SECTION 1.0 PNMB GROUP’S COMMITMENT
PNMB Group and its subsidiaries (“PNMB Group”) desires to maintain a reputation for integrity that is in keeping with its responsibilities and position. In line with this commitment, it requires all Directors and employees (collectively referred to as “Personnel”) to observe the highest ethical business standard of honesty, integrity and to apply these values to all aspects of its business and professional practices.
SECTION 2.0 OBJECTIVE
The Business Code of Conduct (“Business Code”) shall serve as a guidance on the standards of behavior expected by all personnel and where applicable Business Partners. The standards of behavior are derived from PNMB Group’s Business Principles.
SECTION 3.0 SCOPE
The Business Code applies to all personnel. This includes employees on secondment to join ventures, affiliates or associates. We expect and encourage all Business Partners to operate in accordance with the principles in this Business Code. Business Partners are encouraged to adopt similar principles and standards of behavior.
This Business Code contains general requirements applicable to all Business Partners of PNMB Group. Particular Business Partners may contain more specific provisions addressing some of these same issues. Nothing in this Business Code is meant to supersede any more specific provision in a particular contract and to the extent, there is any inconsistency between this Business Code and any other provision of a particular contract, the other provision will control.
SECTION 4.0 BUSINESS PRINCIPLES
Through the acceptance of any Business Dealing(s) with any company under PNMB Group, Business Partners are expected to uphold the eight (8) principles contained in this Business Code in every aspect of their business.
4.1 Code of Ethics
PNMB Group is dedicated to administer its business relationships to be handled with the highest professional and ethical standards. We expect all Business Partners to comply with all laws and regulations on anti-bribery, corruption and prohibited practices. All Business Dealings should be transparently performed and must be conducted with honesty, integrity and fairness.
4.2 Conflict of Interest
A conflict of interest may arise when a Business Partner has a competing professional or personal interest during carrying out Business Dealings. All Business Partners must avoid any Conflict of Interest in their work with PNMB Group. Business Partners should likewise ensure that all sub-contractors avoid such situations.
Any Business Partner which suspects an actual, potential or perceived Conflict of Interest must disclose the situation immediately in writing via email to [email protected].
4.3 Confidentiality
Business Partners are expected to conduct all procurement and business relationships with integrity, respect and trust.
Business Partners are expected to always protect the confidentiality of the information and have no right to use any intellectual property or other proprietary information belonging to PNMB Group without prior written authorisation.
4.4 Competitive Practice
All Business Partners must respect their contractual commitments to PNMB Group. Business Partners must not collude with other tenderers, distributors, suppliers or contractors, or engage in any other form of anti-competitive behaviour.
4.5 No Gift Policy
PNMB Group is committed to conduct our business with the highest standard of integrity and good governance. Our No Gift Policy aims to avoid a conflict of interest and demonstrate PNMB Group’s commitment to provide equal treatment to all individuals or organisations that we are in contact with for our business. In this regard, personnel of PNMB Group shall not solicit or receive any gifts from current or potential Business Partners either directly or indirectly which may influence the employee’s judgement in a decision-making process or put the personnel in a position of conflict.
All Business Partners should avoid either directly or indirectly, promise, offer or give any bribe or an improper advantage (whether financial or otherwise) to any person in PNMB Group, or any other person representing any company or associate company under PNMB Group as an inducement, incentive, reward, gift or bonus during Business Dealing(s).
4.6 Disclosure of Information
All Business Partners are expected to disclose information regarding its business activities, structure, financial situation and performance in accordance with the applicable regulations and prevailing industry practices. Falsification of records or misrepresentations of conditions or practices in the supply chain is unacceptable.
4.7 Record Keeping
The Business Partners are encouraged to maintain adequate internal controls and procedures to ensure that all transactions with PNMB Group are accurately recorded and reported in its books and records to reflect truly the activities to which they pertain such as the purpose of each transaction and to whom it was made or from whom it was received.
PNMB Group expects its Business Partners to:
i) Maintain the integrity of the information provided to PNMB Group at all times.
ii) Respond promptly to inquiries from authorised representative of PNMB Group regarding the implementation and compliance to the Business Code of Conduct.
iii) Fully cooperate, provide the access and allow to visit and audit the relevant document, staff and facilities, upon request from PNMB Group.
iv) Report/update any change in circumstances and Business Partners’ details which may have an impact on PNMB Group or the Business Dealing(s).
4.8 Whistleblowing
Business Partner who believes that personnel, or anyone act on behalf of PNMB Group, has engaged in illegal or otherwise improper conduct, should report the matter to the company. The Business Partner can contact the Head of Risk Management, Compliance, Integrity & Audit Department at 03-9236 6888 or email to [email protected]. Business Partner’s relationship with PNMB Group will not be affected by an honest report of potential misconduct.
SECTION 5.0 IMPLEMENTATION OF INTEGRITY PACT
Integrity Pact promotes clean operations for both PNMB Group and the Business Partner during the execution of a contract. The implementation of Integrity Pacts also yields other benefits such as greater transparency in contracting and enhancement of public confidence and trust.
Integrity Pact must be signed by all PNMB Group’s Business Partners during the vendor registration and tender submission process.