Code of Conduct


This Code of Conduct applies to all employees of MBM Resources Bhd and its subsidiaries (referred to collectively as “MBMR” or “Company”), as well as non-executive members of the boards of directors of MBMR. The Code helps define how we run our business by setting the highest standards of conduct throughout the Group. Its compliance is mandatory. 

If you have any questions on how the Code of Conduct may apply, please contact Legal/Human Resource.

In the rest of this document, the term “Code” refers to this Code of Conduct, as amended from time to time.
The Code reflects and supports the vision and values upheld by MBMR.

Our Vision

“The Complete Automotive Group”

Our Mission

To be the Automotive Partner of Choice to our employees, customers and investors

Our Values

We strive to promote and uphold these values for the whole Group:
  • Honesty and Integrity – Conduct our business with honesty, integrity and responsibility to safeguard our reputation and in compliance with legal and regulatory requirements
  • Respect – Treat each other as well as our customers, suppliers and stakeholders with respect; 
  • Teamwork – Work as a team in a participative environment to bring about better results 
  • Passion – Be the best we can and take pride in our work. Drive in achieving targets and then exceed them
  • Continuous Improvement – Challenge each other to do better and promote a performance-driven work environment
  • Skills – value and develop our skills
  • Caring – Be aware of the impact of our activities on the environment, safeguard the environment and engage actively with the community; ensure a safe and clean workplace
  • Zero waste – Discourage waste of assets and opportunities, leakage of business and abuse of assets; properly plan, fund and execute projects
  • Diversity – celebrate the richness of an environment that comes from a diverse workforce in gender, race and age
  • Reward – Recognize and reward accomplishments fairly and competitively




MBMR promotes and upholds a set of core values and principles of ethical behavior within the organization and in dealing with third parties in our business activities. We believe that our continued and future growth depends on each of us understanding and practising, today and everyday, these values and principles that form the foundation of MBMR.

The Code is not a standalone document. It is an integral part of the MBMR Governance Framework that includes:
  • The MBMR Board Charter
  • The MBMR Statement of Corporate Governance
  • The MBMR Risk Management Policy
  • The Whistle Blowing Policy
  • The policies and procedures manuals applicable to detailed areas of the operations of MBMR

Every employee of MBMR is encouraged to read and understand the documents that collectively form the MBMR Governance Framework.

MBMR supports the highest ethical standards in the conduct of its various business activities. This includes and in many cases go beyond compliance with the letter and spirit of the law. Our goal is not only to comply with the laws that govern our activities, but also to continuously demonstrate uncompromising integrity and a strong regard for others and the environment in which we operate. 

We strongly believe in the full compatibility of long-term profitability with good corporate behavior.

As it is not possible to prescribe specific behavior or standards for each situation that requires ethical judgment, the Code acts as a frame of reference in prescribing standards and guidance on situations and issues that are critically important to MBMR. The Code can also help you to identify when it would be appropriate to ask for guidance from your manager as to the proper course of conduct in any situation, which is not specifically covered by the Code.

The Code applies to each employee of MBMR. Violating the Code may subject an employee to a poor or unsatisfactory performance review, disciplinary action, including immediate termination, and/or legal actions.

Therefore, you are urged to read and understand the Code so that you are clear on all aspects of the Code and the expectations of you as an employee of MBMR. The Code forms part of the employment terms and conditions, will be reviewed periodically and may be changed from time to time. 

The Code affirms and upholds the ten core values and principles stated above through the promotion of five pillars of behavior— 
  • Act with honesty and integrity
  • Know and comply with the letter and spirit of the Law and the Company’s policies and procedures
  • Treat your colleagues and others you deal with in the course of business fairly and with respect
  • Act in the best interests of MBMR and avoid conflicts of interests
  • Protect MBMR’s assets and reputation

Conduct Business with Honesty and Integrity

One of our core values is to conduct business with uncompromising integrity and professionalism. We practice this by:
  • Dealing with our customers, suppliers and others fairly and honestly,
  • Acting as a responsible corporate citizen, respecting human rights, working together with our communities and managing the impact of our business on the world around us,
  • Keeping accurate financial and other books and records,
  • Respecting privacy and commitments we have given to others.

Conducting Business with Customers, suppliers and others

Our business has been built upon strong relationships of mutual respect and trust with our manufacturers, joint venture partners, customers, suppliers and others. To maintain and build upon these relationships, we treat everyone we deal with with fairness, honesty and respect.

In our marketing and in our interactions with customers and potential customers, we must always present MBMR’s products and services in a fair, accurate and responsible manner.

We value our relationships with our suppliers and communicate our requirements and expectations to them on a timely and open basis.

Being a responsible corporate citizen

For us, corporate responsibility means achieving business success in ways that demonstrate respect for people and the planet and uphold the values and high standards of ethics in matters concerning environmental health and safety. We strive to be a part of every community in which our business is located and be sensitive to the impact of our business on that community and the world around us.

In MBMR, we:
  • Promote equal opportunity for our employees at all levels with respect to issues such as color, race, gender, age, ethnicity or religious beliefs, and have zero tolerance for offensive behavior such as the exploitation of children, physical punishment, sexual harassment, involuntary servitude, or other forms of abuse,
  • Respect our employees’ voluntary freedom of association,
  • Reward our employees fairly and provide the opportunity to improve their skills and capabilities,
  • Provide a safe and healthy workplace, protect human health and the environment, and promote sustainable development,
  • Be sensitive to the impact of our business on communities and work with communities to at least maintain or improve the quality of life in those communities,
  • Promote the practice of these principles by those with whom we do business.

Preparing and maintaining accurate financial and other records

Our financial and other business records not only reflect but also shape the business decisions we make. We are responsible for ensuring that MBMR’s books and records are complete, fair, accurate, timely and understandable reflections of the group’s operations and business activities.

Any records required by our jobs, such as time cards and expense reports must be accurate and complete. If you become aware of records that may be inaccurate, report the situation immediately to Finance or Legal. We do not condone preparing false or misleading financial records or reports under any circumstances.

We engage internal and external auditors to ensure that the way we conduct business and keep records is consistent with relevant accounting, industry and internal standards. We must cooperate with auditors and ensure that anyone acting under our direction also cooperates with auditors.

Follow the Letter and Spirit of the Law and the Company’s Policies and Procedures

MBMR must comply with the laws of all countries in which it does business. We are each responsible for knowing and complying with all applicable laws or regulations. If we have any questions, ask your manager or Legal.

We must also act in a manner that upholds the spirit and intent of the law. Where the Code or company guidelines differ from any laws or regulations, we must always follow the higher standard. If you believe any requirement of the Code conflicts with the law, consult Legal.

Violations of laws and regulations have serious consequences, civil and criminal, both for the company and for the individuals involved. Therefore, when questions arise on these or other legal matters, you should always seek guidance from Legal.

Some of the legal topics we encounter in our business include anti-competitive and unfair trading practices, anti-corruption, environment, anti-money laundering, taxation, insider trading, intellectual property, privacy and public communications.

Anti-Competitive Activities

Antitrust laws, also called competition laws, govern the way that companies behave in the marketplace. Antitrust laws encourage competition by prohibiting restraints on trade. The laws deal in general terms with the ways companies deal with their competitors, customers and suppliers. Violating antitrust laws is a serious matter and could place both the company and the individual at risk of substantial criminal penalties.

MBMR is committed to competing vigorously but fairly for suppliers and customers.

Business activities in Malaysia involving antitrust and anti-competitive behavior are regulated under the Malaysian Competition Act 2010 (“Competition Act”). The Competition Act prohibits:
  • any formal or informal agreement or understanding that has the object or effect of significantly preventing, restricting or distorting competition in any market for goods or services; and
  • engaging in any conduct, which amounts to an abuse of a dominant position in any market for goods or services.

Affecting competition

It is important to note that there need not be a formal agreement in place for a breach of the Competition Act to occur. A breach can occur based on discussions at meetings, conferences, and informal gatherings or based on circumstances where an inference may be drawn of the intention of the company or its employees to commit an anti-trust or anti-competitive act. Therefore, no employee shall attempt, discuss or agree with a third party to:
  • directly or indirectly fix a purchase or selling price or any other trading condition, i.e. through minimum, recommended or maximum selling prices;
  • share markets or sources of supply of goods and services, i.e. to impose geographical limits or dividing the market by customer types;
  • limit or control production, market outlets or market access, technical or technological development or investment, for example to limit the supply of goods or cost of production or capital investment that would have the effect of creating an artificial price for goods based on restricting innovation and cost efficiency; or
  • fix or affect the outcome of tenders for goods or services through bid rigging such that tenders may not be determined based on the best prices and most attractive commercial terms.

Dominant position

MBMR’s situation may at times lend itself to the possibility of possessing a dominant market position. Accordingly, employees must be cautious in:
  • directly or indirectly imposing an unfair purchase or selling price or other unfair trading condition on a supplier or customer;
  • limiting or controlling production, market outlets or market access, technical or technological development or investment to the prejudice of consumers;
  • refusing to supply to a particular enterprise or group or category of enterprises;
  • applying different conditions to equivalent transactions with other trading parties to an extent that may:
    • discourage new market entry or expansion or investment by an existing competitor
    • force from the market or otherwise seriously damage an existing competitor which is no less efficient than the enterprise in a dominant position; or
    • harm competition in any market in which the dominant enterprise is participating or in any upstream or downstream market
  • making the conclusion of contract subject to acceptance by other parties of supplementary conditions which by their nature or according to commercial usage have no connection with the subject matter of the contract;
  • any predatory behavior towards competitors; and
  • buying up a scarce supply of intermediate goods or resources required by a competitor in circumstances where the enterprise in a dominant position does not have a reasonable commercial justification for buying up the intermediate goods or resources to meet its own needs.
A company may still commit one or more the abovementioned acts without falling foul of the Competition Act provided it has economic reasons for doing so or it is undertaking an economic response. Due to the complexity of the competition laws, each employee is required to observe these prohibitions strictly and while there are exceptions and exemptions under the law, the decision to act within the bounds of exception or exemption can only be exercised by the company, acting on professional advice. If there is doubt as to the application of the Code or the Competition Act on a particular situation or action, consult your manager or Legal.

Bribery and Anti-Corruption

Malaysia has bribery and other anti-corruption laws that are intended to prevent companies and individuals from gaining an unfair advantage and from undermining the rule of law. 

This prohibition on offering or paying bribes also applies to third parties acting on MBMR’s behalf, such as contractors or consultants. We must never engage a third party who we believe may attempt to offer a bribe to conduct company business.

When doing business with the government, consult with Legal to be certain you are aware of any special rules that apply, and obtain approval from your chief executive before providing anything of value to a government official.

If an employee makes a contribution to a political party, committee or candidate of their choice, such contribution must not directly or indirectly involve company funds or implicate MBMR in connection with the contribution.

The company’s resources (cash or otherwise) may be used for political contributions, provided it is legal and appropriate, only with the approval of the chief executive of the company.

Environmental management and compliance

A number of environmental laws, standards, requirements and policies apply to our business operations, practices and products. We have a responsibility to understand and follow these requirements, including:

• Conserving energy, water, raw materials and other natural resources
• Managing materials and wastes properly, and
• Complying with environmental permits and health and safety requirements.

We support a precautionary approach to the materials used in our products and strive to reduce and minimize the use of hazardous materials and environmental impact of our manufacturing technologies and in the use of properties occupied by MBMR.

We expect our suppliers and others to comply also with all applicable environmental, health and safety laws and standards in their operations.

Insider Trading

Malaysia has insider trading laws that restrict securities trading and other activities by anyone who is in possession of material, non-public information. 

Material, non-public information is any information not generally known to the public that people might find important in making their decisions to buy or sell securities (including shares, bonds and warrants issued by the company).

Any employee who is aware of material, non-public information regarding MBMR or any other company in the Group must not:
  • Trade in MBMR securities,
  • Disclose that information to others who may buy or sell securities because of the information, or
  • Otherwise use the information for personal advantage or the personal advantage of others.

Intellectual Property

Intellectual property rights are crucial to protecting the investments that companies and individuals make in developing new products and ideas. We protect our intellectual property and respect the intellectual property rights of others.

We must not copy, reproduce, or transmit protected material, such as writing, artwork, music, video, photographs, movie clips and software unless we have authorization or license.

We must use the confidential information of MBMR or others only for business purposes and disclose it only to those who are authorized and have a need to know. Even after we leave MBMR Group employment, we must continue to protect confidential information (whether MBMR's or another party’s) and not use or disclose it without authorization.

Furthermore, we must not request or encourage anyone to use or disclose privileged, proprietary, or confidential information unless they are authorized to do so by the owner of that information.

Privacy and Personal Data Protection Act 2010

Malaysia’s Personal Data Protection Act 2010 (“PDPA”) came into force on 1 January 2013. The PDPA encompasses seven data protection principles:

  • General principle: The processing of personal data requires consent and in the case of “sensitive” personal data, explicit consent is required
  • Notice and choice principle: Data users are required to notify the data subjects regarding the purpose for which the data is collected and about the right to request access and correction of the personal data
  • Disclosure principle: No personal data shall be disclosed without the consent of the data subject
  • Security principle: A data user shall take practical steps to protect the personal data from any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction
  • Retention principle: The personal data processed for any purpose shall not be kept longer than is necessary for the fulfillment of the purpose for which it was obtained
  • Data integrity principle: A data user shall take reasonable steps to ensure the accuracy and to maintain the data current for the purpose it was collected
  • Access principle: A data subject shall be given access to his personal data and shall be able to correct the personal data where the data is inaccurate or incomplete.
More comprehensive policies and procedures of MBMR regarding compliance with the PDPA will be outlined in the Privacy policies and procedures.

Public Communications

As a publicly listed company, MBMR must comply with a variety of regulations that govern public communications to investors and the public and promote transparency in financial markets. MBMR has specific requirements for financial reports and documents that the company files with or submits to Bursa Malaysia and in other public communications.

Therefore, if you are responsible for preparing such reports or contributing information for such reports, you need to ensure that the disclosures are accurate, reliable, and complete.

In addition, only authorized employees may make any public statements on behalf of MBMR, whether to the media, investors, or in other external forums, including the Internet. This includes disclosing new or confidential information regarding MBMR through social media applications and websites. If you are contacted by a reporter or the public on a topic on which you are not authorized to speak, refer the inquiry to the chief executive of the company.

Treat Each Other Fairly

We work as a team with respect and trust for each other. We strive to uphold open and honest communication and to protect employees from discrimination, harassment, or unsafe practices.

Open and Honest Communication

We value the free flow of thoughts, ideas, questions, and concerns. We encourage employees to raise work-related issues or concerns through our established processes as soon as issues or concerns arise.

We do not tolerate any retaliation against employees for asking questions or making good faith reports of possible violations of law, the Code, or other guidelines.

Equal Employment Opportunities and Discrimination

We value diversity in our workforce, as well as in our customers, suppliers, and others. We provide equal employment opportunity for all applicants and employees. We do not discriminate on the basis of race, color, religion, sex, national origin, ancestry, age, disability, veteran status, sexual orientation, marital status, pregnancy, gender identity, genetic information or any other characteristic protected by federal, state or local law, regulation, or ordinance. 

We follow these principles in all areas of employment including recruitment, hiring, training, promotion, compensation, benefits, transfer, and social and recreational programs.


We are committed to providing a workplace free of harassment based on personal characteristics such as race, color, religion, sex, national origin, ancestry, age, disability, veteran status, sexual orientation, marital status, pregnancy, gender identity, genetic information or any other characteristic protected by federal, state or local law, regulation, or ordinance. We strongly disapprove of and do not tolerate harassment of employees by managers or co-workers. We must treat co-workers, customers, and suppliers with dignity and respect.

We prohibit threats or acts of violence against co-workers, vendors, customers, or others. If you become aware of a threat or act of violent behavior in or near the MBMR workplace, notify management of the details of the act or threat immediately. Managers who receive such information should immediately notify Human Resources as applicable.


We comply with the safety laws, standards and guidelines that apply to our business. Sound safety practices are important in all of our workplaces.

To protect our employees, the public, and our communities, we conduct no activity without the proper safety precautions and produce no product without the proper safeguards.

We believe workplace injuries and illnesses are preventable. When we take care, employees and suppliers at our workplaces need to obey the safety requirements that apply to our job and workplace. We must not begin or continue any work activity contrary to safety requirements.

Act in the Best Interests of MBMR and Avoid Conflicts of Interest

A conflict of interest may occur when an employee’s personal or family interests interfere—or even appear to interfere—with the employee’s ability to make sound business decisions in the best interest of MBMR. We should not put ourselves in situations where we could be tempted to make MBMR business decisions that put our personal needs ahead of MBMR’s interests.

Conflict of Interest Examples

Conflicts of interest typically arise in any or more of the following situations:
  • Conducting any non-company business that interferes with the proper performance of our roles, such as conducting non-company business during working hours; utilizing confidential information, specialized skills or knowledge gained as a company employee; or using company property or equipment for non-company uses (exceeding reasonable personal use)
  • Using confidential information, specialized skills or knowledge gained as a company employee for personal gain or to MBMR’s detriment
  • Offering or accepting a gift, entertainment, or other payment that could be viewed as a bribe
  • Accepting any personal benefit that is or could be interpreted as being given to us because of our role or seniority or because the donors believe we might be in a position to assist them in the future
  • Participating in or influencing a company decision that may result in a personal gain, gain for an immediate family member, or gain for someone with whom we have a close personal relationship
  • Making use of business opportunities discovered or learned through the use of company property, information, or our positions that may result in a personal gain, gain for an immediate family member, or gain for someone with whom we have a close personal relationship
  • Owning a significant interest in any business that does or is seeking to do business with MBMR or is in competition with MBMR, when the ownership might dilute our loyalty to MBMR
  • Participating in or influencing a company decision to hire a family member, or supervising an immediate family member or someone with whom we have a close personal relationship

Handling Conflicts of Interest

We recognize that a conflict of interest may arise without any willful action on our part or that changes in circumstances may create a conflict or appearance of a conflict in situations where previously none existed.

If you become aware of a possible conflict of interest, disclose it immediately to your manager. Your manager will determine, in consultation with Legal as necessary, whether a conflict of interest exists, what needs to be done to resolve the conflict, or whether you may proceed.

Disclosure is mandatory; failing to disclose a conflict of interest is a violation of the Code.

Gifts and Entertainment

We recognize that exchanging business courtesies such as meals, entertainment, routine promotional gifts, and other items can be a part of building strong business relationships. At other times, such business courtesies are not appropriate.

These courtesies should be consistent with the business customs and practices of the place where they are offered or received. Whenever we are involved in the exchange of business courtesies, we must comply with the following standards:
  • Any entertainment offered or accepted should be a reasonable extension of a business relationship. It should occur infrequently and be modest in nature. If we accept such entertainment, we should reciprocate with similar modest hospitality to avoid any obligation to the other party. The term “entertainment” includes, but is not limited to, meals, charitable and sporting events, parties, plays and concerts. We must at all times respect the expressed policies, if any, of customers on entertainment and gifts.
  • We may accept gifts of nominal value when they are associated with promotional activities or are simply gestures of goodwill. However, such gifts should generally not exceed RM100 in value. Baseball caps, t-shirts, calendars, diaries and note pads are examples. If offered a gift exceeding RM100 we must report it promptly to our supervisor. In either situation, we should promptly inform the giver of MBMR’s gift policy. 
However, there are some principles that are fixed:
  • We do not offer or accept a bribe, that is, anything designed to obligate a person to act improperly with regard to our business
  • We do not offer or accept cash or cash equivalents without approval
  • We never participate in any business entertainment activity that would violate the law or embarrass us by its public disclosure
  • We consult our Legal representative before offering anything of value to government or political party officials, as such gifts and entertainment are strictly regulated and often forbidden entirely
  • We do not seek favors directly or indirectly, such as gifts, entertainment, sponsorships, or contributions from organizations doing business or seeking to do business with MBMR
If you have questions, consult Legal.

Where an employee makes or is involved in sourcing or purchasing decisions for MBMR, he/she must make those decisions with uncompromising integrity, honesty, independence and objectivity of judgment. We must seek the most technically efficient, cost-effective and high quality products and services, and to evaluate them using consistent and unbiased standards contained in applicable policies and procedures of MBMR. Therefore, we must not accept any gifts, entertainment or gratuities that could influence, or be perceived to influence, our sourcing and purchasing decisions.

We do not make any gift or provide a benefit of any kind to Government or a Government official or anyone connected to a Government official where it might be seen as a bribe. Where gifts are offered, they must be infrequently given symbolic gifts of no or very little commercial value, and they should typically have the company logo embroidered or imprinted. Suitable gifts of this nature may include baseball caps, golf balls, t-shirts or similar mementos. 

Protect the Company’s Assets and Reputation

We spend considerable resources to acquire, develop and maintain assets used for the company’s business. We each have a responsibility to comply with all procedures that protect the value of MBMR’s assets, including physical assets, information, MBMR brands, and its good name and reputation.

Protecting Physical Assets

Our physical assets include facilities, equipment, and computer and communications systems. We are to use these assets primarily for our business. As a narrow exception, we may use computer and communications systems for reasonable, personal use.

We need to follow applicable security and use procedures to protect the company’s physical assets from theft, loss, damage, or misuse. Report the theft, loss, damage, or misuse of company physical assets to Human Resources as soon as possible.

While we respect employee privacy, we should not assume that our desk, cubicle, or use of computer or telephone equipment is private or confidential. Subject to applicable laws and under the guidance of Legal, we may search and review both incoming and outgoing communications and all device information, including any password-protected employee communications.

Maintaining Information Security

Proprietary information is another valuable company asset and includes internal and external communication; digital information stored on laptops, handhelds, desktops, servers, backups, and portable storage devices; and hard copy documents, verbal discussions, and interactions via social media channels.

We need to take personal responsibility to safeguard both MBMR owned and third-party owned proprietary and confidential information from unauthorized disclosure, changes, or loss.

We must comply with all company security policies and procedures, including the company’s data protection policies, for handling information assets and systems to ensure that we meet legal obligations, protect our reputation, and protect our investment in proprietary information.

Safeguarding Intellectual Property

MBMR has valuable assets in its intellectual property as well as the intellectual property it represents or is licensed to use in its business. Intellectual property includes patents, copyrights, trade secrets, and trademarks. New ideas or inventions may be protected through a formal patent, or as trade secrets. A trade secret is any information that is sufficiently valuable and secret that it gives us an actual or potential advantage over others. A copyright is a right that prevents others from copying artistic, literary, and other works such as photographs, music, articles, and computer programs.

It is the policy of the Company to secure and protect its intellectual property rights, and to take appropriate action against any individual or group making unauthorized use of our rights. Just as we expect others to respect our intellectual property rights, we are committed to respecting the intellectual property rights of others.

To protect the value and recognition of the company’s trademarks and brand, we have established guidelines that specify how and when they may be used.

We must follow these guidelines whenever we use our company’s or licensed trademarks and brands, whether in internal and external communications or in materials prepared by third parties, such as advertising agencies and marketing/public relations consultants.

Representing MBMR

The value of our reputation and good name must be upheld whenever we represent our company. On occasion, MBMR may request individuals to act as an employee, officer, director, partner, consultant, representative, agent, or adviser of another entity. In those cases, an employee should discuss the situation with the direct manager. 

In other cases, such as when speaking on business or technical topics in a public setting or posting on the Internet – including through social media applications and websites – you must make it clear that you are expressing your own views and not those of our company, unless you are speaking as an authorized representative of the company.

You must carefully follow special rules of conduct if you participate in or take a leadership position with an industry trade association, to avoid antitrust violations.

Asking Questions and Reporting Concerns

Each employee is responsible for reading, understanding, and following the Code. 

Anyone who violates the Code is subject to discipline, up to and including termination of employment. Anyone who violates the law may also be subject to civil and criminal penalties.

To help our company conduct business with uncompromising integrity and professionalism, every employee has the duty to report possible violations of the law, the Code, and other company guidelines.

Ways to Seek Guidance and Report Concerns

Because the Code cannot address every situation, you will need to seek guidance whenever unsure of the correct course of action. There are many ways to ask questions about the Code or raise issues.

All employees of the MBMR Group are encouraged to ask questions or raise concerns with their direct manager or internal groups who specialize in handling such questions or issues, including Human Resources, Internal Audit, and Legal as soon as possible after they arise. 

Non-Retaliation Policy

We do not tolerate any retaliation against anyone who in good faith reports possible violations of law, the Code, or other company guidelines, or who asks questions about on-going or proposed conduct. Employees who attempt to retaliate will be disciplined.

Employees who believe they have experienced retaliation for reporting possible violations should contact Legal.

Approvals and Waivers

The Code sets out expectations for our company’s conduct. When certain situations require permission from management or another person before taking action, you need to raise the issue promptly to allow enough time for the necessary review and approval.

In a particular circumstance we may find it appropriate to waive a provision of the Code. To seek a waiver, speak with a manager, who will consider the request in consultation with others, such as Internal Audit, Legal or Human Resources.

Directors and executive officers who seek a waiver should address the Board of Directors or a designated committee of the Board. We disclose such waivers for directors and executive officers to the extent and in the manner required by law, regulation, or the stock exchange listing standard.


The Code serves as our guide for conducting business with integrity. It is not an employment contract and confers no rights relating to employment.

The Code is not a complete list of company guidelines. You are expected to know and comply with all company guidelines related to your job. Violation of these other guidelines may also result in discipline, up to and including termination of employment.

Subsidiaries & Associates