Code of Ethics and Business Conduct

  1. Code Values

    Fourtitude.Asia has, and continually strives to infuse our work and corporate culture with our core values. We strive to meet the commercial objectives of our clients, partners and stakeholders while ensuring the well-being and general concern of our employees. Our value is drafted by employees, embraced by directors, and promulgated by senior management.

    We value integrity, customer focus, creativity, commitment and loyalty, efficiency and we respect highly motivated team members and a positive team spirit.

    “Practicality Makes Perfect Sense.” Practical solutions are clear and effective, end-to-end strategies that are able to resolve complex organizational challenges within organizational and environmental restrictions. It takes foresight, attention, perception, perseverance, patience and experience, thus a practical solution that meets all objectives often makes perfect sense. We are proactive in practicality in Fourtitude.Asia and simultaneously bring practicality to our clients’ success.

  2. Scope and Application

    This Code of Ethics and Business Conduct (“Code”) applies equally to all employees of Fourtitude.Asia and extend to all third parties including contractors, partners, service provider, consultants, personnel and/or their respective employees and/or agents (collectively “Parties”/ “Party”). In this Code, “Company/ We/ Fourtitude.Asia” shall mean Fourtitude Asia Sdn. Bhd. and its group of companies consisting of all its subsidiaries.

    Our business is dependants on trust and confidence earned from all Parties. This Code describes the basic expectation for all Parties, provides framework for ethical decision and business conduct, and identifies the channel for Parties’ concerns to be raised and heard by us. All Parties who work with Fourtitude.Asia are responsible to act in accordance with the standards as set out in this Code and the related policies and any update or amendment made by Fourtitude. Asia from time to time. All external Parties who works with Fourtitude.Asia are required to maintain and implement their code of conduct within their organization at a standard at least same as this Code and any update or amendment from time to time.

  3. Communication

      Parties are expected to use good judgement in the business conduct with the guidance of this Code and are obligated to ask any question, report any known or suspected misconduct regarding the interpretation or application of this Code, our directive, law or regulations to Fourtitude.Asia in order to ensure compliance. Communication may be made to the compliance team through the following channel (“Communication Channel”):

    • Compliance Team Email address: compliance@fourtitude.asia

    • Tel: 03-78806580

    We need all Parties to fully cooperate in our internal or external investigation and audit regarding the conduct or implementation in relation to this Code. Full cooperation shall include prompt, complete and truthful response, participating in any interview in timely manner upon requested, and provision of information as requested by us.

Section I: Workplace and Environment

  1. Non-Discrimination, harassment, threat and retaliation

    We practise respect and tolerance and we strictly reject retaliatory action. All workplaces shall be free from discrimination and all types of abusive, offensive and harassing behaviour. If a Party believes that he/she or other have been retaliated against or received threat of retaliation, report should be lodge to Fourtitude.Asia through our Communication Channel. We will investigate and take appropriate action following the investigation outcome which include applicable disciplinary action and if applicable, the legal action.

  2. Safe and Healthy Workplace

    All applicable workplace safety and health requirements and maintenance of occupational safety and health standards at workplace shall be at the standard which is equal or exceed the best practices in the industry

  3. Environmental care

    Environmental management and monitoring shall be maintained all the time. Aspects that fall within the environmental management and monitoring includes the effort in reducing environmental impacts from the business operation process such as energy and water efficiency.

  4. Sexual Harassment

    Sexual harassment may take many forms – it includes any unwanted conduct of a sexual nature, in any form, whether verbal, non-verbal, visual, gestural or physical, directed at a person which is reasonably offensive or humiliating or is a threat to a person’s well-being. A complaint about sexual harassment shall be made through the Communication Channel and it would be followed by investigation and disciplinary action.

Section II: Company Assets and Information

  1. Confidential Information

    Company’s trade secret or such other information which is confidential in nature including but not restricted to trade secrets, company proprietary information, software programmes and codes, working plans, forecast, budgets, staff performance appraisal, company contacts, network diagrams, billing status, HR information, etc (“Confidential Information”) shall be treated with strict confidence. Personnel who have access to and/or possesses any Confidential Information are responsible to keep the Confidential Information confidential at all time. Parties would be required to provide a non-disclosure undertaking prior to dealing with the Company’s Confidential information.

  2. Disclosure of Information

    Company’s employee shall not without authority disclose to any third party any Confidential Information about the interests or business of Fourtitude.Asia nor make nor possess without authority copies of documents or other media on which such information is recorded, and on termination of his / her employment, he / she shall deliver to the Company (without keeping any copies) any such documents or other media. No Party is allowed to take part in any press interview or write any papers which may involve disclosure of Confidential Information without first obtaining the consent to do so from the Company.

  3. Data Integrity and Data Protection

    If service or business transaction involve handling ( including collection, manage, store, processing and transfer of data) of Personal Data as defined under the applicable data protection law, such Personal Data shall be handled in a manner which is in compliance with the applicable law, regulation and policies including but not limited to the Personal Data Protection Act 2010 and the Company’s Information Security Management Policy and Personal Data Protection Policy.

  4. Company's Email, Internet Access and Social Media Account

    Business tools such as company electronic mail, internet access, and social media account shall not be abused at any time for purposes unrelated to the Company’s business activities. Employee’s usage of the said business tools would be monitored from time to time and at any time. The management shall have full access to employee email and instant messaging correspondences in an event connected to suspected disciplinary issue or in cases connected to a criminal investigation/or when a police warrant or public prosecutors written request, in the presence of 2 witnesses from the Management.

  5. Company's Assets and Resources

    Assets and resources prepared, owned and provided by Fourtitude.Asia to any relevant Parties shall be assets and resources of the Company. Parties who have access, use or storing the assets and resources shall safeguard and make proper use of the assets and resources for the purpose as assigned and shall take responsibility to prevent loss, damage, misuse, theft, fraud or destruction of the assets or resources.

Section III: Integrity

  1. Loyalty and business ethics

    Employees of the Company shall make every effort to further the Company’s interest and shall not use his / her position or any knowledge gained from it for personal interests.

  2. Extra moral employment

    All employees of the Company shall not be involved in any way with any business that materially interferes with the performance of his duties or obligations to the Company.

    The Company, however, does not prohibit any employee from participating in civil, religious, cultural, charitable, community or similar activities. The time devoted to these activities, however, must not interfere or be in conflict with the Company’s requirements.

  3. Conflict of Interest

    Conflict of Interest occurs when a Party’s interest could compromise his or her judgement, decisions or action causing bias and gaining of personal interest or consideration. Any relationship which may possibly create conflict of interest must be declared to the Company. All Parties shall adopt the highest standard of conduct at all time. If any Party at any time believes that he or she may have a potential or is having actual conflict of interest, such Party is required to disclose the conflict promptly to the Company so that a determination can be made as to the existence of an actual conflict and its consequences and impacts.

  4. Anti-bribery and Anti-corruption

    The Company adopts a zero-tolerance policy against all forms of bribery and corruption. Offering, soliciting, giving or accepting bribe or kickback in any form in exchange of any personal or business benefit is strictly prohibited. Employee who is violating the anti-bribery and anti-corruption policy shall be liable for disciplinary action and legal consequences. The company reserve the right to terminate any business relationship with a Party who violates the anti-bribery and anti-corruption policy. Any Party who comes to aware about any suspicious or actual corruption activity within the business transaction is responsible to report the same to the Company via the Communication Channel. A copy of the Anti-Bribery and Anti-Corruption Policy is accessible via the Company’s website at www.fourtitude.asia.

    1. Purchasing and Procurement Process

      Any potential or actual conflict of interest during purchasing or procurement process must be declared to the Company. Any suspected improper behavior or conflict of interest that affects a purchasing or procurement process must be reported to the Company through the Communication Channel.

    2. Gifts, Entertainment and Hospitality

      Gift, entertainment and hospitality could be considered as a bribe if it is given or received with the intention of influencing someone to act improperly, as a reward for having acted improperly or for a favourable business or benefit. Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business. Gifts, entertainment and hospitality are prohibited unless it falls within a permitted exception based on reasonable boundary. As a guideline to determine whether a gift, entertainment or hospitality is permissible, the following questions can be taken into consideration before you decide on whether to accept or reject a gift, entertainment or hospitality:

      • What is the intent – is it to build a relationship or is it something else? It should be rejected or should not be given if the answer is ‘yes’.
      • How would it look if these details were on a newspaper? It should be rejected or should not be given if it could be interpreted as a bribe for improper exchange of certain benefit.
      • What if the situation were reversed – would there be a double standard? It should be rejected or should not be given if answer is ‘yes’.
      • Transparency – is it comfortable for you to disclose to your colleagues about the gift, entertainment or hospitality in question? It should be rejected or should not be given if the answer is ‘no’.
      • Does it put you in a position of conflict? It should be rejected or should not be given if the answer is ‘ yes’.
      • Does your acceptance or giving of a gift, entertainment or hospitality affect any pending business decision or enable any unmerited advantage? It should be rejected or should not be given if the answer is ‘yes’.
      • Does the gift, entertainment or hospitality are given so frequently until it put you or the recipient under an obligation? It should be rejected or should not be given if the answer is ‘yes’.
      • Is giving or acceptance of the gift is purely out of friendly gesture during cultural or festive occasion? If yes, it can be accepted provided if the value is not more than RM 200.

      When one is unsure about whether a gift, entertainment or hospitality could be accepted or be given, one should seek decision from the Compliance Team via the Communication Channel.

      For the avoidance of doubt, any gift, entertainment or hospitality which is more than RM200 shall be declared to the compliance team with submission of a duly signed via the Communication Channel.

      Any gifts, entertainment or hospitality that has been received is required to be returned or refunded to the party who has given the said gift, entertainment or hospitality if it is found to have violated the anti-bribery and anti-corruption policy and/or the governing law.

    3. Dealing with Public Officials

      Public Officials” include:

      • elected or appointed public official such as a member of a ministry of the government;
      • political officer, candidate for public office, officer, or employee or individual acting for or on behalf of a political party or candidate for public office;
      • an individual acting for and on behalf of a Public Official, agency or such other form of body which is performing a governmental role, or is owned by or controlled by government;
      • a person acting for or on behalf of a public international organization;
      • a member of royal family or military;
      • any other individual who is a Public Official according to the definition given by the law.

      Parties who are dealing with Public Official must declare the same to the Company. Parties dealing with Public Officials and contract on behalf of the Company must make sure compliance with all applicable laws and regulations.

    4. Facilitation Payment and Kickbacks

      Direct or indirect giving or accepting a Facilitation Payment and Kickbacks of any kind are strictly prohibited. Activity which have the tendency of leading to a Facilitation Payment or Kickbacks must be strictly avoided. Any invitation for Facilitation Payment or Kickbacks must always be refused and Party who come across with such invitation must notify the Compliance Team via Communication Channel immediately.

    5. Donation and Contribution

      Donation and contribution which is made on the ground of supporting corporate social responsibility in good faith is acceptable. There shall be no political contribution from company’s fund without prior authorisation. In general, donation or contribution which is made with intention to exchange for certain outcome in the business transaction is strictly prohibited. To cite some examples for reference, donation or contribution of the following nature are strictly not allowed:

      • with intention to exchange directly or indirectly any desirable benefit or outcome;
      • is or could reasonably be perceived as for the purpose of influencing a business decision and/or obtaining a benefit in a business transaction;
      • which is against the law; or
      • which is excessive.
  5. Money Laundering

    Money laundering refers to the concealment of the origins of illegally obtained money. At Fourtitude.Asia, we keep high alert on risk of our business transaction and operation being used for money laundering purpose. Any actual money laundering activity that involve in the Company’s business operation or suspicious transaction that may potentially a money laundering activity shall be reported immediately to the Company through the Communication Channel.

  6. Whistleblowing

    Parties who have knowledge of or a concern of illegal or dishonest/fraudulent activity in violation of the principle set out under this Code shall report immediately to the Company through the Communication Channel. Whistle blower will be protected as per the protection available under the Company’s Whistleblower Policy including non-retaliation and confidentiality of identity.

  7. Due Diligence

    Fourtitude.Asia requires external Parties including supplier, sub-contractor, agents and intermediaries to comply with due diligence review process unless it is reasonably exempted. Failure to provide full cooperation in the due diligence process may result in termination of business relationship.

  8. Fraud

    All Parties are expected to put high alert in recognizing any fraud, falsification of records or other irregularities that occur in the business process with the Company. Examples of fraud are forgery of document, misappropriation of fund, misleading or false report etc. Parties who come to know or suspect any such irregularity is obligated to disclose the same through immediate reporting to the Company via the Communication Channel, and subsequently to provide cooperation in the investigation in good faith.