Introduction

Image Magic Printing Sdn Bhd (referred to as “Imagic”) is committed to meeting or exceeding all laws and regulations wherever we operate. All employees are expected to understand legal and policy requirements applicable to their roles and to conduct business with honesty and integrity.

This Code of Ethics & Conduct sets out acceptable practices that guide employees of the Imagic Group of Companies (“Imagic Group / Company / Imagic”). Imagic reserves the right to amend this Code when necessary in the best interest of the Company. Employees will be notified of changes.

Scope

This Code applies to all employees (including temporary employees) and covers business activities with suppliers, contractors, clients, customers, shareholders, and employees in Malaysia and overseas. It must be read together with relevant company policies.

Compliance with Laws & Regulations

Imagic and its directors, officers, and employees must be aware of and comply with duties and obligations under applicable laws, legislation, and regulations relevant to their roles and responsibilities.

Enforcement

Any employee who violates this Code, condones a violation, fails to report a possible violation, makes a false report, or fails to cooperate in an investigation may face disciplinary action up to and including dismissal. Disciplinary action may also apply for inadequate diligence or supervision.

Business Communication

Employees must exercise due care, diligence, and etiquette in all work-related communication (written, verbal, or otherwise) to ensure it is clear, truthful, courteous, and accurate.

Imagic maintains a zero-tolerance policy for discriminatory, defamatory, offensive, sexually suggestive, pornographic, misleading, or similar communications made during business or using Imagic resources.

Fair Dealing

Imagic aims to maintain the highest ethical standards in dealings with customers, clients, shareholders, government, employees, suppliers, and the community. Employees must deal fairly and comply with applicable antitrust, competition, and fair dealing laws.

Conflict of Interest

Conflicts of interest arise when personal interests may interfere with objective judgment on behalf of Imagic. Employees must avoid conflicts (or the appearance of conflict) and must not use their position, work hours, resources, or assets for personal gain.

Imagic sets procedures for conflicts involving suppliers/contractors/customers, personal dealings, outside employment, board memberships, family relationships, and investment activities.

Commercial Bribery (Zero Tolerance)

Commercial bribery is illegal and prohibited. Employees must not give, offer, promise, accept, request, or authorize bribes directly or indirectly. Bribes include cash, gifts, entertainment, hospitality, travel perks, special favours, or privileges.

Anti-Money Laundering

Money laundering involves transactions connected to proceeds of unlawful activities. Employees must not assist, abet, or participate in money laundering, and must exercise high due diligence in business relationships. Breaches may result in disciplinary action including dismissal.

Gifts, Entertainment & Gratuities

Receiving gifts or entertainment from parties we do business with is generally not acceptable due to potential conflict of interest. If refusal is impossible and business impact is likely, gifts may be accepted in rare cases and must be discussed with a line manager. Alternatives include donating the gift to charity or making it company property.

Fraud & Dishonesty

Fraud is intentional deception for personal gain. Fraud, theft, embezzlement, and misappropriation are strictly prohibited. If evidence of fraud or crime is established, employment may be terminated and authorities/legal action may be considered.

Examples include: falsifying records, misappropriating assets, embezzlement, bribery, kickbacks.

Employees must report suspected fraud to a line manager or the Audit Committee. False reports may lead to disciplinary action and termination.

Workplace Behaviour, Diversity & Respect

Imagic is committed to human rights, diversity, equal opportunity, and a workplace free from discrimination, harassment, intimidation, bullying, and victimisation. Line managers are responsible for employee wellbeing.

If an employee experiences unwanted conduct: (i) submit a complaint via e-form, (ii) Audit Committee investigates discreetly, (iii) investigation may lead to domestic inquiry and disciplinary action including dismissal.

Responsibility for Company Property

Employees must care for company equipment, tools, and property and must not misuse, abuse, steal, or use items without authorization. Company equipment and stationery must not be used for personal purposes without approval.

Computer Systems: Security & Control

Company systems, networks, devices, software, and data are company property. Primary use is for business; occasional personal use may be allowed if reasonable and does not interfere with work. The Company retains rights to access systems, backups, and emails.

Employees must not access or store improper or illegal content, must remain alert to phishing/scams, and must not install hardware/software without written approval. Violations may lead to disciplinary action including dismissal.

Password Security

Passwords protect access and accountability. Unauthorized disclosure of passwords or attempts to obtain others’ passwords may result in disciplinary action including dismissal.

Private & Confidential Data

Employees must protect private and confidential data from improper disclosure or misappropriation. Sensitive documents should not be left exposed. Store devices containing sensitive information securely when not in use. For guidance, contact Human Resources.

Personal Information & Privacy

Personal information must be collected and used only to the minimum necessary for business needs (HR/legal purposes) in accordance with the Company’s Privacy Policy. Sharing confidential employee personal information with unauthorized parties is strictly prohibited.

Use of Social Media

Employees must use good judgment on personal social media. Do not disclose non-public/confidential company information or spread rumours/speculation. Maintain respectful and professional conduct when accounts identify you as an employee.

Whistleblowing

Imagic encourages employees to raise genuine concerns confidentially and without reprisal, including unlawful, unethical, or questionable behaviour. Reports may be made to a line manager, Human Resources, or the Audit Committee. Reports may be accepted anonymously where practicable.

Child Labour & Worker Policy

Imagic does not permit child or forced labour. We comply with legal minimum working age and do not tolerate unacceptable treatment. We expect suppliers/partners/contractors to uphold the same standards, and may discontinue relationships if violations persist.

Health, Safety & Environment

Imagic is committed to a healthy and safe workplace. Employees must follow safety procedures and lawful instructions. Controlled substances, illegal drugs, improper medication use, and alcohol misuse at work will not be tolerated.

Fair Competition

Imagic supports vigorous yet fair competition. Employees must not coordinate prices with competitors, must deal fairly with customers/suppliers, and must obtain competitive information lawfully. Report inappropriate discussions to a line manager immediately.

Continuous Improvement

The Company values continuous improvement, innovation, and teamwork. Line managers should conduct regular consultation, counselling, and coaching, and support employee development.

Disclaimer

This Code is a statement of fundamental principles, policies, and procedures. It is not intended to create rights for any employee, client, customer, supplier, competitor, security holder, or any other person or entity.