The Group recognises the expectation from the employees, stakeholders and communities in which we operate to act in an ethical and honest manner. We are committed to uphold integrity, promote accountability and transparency as a way of doing business and transaction. The Group adopts procedures which are guided by the HLMG policies. The Group is certified with ISO 37001 Anti-Bribery Management System, which defines the expectation in the way the stakeholders act, so as to ensure that the decisions made are lawful, ethical and honest in line with our policy.

An overview of the Group’s key policies, codes, procedures and activities are listed as below:

Anti-bribery and Corruption Management System (“ABCMS”) Risk Assessment

In addition to the requirement of ISO 37001, the Group adopts the practice of HLMG to identify and review ABCMS risk on quarterly basis. From the list of identified risks, especially the significant risks, the respective risk owner will establish mitigation plan to address the risk accordingly.

Anti-Bribery and Corruption (“ABC”) Policy

The Group is committed to conducting business ethically in compliance with applicable anti-bribery and corruption laws of every country in which we operate. We do not condone any form of bribery and corruption.

The Board Audit and Risk Management Committee (“BARMC”) is the governing body for the Group, approving the policy and has oversight over the implementation of the policy. The Group’s ABCMS Compliance Function Officer is responsible for the overall implementation of ABCMS and ensuring that the objectives of ABCMS are met.

The stakeholders can report any bribery and corruption related concern or suspicion to the Head of Internal Audit or Head of Human Resources as stated in the policy.

Whistle Blowing Policy

The Group promotes and supports the culture where people feel comfortable to raise genuine and legitimate concerns about inappropriate conduct and behaviour. We encourage our employees to speak up if they become aware of any improper or wrongful act involving the Group.

The Group is committed to protecting people who make genuine and legitimate disclosures from adverse employment action to the extent permitted by law.

For FY 2022, there was no whistleblowing disclosure reported through any of the various whistleblowing channels and no investigation case was conducted.

Conflict of Interest

To avoid any potential conflict of interest during tendering process, the tender committee members are required to make self-declaration on whether there is potential conflict of interest with the tenderers. During the recruitment interview, the interviewee is also required to declare if he/she has any family members or relatives who are currently working in the Group.\

Refer to FY 2022 Annual Report page 14 for Statement of Declaration by the Board members.

Donation policy

The Group adopts the Donation policy of HLMG. The scope of the policy includes corporate donations made to charities, non-profit organisations, and/or causes of greater good by an operating company.

Refer to FY 2022 Annual Report page 54 for Community Engagement details on donation.

Gift and Entertainment Policy

The Group adopts a “No Gift Policy” whereby all employees are prohibited, save as expressly permitted by the Policy, from giving and/or receiving gifts and entertainment.

Effective from 1st January 2021, the Group’s policy requires all employees to make half-yearly declaration on giving and/or receipt of gifts and entertainments.\

The Group has achieved a declaration rate of 100% for 1st half of FY 2022 with exclusion of those under long hospitalisation leave during the period of declaration.

ISO 37001 Anti-Bribery Management System Surveillance audit

The Group has completed the 1st surveillance audit by SIRIM QAS and the certification is continued. 

Training

The Group continues to enhance the understanding of ABCMS and policies. We have set up E-Training and Evaluation Portal for employees to go through refresher training once in every three years.

In FY 2021, we had conducted an employee survey on understanding of ABCMS that was implemented. We had achieved a rating of 4.4 out of the total of 5. Our Compliance Officer had further analysed the outcome of the survey and launched a two years program until the end of FY 2023 to brief and refresh the Gift and Entertainment Policy and Whistle Blowing Policy to employees.

Annual ABCMS Awareness Program

As part of the continuing effort to create awareness, the Group has set up ABCMS corners at each operating company. 

Promoting ABCMS to Business Associates

The Group promotes ABCMS to business associates by communicating through email and providing them with our ABC Policy. In addition, suppliers are also provided with the Suppliers’ Code of Conduct and Ethics. We have been actively following up with the business associates for their acknowledgement. For FY 2022, the cumulative business associates’ responses were as below:

• Southern Steel Berhad 90%
• Southern Steel Mesh Sdn Bhd 97%
• Southern PC Steel Sdn Bhd 96%
• Southern Pipe Industry (M) Sdn Bhd and Southern Steel Pipe Sdn Bhd 82%