Our Code on Business Conduct and Ethics (“Code”)
Good governance is an integral aspect of our ESG framework at SAMEE. It encompasses the systems, principles, and policies that guide our operations, ensuring that we conduct our business with integrity, transparency, and accountability.
Sustainability > Governance
With the globalisation of the economy, regulations and variations in governmental and economic frameworks, it is crucial to establish a culture based on ethics and integrity. Our corporate governance system ensures sound risk management and strong internal controls.
In FY2023, SAMEE made revisions and updates to its Enterprise Risk Management Framework in accordance with the principles and guidelines outlined under the Committee of Sponsoring Organisation of the Treadway Commission’s Enterprise Risk Management – Integrating with Strategy and Performance 2017 and is embedded in the Group’s management systems.
SAMEE introduced an updated risk management framework to address material ESG concerns, regulatory compliance and strategic goals. This framework aligns with enhanced corporate governance guidelines of the Malaysian Code of Corporate Governance, released in April 2021 by the Securities Commission of Malaysia.
The Board delegates the review of the risk management framework and dashboards, including significant risks and action plans, to the Risk and Sustainability Committee (“RSC”). The Chief Risk Officer and management staff, along with the risk management section of business unit heads, support the RSC’s operations. SAMEE upholds ethical and honest business conduct through enforced internal control policies. These policies are accessible on the Group’s website.
SAMEE’s corporate governance framework includes a Code on Business Conduct and Ethics (“Code”), an anti-bribery and corruption policy and a whistleblowing policy. We expect employees to demonstrate integrity when interacting with stakeholders and violating the Code is unacceptable. Reporting incidents of wrongdoing or non-compliance is encouraged.
To provide more detail, our Code includes policies related to Business Ethics, Standards of Conduct and Conflicts of Interest. The Code covers the following topics:
Our Code on Business Conduct and Ethics (“Code”)
All SAMEE employees are bound to adhere to the implemented Code, which establishes behavioural principles and responsibilities within and outside the Company. These principles are communicated and emphasised during training sessions. Employees commit to ethical business conduct and compliance through signed SAM Employee Agreement.
Our Core Values
SAMEE has in place the ERM framework in accordance with the principles and guidelines outlined under the Committee of Sponsoring Organisation of the Treadway Commission’s Enterprise Risk Management – Integrating with Strategy and Performance 2017 and is embedded in the Group’s management systems.
In order to identify, measure, assess and manage risks in our activities and ensure they are aligned with the Group’s strategic objectives and regulatory requirements, we implemented a risk management framework to identify, measure, assess and manage risks faced by the Group.
• Board of directors provides oversight of the Group’s strategic plans and their corresponding strategic; and carries out governance responsibilities to support Management in achieving strategy and business objectives for long term value creation
• Management establishes operating structures in the pursuit of strategic and business objectives
• Management defines the desired group-wide culture
• Management demonstrates commitment to the Group’s core values
• Management is committed to build human capabilities in alignment with strategic and business objectives
• Management considers potential effects of business context on risk profile
• Management defines risk appetite in the context of creating, preserving and realising value
• Management evaluates alternative strategies and their potential impacts on risk profile
• Management considers risks in formulating business objectives at various levels that align and support strategy
• Management identifies risks that impact the performance of strategy and business objectives
• Management assesses the severity of the identified risks
• Management prioritises risks as the basis to select appropriate responses to risks
• Management selects and implements risk responses
• Management develops and evaluates portfolio view of risks
• Management assesses changes that may substantially affect strategy and business objectives
• Management reviews group performance and considers risks
• Management pursues improvement in ERM
• Management leverages Group’s information and technology systems to support ERM
• Management uses existing communication channels to support ERM
• Management reports on risk, culture and performance at different levels and across the Group
SAMEE Group strictly prohibits bribery and corruption, with severe consequences for violators. Suppliers are annually reminded of our zero-tolerance stance and are expected to comply. We encourage suppliers to report conflicts of interest. Employees receive annual policy reminders and those in sensitive positions must confidentially disclose their debt position.
The management philosophy at SAMEE has long been centred around the principles of “No Bribery, Zero Corruption” in all aspects of the company’s operations, predating the implementation of Section 17A of the MACC Act 2009. Our policies outline our ethical approach to conducting business daily. Our Anti-Bribery and Corruption Policy can be publicly accessed on our website at https://www.sam-malaysia.com.
All our directors have participated in training sessions on anticorruption measures and will continue to keep themselves abreast of anti-bribery and anti-corruption policies and knowledge. SAMEE has communicated its anti-corruption policies and procedures to all 1,972 staff members across three countries, ensuring complete coverage.
Additionally, a significant portion, comprising 48% of the total workforce, has also received comprehensive anti-corruption training. In our effort to improve communication and training on anti-corruption policies and procedures, SAMEE has developed more training methods e.g., e-learning to keep the training more reachable and convenient to our employees.
All 127 business partners have been made aware of and attended training for SAMEE’s anti-corruption policies and procedures. We will provide regular updates on changes to the anti-corruption policy, new risks and best practices to our business partners, which can be done through email or newsletter. During the period for FY2023, there were no incidents of corruption reported or identified within SAMEE. This reflects our commitment to maintaining high standards of ethical conduct and integrity in our operations.
The Whistleblower Protection Act 2010 is the basis for SAMEE’s Whistle Blowing Policy (“WBP”). Our WBP provides employees and external parties with the assurance that they have access to an effective reporting channel in the event of any breaches of our Code of Conduct, ethical misconduct, or omissions by a SAMEE employee. When employees join our company, we prioritize their seamless integration by providing them with comprehensive direction on their roles and responsibilities and maintaining an open and supportive environment.
Whistleblowers may submit their report to https://www.kpmgethicsline.com.sg and the complaint will be directed to the KPMG Portal. The report would thereafter be forwarded to both the Chief Executive Officer and the Chairperson of the AC.
Our Human Resources Team is also actively committed to handling these grievances with sensitivity, fairness, and discretion, fostering a workplace where every employee's well-being and concerns are taken seriously and addressed appropriately.
For more information, the WBP is available on our website at https://www.sam-malaysia.com.
