarrassment or the item has already been delivered, the employee must declare it promptly. Management may require the item to be returned, shared, donated or treated as company property.

Image Magic will not knowingly assist in concealing criminal proceeds, disguising the true purpose of a transaction or transferring funds for an unlawful purpose. Employees should remain alert to unusual payment or refund instructions.

• Overpayments followed by a request to refund a different person or bank account.
• Requests for false descriptions, false invoices, artificial order values or unexplained third-party payments.
• Unusual splitting of payments, rapid cancellations or transactions with no clear commercial purpose.
• Attempts to avoid reasonable identity, order, payment or delivery verification.

Employees must not accuse or independently investigate a customer. Pause the affected transaction where authorised, keep accurate records and escalate the facts to management for review and, where appropriate, professional or official advice.

Image Magic competes independently and fairly. Employees must not enter into or support anti-competitive arrangements.

• Agreeing prices, discounts, surcharges, production limits or tender outcomes with competitors.
• Bid rigging, cover quotations, market sharing or customer allocation.
• Improperly exchanging non-public pricing, cost, customer, capacity or strategy information.
• Obtaining competitor information through theft, deception, unauthorised access or breach of confidentiality.

Suppliers and contractors must be selected using legitimate factors such as quality, price, capability, reliability, compliance, safety and service. Personal relationships must be disclosed, and purchasing decisions must be documented sufficiently to explain why the supplier was chosen.

All company records must be complete, accurate, timely and supported by genuine transactions. This includes quotations, orders, invoices, receipts, expense claims, payroll, attendance, inventory, purchasing, delivery, production, quality and maintenance records.

• Falsifying, backdating, concealing or destroying records improperly.
• Creating off-book accounts, false suppliers, fictitious sales or unsupported payments.
• Misusing company money, stock, materials, equipment, discounts or customer payments.
• Manipulating quantity, wastage, production, commission, overtime or delivery information for personal benefit.
• Deleting or altering relevant evidence after a complaint, audit, incident or investigation is anticipated.

Errors must be reported and corrected transparently rather than hidden. Records must be retained and disposed of according to law and approved company requirements.

Image Magic is committed to a workplace based on dignity, fair opportunity and professional respect. Discrimination, sexual harassment, harassment, bullying, intimidation, threats, workplace violence, humiliation and victimisation are not tolerated.

• Employment decisions should be based on legitimate job requirements, performance, conduct, capability and business needs.
• Communication must remain respectful across languages, cultures, seniority levels and work locations.
• Managers must not ignore complaints, retaliate, pressure a complainant to withdraw, or prejudge either party.
• Reasonable privacy must be respected, while information may be shared on a need-to-know basis to investigate and respond.
• An unsubstantiated good-faith complaint is not the same as a knowingly false or malicious report.

Image Magic respects internationally recognised human dignity and complies with applicable employment requirements. We do not knowingly use child labour, forced labour, debt bondage, human trafficking or coercive recruitment.

• Employment must be voluntary and workers must be legally eligible to work.
• No unlawful withholding of passports, identity documents, wages or freedom of movement.
• No recruitment practice that traps a worker through coercion, threats or unlawful debt.
• Working hours, wages, rest and leave must follow applicable requirements.
• Suppliers and labour providers are expected to meet compatible standards and address identified problems promptly.

Everyone shares responsibility for a safe printing, finishing, packing, office and delivery environment. Employees must follow training, risk controls, equipment instructions and lawful safety requirements.

• Use required personal protective equipment, guards, ventilation and safe material-handling methods.
• Follow authorised procedures for printing equipment, cutting machines, lasers, chemicals, inks, solvents, electrical systems, lifting and fire safety.
• Report hazards, spills, unsafe conditions, injuries and near misses promptly.
• Stop work and seek help where there is an immediate serious danger, in accordance with company procedures and applicable law.
• Do not work while impaired by illegal drugs, alcohol or misuse of medication. Seek confidential guidance if prescribed medication may affect safety-critical duties.
• Reduce avoidable waste, prevent pollution, manage chemicals responsibly and dispose of materials through approved methods.

Customer artwork, logos, photographs, variable data and designs must be handled with care and used only for authorised business purposes. Image Magic respects copyright, trademarks, privacy, confidentiality and other rights.

• Do not copy, publish, sell, share or use customer artwork for personal work, training, social media or a portfolio without permission.
• Use licensed fonts, images, software and design resources according to their terms.
• Do not knowingly produce counterfeit labels, forged certificates, fraudulent identity documents, deceptive packaging or other unlawful material.
• Escalate jobs that appear to infringe rights, impersonate another party, facilitate fraud, contain unlawful exploitation, or create a serious legal or safety risk.
• Do not alter a customer's approved content or specifications without authority.

Employees are not expected to make legal conclusions on their own. Where a job is questionable, pause it and obtain management guidance before production.

Confidential information includes customer artwork, mailing lists, variable data, quotations, pricing, supplier terms, production methods, employee information, financial records, passwords, security information and business plans.

• Access only the information needed for authorised duties.
• Use approved storage, transfer and communication channels.
• Verify recipients before sending artwork, personal data or confidential documents.
• Do not discuss confidential matters where unauthorised persons may overhear.
• Securely dispose of printouts, labels, proofs, storage media and waste containing sensitive information.
• Report suspected loss, misdirection, unauthorised access or disclosure immediately.
• Confidentiality obligations continue after employment or a business relationship ends.

Personal data must be handled according to the Privacy & Personal Data Protection Policy, applicable law and customer instructions where Image Magic processes data on a customer's behalf.

Company money, stock, machines, vehicles, tools, computers, software, accounts, networks, data, time and intellectual property must be protected and used for authorised purposes.

• Personal credentials must not be shared. Approved shared workstation or team accounts may be used only under formally authorised access arrangements.
• Use multi-factor authentication, screen locking and secure passwords where available.
• Do not install unauthorised software, connect unapproved devices or store company data in unapproved personal cloud services.
• Remain alert to phishing, fraudulent payment requests, malicious links and impersonation.
• Report lost devices, suspected malware, compromised accounts and accidental disclosures immediately.
• Limited personal use may be allowed only when reasonable, lawful, approved where required and not disruptive.

Image Magic may access, preserve or monitor business systems for legitimate operational, security, compliance and investigation purposes, only through authorised personnel and subject to applicable law and company policy.

Artificial intelligence and automated tools may improve productivity, but they must be used responsibly and with human oversight.

• Use only tools approved for the type of work and information involved.
• Do not upload customer artwork, personal data, confidential pricing, passwords or restricted business information into an unapproved AI service.
• Review AI-assisted text, design, translation, calculations and recommendations for accuracy, bias, confidentiality, intellectual-property risk and suitability before use.
• Do not use AI to impersonate a person, create deceptive evidence, fabricate customer approval or produce unlawful content.
• Disclose AI assistance where required by law, contract, customer instruction or company policy.
• The employee using the tool remains responsible for the final work and decision.

Only authorised persons may speak on behalf of Image Magic, provide official comments, publish company announcements or respond to media, legal or regulatory enquiries.

• Do not disclose confidential, customer, employee or non-public company information.
• Do not present a personal opinion as the official position of Image Magic.
• Do not post discriminatory, threatening or harassing content using company accounts or while representing the company.
• Do not create fake testimonials, undisclosed endorsements or misleading promotional content.
• Refer complaints and sensitive public enquiries to the authorised team instead of arguing online.

Employees retain the right to lawful personal expression, but must not misuse company identity, resources or confidential information.

Image Magic seeks to work with business partners that support lawful, ethical and responsible business practices. Due diligence and contractual controls should be proportionate to the nature and risk of the relationship.

• Communicate expectations concerning anti-bribery, fair labour, safety, privacy, information security, intellectual property and environmental responsibility.
• Do not use a third party to perform an act that Image Magic is prohibited from doing directly.
• Record the scope of work, pricing, approvals and payment arrangements accurately.
• Monitor serious concerns and require appropriate corrective action.
• Suspension or termination may be considered according to the severity, evidence, legal requirements and willingness to remediate.

Employees are encouraged to ask questions and report genuine concerns as early as possible. Concerns may be raised with a supervisor, Finance & Human Resources or the Managing Director through the confidential channels communicated internally. A person who is uncomfortable using one channel may use another.

Customers, suppliers and other external stakeholders may email [email protected] with the subject “Confidential: Ethics Concern” and request escalation to management.

• Reports may concern bribery, fraud, harassment, safety, data misuse, unlawful printing, conflicts of interest, retaliation or another serious breach.
• Anonymous information may be considered where practicable, although anonymity can limit follow-up.
• Information will be handled as confidentially as reasonably practicable and shared only when needed to assess, investigate or respond.
• Image Magic prohibits retaliation against a person who raises a concern, participates in an investigation, refuses a bribe or reports an unsafe condition in good faith.
• A knowingly false or malicious allegation may result in disciplinary action. A good-faith report is not treated as false merely because it is not substantiated.

Reported concerns will be assessed according to their nature, urgency and available evidence. Investigations should be fair, appropriately independent and limited to persons who need to know.

• Preserve relevant documents, messages, footage, files and physical evidence.
• Cooperate honestly and do not obstruct, influence witnesses or retaliate.
• Respect the privacy and dignity of complainants, respondents and witnesses.
• Give affected persons a reasonable opportunity to respond, subject to safety, legal and evidence-preservation needs.
• Correct control weaknesses and recover company property or losses where appropriate.

Confirmed breaches may result in proportionate corrective or disciplinary action, subject to applicable law and due process. Action may include counselling, retraining, removal of access, warning, reassignment, suspension, dismissal, termination of a business relationship, recovery action or referral to an authority.

This Code is a public statement of Image Magic's ethical principles. It complements—but does not replace—employment contracts, internal procedures, safety rules, customer agreements, statutory rights or applicable law.

• Employees may be required to acknowledge the Code and complete periodic training.
• Managers should discuss relevant risks with their teams and reinforce expected conduct.
• The Code may be updated when laws, technology, operations or company risks change.
• Material changes should be communicated to affected personnel.
• Questions should be raised before an uncertain action is taken.