WONG ENGINEERING CORPORATION BERHAD

Registration No. 199601037606 (409959-W)

(Incorporated in Malaysia)

CODE OF CONDUCT

Statement 

WONG ENGINEERING CORPORATION BERHAD and its subsidiaries (“Wong Engineering” or “WEC” or the “Company”) is principally engaged in manufacturing in high precision metal parts.

While we conduct our business within the framework of applicable professional standards, laws, regulations and internal policies, we also acknowledge that these standards, laws, regulations and policies do not govern all types of behaviour. As a result, we also have a Code of Conduct for all Wong Engineering’s people and companies.

Each of us at Wong Engineering has an obligation to know and understand the guidelines contained in this Code. We also have an obligation to comply with the letter and spirit of this Code and to help others do the same. As individuals, we are encouraged to raise any issues and concerns through appropriate channels.

While the Code provides a broad range of guidance about the standards of integrity and business conduct, no Code can address every situation that individuals are likely to encounter. As a result, this Code is not a substitute for our responsibility and accountability to exercise good judgement and obtain guidance on proper business conduct but instead, we are encouraged to seek additional guidance and support from those designated as responsible for business conduct matters.

Mr. Yong Loy Huat

Chief Executive Officer

 

Purpose and Goals 

We are committed to comply with all laws and strive to meet or exceed applicable regulations wherever we conduct our business activities.

It is the responsibility of employees to be aware of the laws and regulations that govern their activities and comply with those laws, using all appropriate corporate resources. Every employee must understand and be responsible for incorporating safe behavior and environmental quality into their daily business activities.

 

Scope

This Code of Conduct covers standards for Labor, Health and Safety, Environment, Business Ethics and Management Systems to manage conformity to this Code.

 

Definition

  1. Freely chosen employment

Workers are employed on his / her free-will and are not required to surrender any personal identification documents or money.

  1. Original personal identification documents

Personal identification documents are documents that are issued by relevant government authority (example: personal identification card, passport, driver’s license).

  1. Underage Worker

Worker age below 18 years old.

  1. Young Worker

Worker age 16 and above but below 18 years old.

  1. Child Worker

Worker age below 16 years old.

  1. Age Proof Documents

Government issued documents such as NRIC, or Passport.

  1. Whistleblower

Any person who makes a disclosure about an improper conduct by an employee or officer of a company, or by a public official or official body.

  1. Collusion

Collusion is an agreement between two or more persons to limit open competition by deceiving, misleading, or defrauding others of their legal rights, or to obtain an objective forbidden by law typically by defrauding or gaining an unfair advantage.  It can involve an agreement among companies to divide the market, set prices, or limit production. It can involve wage fixing, kickbacks, or misrepresenting the independence of the relationship between the colluding parties.

 

Responsibilities

  1. CEO

Chief Executive Officer shall establish the WEC Code of Conduct and is responsible for the entire organization and the supply chain of the company’s state of compliance to applicable laws and regulations.

  1. Head of Department

HR Department shall execute and monitor the policy and procedure for this Code of Conduct. Immediate action will be taken for any non-conformances and reported to the Board of Management.

  1. Entire Organization

All employees are expected and directed to comply with all applicable laws, rules and regulations as well as the Company’s internal policies.

  1. Supply Chain Management Department

Supply chain shall ensure entire supply chain (suppliers) of the organization is fulfilling the WEC Code of Conduct.

 

A. Labor

The Company’s fundamental policy is that we treat all our colleagues with respect. Wong Engineering is committed to providing a fair work environment free of any form of harassment based on race, gender, religion, national origin, age or any other non-job-related personal characteristics.

  • Freely Chosen Employment
    • No original personal identification documents or monetary shall be required to deposit to secure employment with the Company.
    • Deposit of any original personal identification documents with the Company is for security verification only. A letter of consent from the respective employees shall be obtain and no fee shall be charge for safekeeping. The original personal identification documents must return to the worker within 12 hours upon his/her request.
    • No force, bonded, involuntary labor practice shall be in place.
    • All job application with the Company shall be free of charge and the management are not responsible for any fees paid by the employees to any external parties.
    • Employees shall not be restricted to access their basic liberties such as freedom of speech, expression in accordance to standard law at any time.
    • Employees employment terms shall be stated clearly and explained to workers in a language that’s understandable to them or in their native language by the recruitment agency of the source country prior acknowledgement of contract.
    • Recruitment agency shall submit the duly acknowledge letter by the employee to confirm their understanding of the terms of employment and contract contents.
    • Employee shall sign acceptance of the term of the employment and a copy of the contract shall be provided to respective employees.
    • No penalty shall be imposed when an employee terminates their employment in accordance to the employment termination notice period.
  • Young Workers
    • The Company strictly adheres to the Children & Young Persons (Employment) Act 1966 of Malaysia.
    • The Company prohibits the employment of child labour whether directly or indirectly.
    • Age proof documents will be verified during the hiring process and photocopies of age proof documents retained in the employee personal file.
    • In the event of young worker being employed, the Company shall comply to the standard law on Children & Young Person (Employment) Act 1966 (Sect 2 ~ 6).
  1. Apprentice/Intern/Student
    • In line with the Company corporate responsibility, the Company provides apprentice /intern /student employee with an employment opportunity to complete their course of study field with the maximum duration of 6 months.
    • The apprentice / intern / student employee will enjoy benefits in accordance to the Company policy and the standard law of Employment Act 1955.
    • Apprentice / Intern/ student employee who finished their studies are welcome to join the Company subject to available job opening with employment terms and benefits as per the company’s policy.
  1. Working Hours
    • Working hours for all employees is in accordance to Employment Act 1955, not exceeding 48 hours per week and overtime work is 104 hours per month.
    • 30 minutes of mandatory meal break for every 4 hours of work.
    • One (1) rest day in each week.
    • Special approval shall be obtained from Top Management and the local authority when the hours work exceeds the standard law.
    • Employee attendance is consistently recorded at all times.
    • Working hours shall refer to the term of employment that employee has acknowledge agreed.
    • Wages will be deducted according when they report late for work.
  1. Wages and Benefits
    • Wages paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits.
    • Overtime rate in accordance to Employment Act 1955 as follows:
  • Weekday – 5 times regular hourly rate;
  • Rest Day – 0 times regular hourly rate; and
  • Public Holiday    –           3.0-time regular hourly rate.
    • No unlawful deduction shall be allowed, this included disciplinary measure.
    • Any wages deduction will be done in accordance to Employment Act 1955.
    • Worker wages and benefit shall refer to their contract of employment.
    • Wage payment shall be made via bank transfer to the worker’s legal name bank account only.
    • Employee will be provided with a detailed pay slip that is easy to understand.
  1. Sexual Harassment
    • The Company is committed in providing a workplace that is free from sexual harassment and comply to the Employment (Amendment) Act 2012, Part XVA.
    • Sexual harassment in the workplace is against the law and will not be tolerated. When the Company determines that an allegation of sexual harassment is credible, it will take prompt and appropriate corrective action.
    • Unwelcome actions such as below are inappropriate and meet the definition of sexual harassment:
  2. Sexual pranks, or repeated sexual teasing, jokes, or innuendo, in person or via e-mail or SMS;
  3. Verbal abuse of a sexual nature;
  4. Touching or grabbing of a sexual nature;
  5. Repeatedly standing too close to or brushing up against a person;
  6. Repeatedly asking a person to socialize during off-duty hours when the person has said no or has indicated he or she is not interested;
  7. Giving gifts or leaving objects that are sexually suggestive;
  8. Repeatedly making sexually suggestive gestures;
  9. Making or posting sexually demeaning or offensive pictures, cartoons or other materials in the workplace;
  10. Off-duty, unwelcome conducts of a sexual nature that affects the work environment.
  • The above actions will constitute sexual harassment when:
  1. The unwelcome conduct unreasonably interferes with an individual’s work performance or creates an intimidating, hostile, or abusive work environment; or
  2. An employment decision affecting that individual is made because the individual submitted to or rejected the unwelcome conduct.
    • If the Company receives a credible allegation of sexual harassment, or has reason to believe sexual harassment is occurring, it will take the necessary steps to ensure that the matter is promptly investigated and addressed.
    • Employees who have been found by the Company to have subjected another employee to unwelcome conduct of a sexual nature will be subjected to disciplinary action which will include termination of employment.
  1. Non-Discrimination
    • Employment practice in hiring, wages, promotion, rewards and access to training are based on merit and business needs, and not on race, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status.
    • Medical test or physical exam should not be used in a discriminatory way for any of above situation.
    • Reasonable accommodation for religious practices shall be provided for worker and workers are free to practice their own faiths.
  1. Freedom of Association
    • The Company respect the employee freedom of association in accordance to existing laws and regulation.
    • Employee can establish and participate in collective negotiation and engage in legal peaceful assembly according to local laws requirement.
    • Employee and/or their representatives can communicate, share ideas and concerns with management regarding work environment and management practices without fear of discrimination, reprisal, intimidation or harassment.

B. Health and Safet

The Company is committed to provide a safe, healthy and productive working environment to minimize potential incidence of work-related injury and illnesses.  Each employee has a personal responsibility to another Wong Engineering employee and to the Company to help eliminate actions or circumstances which undermines this environment. Safe and healthy work environment enhances the quality of products and services, consistency of production, worker retention and morale.  Company will provide all training requirements to help reduce the risk of occupational hazards in the workplace.

It is the responsibility of all employees to be aware of the laws and regulations that govern their activities and comply with those laws, using all appropriate corporate resources. Every employee must understand and be responsible for incorporating safe behavior and environmental quality into their daily business activity.

The health and safety standards are:

  1. Occupational Safety
    • Work environments with exposure to potential safety hazards (e.g. electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tag-out).
    • Employees shall be provided with appropriate, well-maintained, personal protective equipment and educational materials for hazards associated to their work scope.
    • Safety training or briefing is to be conducted at least once a year.
    • Employees are encouraged to raise their safety concerns to the Safety Committee for further improvement.
  1. Emergency Preparedness
    • Identify and assess the potential emergency and events such as HIRARC
    • Minimized the impact by implementing emergency plans and response procedure (ERT) including the followings:
  • emergency reporting;
  • evacuation plan to be place at appropriate locations.
  • employee evacuation training and fire drills to be conducted at least once in a year;
  • appropriate fire detection and suppression equipment must be installed and inspection on quarterly basis;
  • adequate exit doors and ensure not blocked at all times; and
  • recovery plans to be in place.
    • All the plans and procedures shall focus on minimizing harm to life, environment and property.
  1. Occupational Injury & Illness
    • Procedure and systems shall be in place to prevent, manage, track and report occupational injury and illness including the following provisions:
  • To encourage employee to report any occupational injury to the Company;
  • Classify and record injury and illness cases;
  • Provide necessary medical treatment;
  • Investigate cases and implement corrective action to eliminate the root cause; and
  • Facilitate employees to return to work.
  1. Industrial Hygiene
    • Identify, evaluation and control the work environment with exposure to chemical, biological and physical agent.
    • Engineering or administrative controls must be used to reduce over exposures.
    • Appropriate personal protective equipment in place.
  1. Physically Demanding Work
  • The following physically demanding hazard shall be identified, evaluated and controlled:
  1. Manual material handling and heavy or repetitive lifting;
  2. Prolonged standing; and
  3. Highly repetitive or forceful assembly task.
  1. Machine Safeguarding
    • Production and other machinery shall be evaluated for safety hazards.
    • Physical guards, interlocks and barriers shall be provided and properly maintained to prevent any injury hazard to workers.
  1. Sanitation, Food and Housing
    • The following facilities shall be provided with ready access:
  • Clean toilets facilities;
  • Potable water and sanitary food preparation;
  • Clean Storage facilities; and
  • Eating facilities.
    • Employee dormitories provided by any party (including labor agent) shall be maintained clean and safe, with available appropriate emergency escape, reasonable entry and exit privileges.
  1. Health and Safety Communication
  • Health and safety training will be provided to all employees.
  • Health and safety related information shall be clearly posted around the facility.

 

C. Environmental

The Company recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. Recognized management systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful source of additional information.

The environmental standards are:

  1. Environmental
    • All local law requirements on environment will be strictly adhere.
  1. Pollution Prevention and Resources Reduction
    • The use of resources and generation of waste of all type, including water and energy shall be reduced or eliminated at the source or by the following practice:
  2. Modifying production;
  3. Maintenance and facility process;
  4. Material substitution;
  5. Conservation; and
  6. Recycling and re-using materials.
  1. Hazardous Substances
    • Identified chemical and other material hazard that released to the environment.
    • Managed chemical and other material hazard to ensure safe handling, movement, storage, use, recycling or reuse and disposal.
  1. Waste Water & Solid Waste Management
    • Implement a systematic approach to identify, manage, reduce and responsibly dispose of our wastes.
    • Wastewater generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal.
    • Implemented reduce generation of waste water initiatives.
    • Conduct routine monitoring for wastewater treatment systems performance.
  1. Air Emissions
    • Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge.
    • Where applicable, routine monitoring air emission control system performance shall be conducted.
  1. Product Content Restrictions
    • All applicable laws, regulations and customer requirements regarding prohibition or restriction or specific substances in product and manufacturing including labeling for recycling and disposal shall be adhere to.

D. Ethics

Every employee is expected to act, at all times, in an honest and ethical way, including the ethical handling of actual or apparent conflicts of interest. To meet social responsibilities and to achieve success in the marketplace, all parties shall uphold the highest standards of ethics including:

  1. Business Integrity
    • All employees are expected to strictly comply with anti- trust or competition law and anti-monopoly laws of the countries in which the Company conducts business. This refers to situation where competitors co-operate to reach anti-competitive agreement with a view to restraint trade, join refusals to deal with a third party, fixed prices, allocation of markets, customers or territories.
    • Anti-competition is defined in accordance to Chapter 1 of the Malaysia Competition Act 2010.
    • Any gratification given to customers or suppliers of the Company or the receipt of gratification by employees as defined under Sections 16 to 23 of the Malaysian Anti-Corruption Commission Act 2009 are strictly prohibited.
    • Gratification is defined as
  2. money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;
  3. any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
  4. any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;
  5. any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;
  6. any forbearance to demand any money or money’s worth or valuable thing;
  7. any other service or favour of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and
  8. any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f);
    • The Company’s success depends on building productive relationships with customer and suppliers based on integrity, ethical behavior and mutual trust. All customers are treated fairly and without discrimination. Purchases of materials and services from suppliers are bases on the merits of the purchase opportunities available from competing offers.
    • The Company prohibits the receipt of any gifts and entertainment from supplier or of customer of Wong Engineering, unless permission is granted by HR Department in consultation with the CEO of Wong Engineering. In addition, you must disclose and handover to the HR Department all gifts received.
    • Declining of gifts and entertainment must be conveyed in an ethical and respectful manner to suppliers and with reference to the Company HR Policy. Always maintain good business relationships.
    • Year’s end gifts of calendar and dairies will not fall under this restriction.
    • The Company adheres strictly to Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (“AMLA Act”). All employees are expected to observe and familiarize themselves with Part 2 of AMLA Act for prohibited offences in ensuring compliance to prevent, detect and report on money laundering and financing of terrorism activities.
    • All employees are expected to adhere to the Securities Industry Act 1983 where employees in procession of inside information is prohibited on conducts as defined under Section 89E of the Act.
  1. Conflicts of Interest

2.1    The Company’s policy on conflicts of interest are based on the principle that an employee’s decisions in the business must be made solely in the best interest of the Company.

2.2    Conflicts between the interest of the Company and our employees or their family are prohibited.

2.3    All employees are expected to be aware and comply with the conflict of interest policy and procedures of the Company.

  1. Confidential /Intellectual Property
    • Protecting confidential and Intellectual property right, transfer of technology material and customer information is vital to the Company’s future success and, therefore, could be important to the job security of all employees.
    • Every employee has a moral and legal obligation not to disclose confidential or trade secret information to third parties.
    • The disclosure of any non- public information concerning the Company, their clients or their employees is prohibited unless approved by the management.
  1. Fair Business, Advertising and Competition
    • Standards of fair business, advertising and competition are to be upheld.
    • Appropriate means to safeguard customer information must be available.
  1. Protection of Identity and Non-Retaliation
    • Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law.
    • Communication process shall be in place to ensure any personnel able to raise any concerns without fear of retaliation.
  1. Responsible Sourcing of Minerals
    • The sources of tantalum, tin, tungsten and gold in the products of manufacturing shall not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in countries identified by the Organisation for Economic Co-operation and Development (refer to OECD guideline as set out in a document called ‘Due Diligence Guidance for Responsible Supply Chains from Conflict-Affected and High-Risk Areas).
    • Appropriate verification measures shall be in place on the source and chain of custody of the used material and make the information available to stakeholders upon request.
  1. Privacy
    • Everyone that has business relationship including suppliers, customers, consumers and employee personal information or privacy shall be reasonably protected.
    • Local privacy and information security law and regulatory requirements for personal information collect, store, process, transmit and share shall be adhering.

 E. Management System

The management system shall be designed to ensure:

  1. compliance with applicable laws, regulations and customer requirements related to the participant’s operations and products;
  2. conformance with this Code; and
  3. identification and mitigation of operational risks related to this Code.

It should also facilitate continual improvement. The management system should contain the following elements:

  1. Company Commitment
    • Corporate social and environmental responsibility policy statements affirming Company commitment to compliance and continual improvement, endorsed by the management and posted in the facility in the local language.
  1. Management Accountability and Responsibility
    • Managers are responsible for communicating the code of conducts to employee and supervising compliance.
    • Employees are encouraged to talk to supervisors and other appropriate personnel, when in doubt about the best course of action in a particular situation.
  • Reporting of Violations
    • Every employee is expected to report any violations of laws, rules and regulations or misconducts so that such matters can be properly addressed.
    • Reportscan be made directly to the relevant supervisors, or where                         appropriate, directly to higher level in accordance to policy and procedure.
    • Reports may be made on a confidential, anonymous basis.
    • The Company prohibits intimidation or retaliation by any managers or co-                        worker against any employee for such reports made in good faith.
    • Disciplinary proceedings shall be taken for failure to comply with the Code of Conducts which may result in termination and the employee concerned shall be personally liable if he/she breaks any Malaysian law.
  • Legal and Customer Requirements
    • Process for identify, monitor and understandable applicable law, regulations and customer requirement, including the requirement of this code shall be in place.
    • Consistently record the list of the applicable law, regulations and customer requirement, including the requirement of this code.
  • Risk Assessment and Risk Management
    • Process to identify the legal compliance, environmental, health and safety, labor practice, and ethics risk associated with business operation shall be in place.
    • Determination of the relative signification for each risk and implementation of appropriate procedural and physical controls to manage the identified risks and ensure regulatory compliance shall be exercise.
    • Risk review shall be on yearly basis.
  • Improvement Objectives
    • Written performance objectives, targets and implementation plans to improve the social and environmental performance, including a periodic assessment of operation performance in achieving those objectives.
    • The Management shall review the performance plan on yearly basis.
  • Training Management
    • Human Resources staff shall prepare annual training plan by identifying and assessing the needs of the training.
    • The Management shall approve the annual training plan.
    • Human Resources Manager shall ensure the plan is execute and assess the feedback from participants.
  • Communication
    • Communicate clear and accurate information about the policies, practices, expectation and performance to workers, suppliers and customer.
    • Regular communicate shall be in place.
  • Worker Feedback and Participation
    • Regularly assess and obtain employee feedback on the practices and conditions to foster continuous improvements.
    • Assess and obtain employee feedback and analyses the needs for improvement.
    • Employee feedback shall be review by the Management at least once a year.
  • Audits and Assessments
    • Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and Customer contractual requirements related to social and environmental responsibility.
    • Create an independent team to conduct audits, assessment and investigation to assess the conformity to legal and regulatory requirements, the Code and Customer contractual requirements.
    • Audit, assessment and investigation result shall be submitted to the CEO for review.
    • Audit, assessment and investigation shall conduct at least once a year and / or conduct when is necessary.
  • Corrective Action Process
    • Deficiencies identified by internal or external assessments, inspections, investigations and review shall be correct timely by the Head of Departments.
    • The Management shall review the status of corrective action in regular basis.
  • Documentation and Records Management
    • Creation and maintenance of documents and record to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy shall be in place.
    • Privacy documents and records shall be view in the designed only and do not disclosure, copy or publish without prior approval from Management.
    • All the record store period shall be follow the legal requirements.
    • Disposal of the record shall ensure the process is at the appropriate confidential level.
  • Supply Chain Responsibilities
    • The Company’s expectation and the Code shall be communicated to suppliers.