Company's Code of Conduct

  1. Policy

    It is the policy of ELK-Desa Resources Berhad (“ELK-Desa” or “the Company”) that the employees and Board members of ELK-Desa and its subsidiaries (“ELK-Desa”) should observe the highest standards of ethics and integrity in their conduct and do the right thing – follow the law, act honorably, and treat co-workers with courtesy and respect.

    We expect all of our employees and Board members to know and follow the following Code of Conduct which we believe will help ELK-Desa in reaching its goal through honourable conduct. Failure to do so can result in disciplinary action, including termination of employment. Any waivers of this Code for directors or executive officers must be approved by our Board.

    If you have a question or concern about this Code or believe that someone may be violating it, or if you want to remain anonymous, you can make a report of a suspected violation or concern through the Company’s Whistleblowing channel.

  2. Setting the Tone at the Top

    Management has the added responsibility for establishing, via their actions, the importance of this Code. It is believed that ethical behaviour is the product of clear and direct communication of behavioural expectations, which must be demonstrated from the top and proven by example. In another word, it is our actions that matters.

    To make our Code work, Management must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate actions to deal with such issues. Management should not view employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of internal communication to prevent mistakes or wrongdoings.

  3. Trust and Credibility

    Our business is dependent on the trust and confidence we earn from our employees, customers and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honourable conduct.

  4. Cultural and Workplace Harmony

    ELK-Desa has taken affirmative action and is committed to create a harmonious environment of workplace free of discrimination of all types of abusive, offensive or harassing behaviour. Every employee will be treated with dignity and respect and there is equal employment opportunity disregard of race, religion, culture and gender. Any employee who feels harassed or discriminated against should report the incident to the Management or to the Human Resources Department.

  5. Avoid Conflicts of Interest

    All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

    Determining whether a conflict of interest exists is not always easy to do. Employees or Board members with a conflict of interest question should seek advice from Management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees and Board members must seek review from Management or Company Secretary.

    When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of ELK-Desa. If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.

  6. Ensure Financial Integrity and Responsibility

    Ensure that money is appropriately spent, our financial records are complete and accurate, and our internal controls are honoured.

    If your job involves the financial recording of our transactions, make sure that you’re familiar with all relevant policies, including those relating to revenue recognition.

    Never interfere with the auditing of financial records. Similarly, never falsify any company record or account. Always lend your assistance to the internal audit function and always provide true information.

    If you suspect or observe any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to the Whistleblowing Channel.

  7. Obey the Law

    We are committed to comply with laws, rules and regulations where we do business. Further, employees and Board members must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. A few specific laws are easy to violate unintentionally and so are worth pointing out here. If we are unsure of whether a contemplated action is permitted by law or Company policy, we should seek the advice from the Company Secretary. We are responsible for preventing violations of law and for speaking up if we see possible violations.

    Trade Controls

    As our business is regulated by various Malaysian laws, rules and regulations such as the Hire Purchase Act and the Personal Data Protection Act, you should work with the management to ensure that the transaction stays within the bounds of the applicable laws.

    Insider Trading

    Do not use non-public information to buy or sell shares in the Company to gain personal advantage, or to pass it along to others so that they may do so. That could constitute the crime of insider trading.

    Familiarize yourself with the Laws and the risks of insider trading, such as:

    • prohibition on market manipulation of ELK-Desa shares
    • periodic blackout windows when you may not trade ELK-Desa shares

  8. Corruption

    We pledge not to bribe anybody nor accept bribe from anyone, at any time, for any reason.

    Business Courtesies

    Most business courtesies offered to us in the course of our employment are because of our positions at ELK-Desa. Although we may not use our position to obtain business courtesies, we must never ask for them. We may accept occasional meals, refreshments, entertainment, gifts and similar unsolicited business courtesies that are customary and conform to reasonable ethical or cultural practices of the marketplace provided these courtesies are not inappropriately lavish or excessive, not frequent from the same person or entity, not create the appearance of an attempt to influence business decisions.

  9. Our Pledge

    We rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all Board members and employees to be guided by the Code of Conduct and Ethic and the Employees Handbook (published on 17 November 2017) respectively, as well as the spirit of this Code.

Adopted 24 May, 2018;

You may report your concern through the Company’s Whistleblowing Channels as follows:

■   Online Reporting
■   Phone Hotline 1-700-81-5333
■   Email Reporting
■   Written Letter P. O. Box 10891
50728 Kuala Lumpur