Business of Conduct

 

1.0 PURPOSE
The purpose of this document is to state YKK (MALAYSIA) SDN. BHD. commitment in conducting its business with the highest standards of ethics and in full compliance with the law. These guidelines outline the basic responsibilities of each employee binding in the employment contract.
2.0 OUR BASIC RESPONSIBILITIES


2.4.1 Conflicts of interest

Our private life is very much our own. Still, a conflict of interest may arise if we engage in any activities or advance any personal involvement at the expense of YKK interests. It’s up to us to avoid situations in which our loyalty may become divided. Each individual’s situation is different, and in evaluating our own, we will have to consider many factors. The most common types of conflicts are addressed here to help us make uniformed decisions.

2.4.1.1 Assisting a competitor:A possible conflict of interest is providing assistance to an organization that markets products and services in competition with YKK current or potential products or service offerings. We must not work for such an organization as an employee, a consultant, as a member of its board of directors, or in any other capacity. Such activities should be avoided because they may divide wer loyalty between YKK and that organization.

2.4.1.2 When someone close to we works in the industry:With the growth in two career families and the expansion of the industry, we may find ourselves in a situation where our spouse, another member of our immediate family, or someone else we are close to is a competitor, supplier or consultant to YKK or is employed by one.

While everyone is entitled to choose and pursue a career, such situations call for extra sensitivity to security, confidentiality and conflicts of interest. The closeness of the relationship might lead we to inadvertently compromise YKK interests.

Several factors need to be considered in assessing such a situation i.e. the relationship between YKK and the other company, the nature of our responsibilities as an YKK employee and those of the person close to we, and the access each of we has to wer respective employer’s confidential information.

To remove any such doubt or suspicions, we should review our specific situation with wer manager to assess the nature and extent of any concern and how it can be resolved. In some limited instances, a change in the job responsibilities of one of the people involved may be necessary.

2.4.1.3 Use of YKK time and assets:We may not perform outside work or solicit such business on YKK premises or while working on YKK time, including time off we are given with pay to handle personal matters. Also, we are not permitted to use YKK equipment, telephones, materials, resources or proprietary information for any outside work. Any employment that we engage outside YKK should not adversely affect wer ability to perform the responsibility of wer position with YKK.

2.4.1.4 Personal financial interests:We should not have a financial interest in any organization that YKK does business with if that interest may cause we to have a conflict of interest with YKK and such organizations, suppliers and customers.


2.5.1 Protecting company assets and intellectual property (IP) rights

YKK security practices are intended to protect all of the company’s assets - its people, proprietary information and equipment. This includes confidential data entrusted to many employees in connection with their jobs, and intellectual property that is owned by YKK or licensed to YKK by others. We should appropriately maintain and use our own intellectual property rights, and continuously undertake the necessary management and improvements to prevent infringement of the IP rights of other companies.

For this reason, we are personally responsible not only for protecting YKK property entrusted to us, but also for helping to protect the company’s assets in general.

2.5.2 Direct requests for information

If someone outside the company ask us questions, either directly or through another person, do not attempt to answer them unless we are certain we are authorized to do so. If we are not authorized, refer the person to the management.

2.5.3 Disclosure and use of confidential information

Besides wer obligation not to disclose any YKK confidential information to anyone outside the company, we are also required, as an employee to use such information only in connection with YKK business. These obligations apply whether or not we developed the information werself.

2.5.4 Post-employment Obligations

If we leave YKK for any reason, including retirement, we still have obligations to protect the company business assets. We may not disclose or misuse YKK confidential information. In addition, the company’s ownership or intellectual property that we created while we were an employee continues after we leave the company.

2.5.5 Communication systems

The increasing reliance placed on internal information and communications such as E-mail and voice mail in carrying out YKK business makes it absolutely essential to ensure their integrity. Like other YKK communication assets such as telephones and fax machines, these facilities and the information they make available through a wide variety of data bases should be used only for conducting YKK business. Their unauthorized use, whether or not for personal gain, is a misappropriation of YKK assets.

2.5.6 Recording and reporting business information

Every employee records information of some kind and submits it to the company. Some employees are directly responsible for recording financial data. Inaccurate or dishonest records or reporting of such information can have serious legal consequences. We should record and report all information accurately and honestly.

Expense accounts are another important record. Employees are entitled to reimbursement for expenses which management considers reasonable - but only if these expenses are actually incurred. To submit an expense account for meals not eaten, miles not driven, airline tickets not used, or for any other expense not incurred, is dishonest reporting, is prohibited, and could result in dismissal as well as criminal prosecution.

Dishonest reporting of information to organizations and people outside the company is also strictly prohibited. It could lead to civil or even criminal liability for we and YKK. This includes not only reporting information inaccurately but also organizing it in a way that is intended to mislead or misinform those who receive it. Be careful not to make false or misleading statements in external reports, particularly in situations where we are reporting to government entities. False statements made to the government and false claims for payment violate specific statutes and can result in criminal and civil penalties including imprisonment.


2.6.1 Avoid misrepresentation

Never make misleading representations to anyone. If we believe that the other person may have misunderstood us, promptly correct any misunderstanding. If we are involved with advertising, the copy must be truthful and not designed to mislead. Honesty based on clear communication is integral to ethical behavior. The resulting trustworthiness is essential to sound, lasting relationships.

2.6.2 Treat everyone fairly

Everyone we do business with is entitled to fair and even-handed treatment. That should be true no matter what relationship with an outside organization were may be - whether we are buying on behalf of YKK or representing the company in any other capacity.

We must treat all suppliers fairly. In deciding among competing suppliers, weigh all the facts impartially. We should do so whether we are in a procurement function, any other part of the business - and whether we are buying many items or just a few, contracting for a small repair job or procuring any other service.

Whether or not we are in a position to influence decisions involving the evaluation or selection of suppliers, we must not exert or attempt to exert influence to obtain special treatment on behalf of a particular supplier. Even to appear to do so can undermine the integrity of our established procedures. It is essential that suppliers competing for YKK business have confidence in the integrity of our selection process. That confidence can be jeopardized if former YKK employees competing as suppliers or suppliers’ representatives are perceived to have inside information or an unfair advantage because of their former YKK job responsibilities.

2.6.3 Avoid reciprocal dealing

Seeking reciprocity is contrary to YKK policy and can violate laws. In other words, we may not tell a prospective supplier that were decision to purchase its goods and services is conditioned on the supplier’s agreement to purchase YKK products or services. To avoid charges of reciprocal dealing, do not tell a prospective customer that it must purchase products and services from YKK to be a supplier to YKK. This does not mean that the YKK customer should not be considered a supplier to YKK.

2.6.4 Prohibitions on Child Labor and Forced Labor

We would not compromise to recruit and employ children below the legal working age stipulated by the Employment Act.


2.7.1 Multiple relationships with other organizations

Frequently, other organizations have more than one relationship with YKK as follows:

  • A Company may be both a customer and a competitor to YKK.
  • Another organization may be a supplier and customer to YKK at the same time.
  • A few organizations may even be suppliers, competitors and end users of YKK products and services.
YKK has relationships with many other types of organizations that continue to emerge in our industry. They include leasing companies, software houses, distributors, dealers, banks and other financial institutions, and many others who compete with, buy from or sell to YKK. In any dealings, it is important that we understand the various relationships involved.

2.7.2 Business contacts with competitors

Because many companies have multiple relationships with YKK, it is particularly important to recognize when a company we are dealing with, as a supplier for example, is also a YKK competitor. Such relationships require extra care. It is possible that we, other YKK employees, and competitors will, from time to time, meet, talk, and attend the same industry or association meetings. Usually these contacts are perfectly acceptable as long as established procedures are followed. Acceptable contacts include sales to other companies in our industry, purchased from them, and attendance at business shows, standards organizations and trade associations. But even these contacts require caution.

In all contacts with competitors, we should not discuss pricing policy, costs, inventories, marketing and product plans, market surveys and studies, production plans and capabilities and of course, any other proprietary or confidential information.

Collaboration or discussion of these subjects with competitors can be illegal. If a competitor raises any of them, even lightly or with apparent innocence, we should object, stop the conversation immediately, and tell the competitor that under no circumstances can we discuss these matters. If necessary, we should leave the meeting. In summary, disassociate werself and YKK from participation in any possibly illegal activity with competitors, confine wer communication to what is clearly legal and proper. Finally, immediately report any incident associated with a prohibited subject to wer management.

2.7.3 Information about other organizations

In the normal course of business, it is not unusual to acquire information about many other organizations, including competitors. Doing so is a normal business activity and is not unethical in itself. In fact, YKK quite properly gathers this kind of information for such purposes as extending credit and evaluating suppliers.

Flagrant practices such as industrial espionage, burglary, wiretapping and stealing are obviously wrong. But so is hiring someone’s employees solely to get confidential information. Improper solicitation of confidential data from a company is wrong. YKK will not tolerate any form of questionable intelligence gathering.

2.7.4 Using information about other organizations

Information about other companies should be treated with sensitivity and discretion. Such information is often about individuals. Other companies are rightly concerned about their reputations and the privacy of their people. Adverse information with no business use should not be solicited, acquired or maintained.

When using sensitive information about other companies, we should use it in the proper context and make it available only to other YKK employees with a legitimate need to know. In presenting such information, we should disclose the identity of the organization or individuals only if it is necessary. If disclosure is not necessary, we should present the information in the aggregate or by some other means.

2.7.5 Gifts and entertainment

We must not offer or make any illegal or improper payments of money, or offer or give services, property or anything else of value, in order to influence governmental action or decisions or gain preferential government treatment.

No bribes, kickbacks or other personal payments of any kind, whether of money, services, property or anything else of value, may be offered or given directly to any domestic or foreign public official or any employee, agent or representative of any domestic or foreign governmental agency or body.

We must not make any illegal or improper payments of money, services, property or anything else of value in order to gain a competitive advantage, influence a contract award, obtain or retain business or business concessions, or gain other preferential treatment by third parties.

Properly authorized business expenses which are otherwise lawful and in accordance with well-established industry practice - such as reasonable business travel and entertainment, non-cash gifts of nominal value provided openly and in accordance with established business practices, and product demonstrations or visits to YKK operations - are permitted.

Payment of openly provided ordinary sales commissions or incentives under written agreements are permitted.

If we are offered money or an inappropriate gift, or if either arrives at our home or office, tell our manager immediately. Appropriate arrangements will be made to return or dispose of what has been received, and the supplier will be reminded of YKK gift policy. It is imperative that all gifts received (even if the gifts are returned to the sender) are made known to HR Manager for recording purpose.

2.7.6 Engagement with antisocial forces

No employee should have relationship with any antisocial forces that threaten the social order and the healthy activities of companies. We resolutely and steadfastly refuse to accede to any request for contributions to such forces.


2.8.1 A productive working environment

YKK strives to provide all employees with a healthy, safe and productive work environment. This environment extends beyond physical conditions. The work climate must also be free from discrimination and harassment based on race, color, religion, sex, age, national origin, disability, veteran status, sexual orientation, or any unlawful reason. YKK will not tolerate unwelcome sexual advances, actions, comments, or any other conduct in the workplace that creates, in the judgement of management, an intimidating or otherwise offensive environment, including promises of job enhancement in exchange for sexual favors. Similarly, the use of vulgar language, jokes, derogatory statements or innuendoes directed towards an individual or group based on race, color, religion, sex, age, national origin, disability, veteran status or affiliation with a person in such a category or any other unlawful reason are unacceptable. Photographs, pictures or printed material which others might find offensive or degrading or any other remarks or conduct that encourages or permits an offensive work environment are also unacceptable in the workplace, even if other employees do not seem to object.

If we believe we have been the victim of harassment in the workplace, we should report the conduct to management. We may, as we believe appropriate under the circumstances, reports incidents of harassment directly to wer manager or the Human Resources Department. All complaints of such conduct will be investigated promptly and dealt with appropriately. YKK will not tolerate threats or acts of retaliation or retribution against employees for using these channels. Employees, who are found to have engaged in harassment or discrimination, or to have misused their positions of authority in this regard, are subject to disciplinary action, including discharge.

Some other activities are prohibited because they are clearly not conducive to a good work environment. Violent behavior, or the threat of violent behavior, will not be tolerated. The use, manufacture, dispensing, distribution, sale or possession of illegal drugs and other controlled substances, except for approved medical purposes, is prohibited on YKK premises. Employees who engage in any of these prohibited activities are subject to disciplinary action, including dismissal. Employees who are using prescribed medications that may affect their ability to work safely should inform management.

2.8.2 Respect for privacy of all employees

Access to personal information about employees is restricted internally to people with a business need to know. Personal information is released outside YKK only with employee’s approval, except to verify employment or satisfy legitimate business objectives in the course of conducting YKK affairs and authorized investigatory or legal requirements. Employees who are responsible for maintaining personal information and those who are provided access to such information must ensure that the information is not disclosed inappropriately or misused.

In relation to handling of personal information or data, the following PDPA Act 2010 compliant clauses need to be made aware that with regards to an employee’s personnel file, the following information will be regarded as personal data which will be maintained within the company relevant human resource department. This information includes but not limited to the following:

The employee’s general personal information such as name, age, sex, address, telephone number, past employment history, educational history etc. This file will be kept under lock and key by the human resource department and will only be given access to the relevant staff within human resource who may require such access for purposes of administering the company’s human resource needs such as payroll processing, manpower planning etc.

  • The employee’s direct supervisor as well as any other relevant heads of department will also be given access to such records. Access to an employee’s personnel file from anyone outside of human resource will be recorded where an access log detailing the date, time and persons viewing such information will be captured.
    The following information is regarded as ‘sensitive’ personal data’ (called a confidential personnel file):
  • The employee’s medical history
  • The employee’s disciplinary history
  • The employee’s performance appraisal scores
  • History of any confidentiality related issues such as grievances raised or whistle blowing, and
  • The employee’s financial status (where applicable).
  • This separate file will be held under the sole custody of the company human resource manager. Access to such sensitive personal data will only be granted on a need to know basis to the head of department of the employee.
In addition, all employees should be aware that personal computers, desks, fax machines, telephones and other facilities provided by YKK are business assets and their use is always subject to YKK inspection and audit. In addition, employees have personal responsibilities over Company’s assets assigned or entrusted to them in their course of work. Employees are expected to exercise personal care over usage of these assets and will be held liable for any cost of damages arising from misuse or carelessness.

Right to access and correct personal data

Subject to the exceptions provided under Malaysian law, we may request for access to, correction, update or limit the processing thereof at any time hereafter or we may utilize the procedure as mentioned in the Policy 206-05Rv1.0 Change in Personal Information.

2.9.1 Building and operating environmental management systems

We build environmental management systems, comply with the requirements of applicable environmental laws, regulations, and rules, and reduce our environmental impact through all our business activities, manufacturing, sales, and waste disposal.

2.9.2 Responding to climate change

As a response to climate change, we pursue energy conservation initiatives to reduce the amount of energy we use in business activities and reduce greenhouse gas emissions by introducing renewable energy use such as solar.

2.9.3 Resource use

As a manufacturing company, we strive to develop and sell products intended to maintain a sustainable use of resources, and to promote the efficient use of resources through new technological innovations in manufacturing. In addition, we also practice rainwater harvest.

2.9.4 Sustainable use of water

Water is an important shared community resource. As a member of local communities, we strive to optimize water uptake and drainage so that water can be used in sustainable manner.

2.9.5 Coexistence with nature

Our goal is to coexist with nature. Through proper use, storage, and treatment, we minimize the impact on the natural environment of the chemical substances we use, and conserve ecosystems through activities such as maintaining green spaces and planting trees.


2.10.1 Promoting safe and secure workplace environments

We strive to minimize all workplace risks and work to build safe and secure workplace environments. As well, we provide environments in which all employees can continue to work in good physical and mental health.

2.10.2 Raising safety awareness

We raise safety awareness through training and other means.

2.10.3 Building and operating worker health and safety management systems

We build worker health and safety management systems, comply with the requirements of applicable worker health and safety laws, regulations, and rules, and work to prevent the occurrence of workplace accidents.

2.10.4 Fire and disaster prevention measures

We implement thorough fire and disaster prevention measures, always giving first priority to human life.


2.11.1 Value creation backed by technology

In order to provide new value that meets the needs of customers and society, we engage in manufacturing in which we apply ingenuity and inventiveness to all processes, from manufacturing, sales, and after-sales service. As well, we commit ourselves to pursuing quality and safety.

2.11.2 Traceability

We forge links with business partners and work to ensure transparency and traceability throughout our supply chains.


2.12.1 Social contribution activities

We contribute to the development of regions through our business activities, and as a member of local communities, we engage in social contribution activities, such as support for international exchanges, and education and regional revitalization that makes the most of local characteristics.

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