LRG Rubber Sdn Bhd

Quality is our way of life

Regional Rubber Trading Co. (Pte) Ltd
LRG Rubber Sdn Bhd

SUSTAIN­ABILITY

OUR
SUSTAIN­ABILITY
POLICIES

Our Sustainability Policies have been well established since 1996 after the launching of the Corporate Philosophy and Quality Policy.

The policies are based on the 3 key pillars of sustainability, namely Environment, Social and Governance (ESG) as below:

OUR CORPORATE PHILOSOPHY

"QUALITY IS OUR WAY OF LIFE"

OUR QUALITY POLICY

To provide quality consistency in products and services, facilitate quality enhancement in human resources, and make quality contribution with respect to social responsibilities.

To also continually review and improve on the effectiveness of our quality management system.

Quality Consistency in our Products & Services
  • Commitment to maintain conformance to standards, customers' specific requirements and other relevant compliance obligations.
  • Assurance of reliability to secure customer satisfaction
Quality Enhancement in our Human Resources
  • Upgrading our personnel through training and development
  • Building and maintaining an environment conducive to participation, personal growth and creativity
Quality Contribution in our Social responsibilities
  • Proactive approach to quality of life and of the environment
  • Sensitivity to the needs of the community and the environment in which we operate

OUR ENVIRONMENTAL POLICY

As a leading natural rubber processor in the region, we recognize our environmental responsibilities toward society and future generations.

We strike to implement an effective Environmental Management System to support and enhance the environmental performance from potential impacts of our activities, products and services in the use of products as well as products End-of-Life.

We are committed to:

  • protect environment through:
    1. prevention of pollution by adopting reduce, re-use and recycle practices where possible
    2. efficient use of  materials and  natural resources
    3. creation of environmental awareness among employees on meeting their environmental responsibilities
  • fulfill relevant environmental compliance obligations
  • continual improvement of our environmental management system to enhance environmental performance

OUR BIODIVERISTY POLICY

Economic and social development is hugely related to the use of natural resources, affecting the availability and the integrity of ecosystems and the biodiversity. We are committed to preserve a healthy ecosystem which is an essential condition for global sustainability. This includes the responsibility to protect the vulnerable ecosystems, biodiversity and protecting its natural environmental resources.

In this regard:

  1. Any business activities carried out by the company shall conform to sustainable development, taking into consideration of environmental issues, and that such activity is carried out in accordance with applicable legislative requirements,
  2. We shall influence our relevant suppliers in upholding the responsibility to protect the vulnerable ecosystem, biodiversity and protecting its natural environmental resources where applicable.

OUR SOCIAL ACCOUNTABILITY POLICY

We are committed to provide a socially accountable work environment to all employees and uphold ethical business practices by supporting and respecting employees’ rights. We shall not complicit in human rights abuses. We shall comply with applicable laws and regulations on Social Accountability.
Forced Labor
  • Shall not use forced labor in our business operations.
  • The overall terms of employment are voluntary.

Child Labor
  • Shall comply with local minimum age legislations and requirements.
  • Shall not employ child labor in our business operations.

Workplace Safety and Health
  • Shall provide a safe and healthy working environment at our workplace and a working environment respectful of their family lives.
  • Shall take adequate steps to prevent any likely accidents and occupational illness.

Environment
  • Shall comply with relevant legislations, regulations and other requirements.
  • Shall make continual improvements of environmental performance and also prevention of pollution in our activities.

Remuneration
  • Shall compensate our employees with wages and benefits that meet the legal requirements.
  • Shall not withhold pay due to disciplinary or punitive reasons.

Working Hours
  • Shall not force our employees to work more than the maximum hours that required by laws.
  • Shall comply with overtime pay requirements.

Discrimination and Harassment
  • Shall prohibit discrimination based on race, color, age, gender, sexual orientation, education, religion or disability.
  • Prohibiting of any threats or use of violence, harassment or intimidation directed towards each other

Freedom of Association
  • Shall allow employees to freely join any organization which is complied with national laws.
  • Shall also include the freedom of employees not to be forced to join a group

Labor Relations & Disciplinary Practice
  • Shall proactively promote the direct contact between employer and employees for improving the labor relations.
  • Shall at all times treat all employees with dignity, honest and respect.
  • Shall employ local employees to the greatest extent practicable and provide training with a view to improving skill levels.

Information Security
  • Shall ensure that all information hold or are responsible for is safeguarded against inappropriate disclosure and secured from any threats that will breach the confidential information of the company.
  • Shall ensure information technology users within the company to understand both their legal and ethical responsibilities concerning information, and empower them to collect, use, store and distribute it in appropriate ways.

Business Ethics
  • Shall uphold the highest standards in business ethics and integrity for the fair, honest and non-conflict of interest business practices; work against all forms of corruption, including extortion, bribery, fraud or unethical practices of any kind.
  • Shall refrain from anti-competitive practices and support in fair, free and open market.
  • Shall comply fully with all applicable money-laundering laws throughout the world.

Responsive Marketing for Dealing with Customers
  • Shall be honest and fair with our customers, competing fairly for their business; promises, gifts and any forms of corruption are strictly prohibited to be used as a way to obtain the advantages in market share.
  • Shall respect their privacy and provide them safe and quality products and services under the conditions we promise.

Respect for Stakeholders
  • Shall be transparent, respectful and fair to local populations, company owner, suppliers and other stakeholders outside our organization who may be affected by our operations.
  • Shall work collaboratively with our communities to enhance the well being of others.

In order to ensure that this policy is understood, implemented and maintained at all levels of the company and by all those working with the company, the top management has put into practice the following initiatives:
  • Displaying this policy at prominent places within the organization for easy access,
  • Providing a copy of this policy (hard or sift copy) for perusal by all personnel within the organization
  • Meeting between the company’s management staff and workers.

OUR OCCUPATIONAL SAFETY AND HEALTH POLICY

We firmly believe that promoting a positive culture and climate on health and safety in the environment we operate is fundamental to our business success and to our sustainable growth.

We are therefore committed to establish, implement and continually make improvements to our Occupational Safety and Health Management System for eliminating or minimizing risk to our employees and other parties whom may be involved.

We will undertake the following provisions for our safety and health management system:
  • Ensure safe, healthy and clean working environment
  • Prevent any likely accidents and occupational illness through effective hazard identification, risk assessment and risk control
  • Create strong safety and health awareness among the whole organization
  • Improve existing activities for total compliance of all relevant laws, regulations and code of practices
  • Conduct regular reviews and audits of all operations

OUR DRUG AND ALCOHOL ABUSE POLICY

Employees  are  our  valuable  resources  and  their  health  &  safety are  our  great  concern.  Drug  or  alcohol  abuse  will pose  a  serious  threat  to  our  employees’  health  &  safety.  Employees  abusing  alcohol  or  drugs  are  not  only  a  danger  to  themselves,  but  also  to  their  families,  colleagues  and  the  company’s  assets.  It  is,  therefore,  the  policy  of  our  company  to  prevent  and  eliminate  any  event  abuse  of  drug  and  alcohol  at  the  workplace.

We  are  fully  committed  to  undertake  adequate  and  appropriate  measures  that  will:

  • Promote  a  safe  and  healthful  working  environment  which  is  free  from  illegal  or  abusive  use  of  drugs  or  alcohol,
  • Assist  employees  who  are  suffering  from  drug  or  alcohol  related  problems  seek  for  rehabilitation  services,
  • Increase  individual  awareness  and  responsibility  on  the  prevention  and  elimination  of  drug  and  alcohol  abuse,
  • Enable  of  reviews  on  existing  policy  and  effectiveness  of  preventive  programs  relevance  to  the  illicit  drug  use  and  alcohol  abuse.

OUR VIOLATION POLICY

We are committed to provide a socially accountable work environment to all persons at the workplace by supporting, respecting and promoting environmental, labor practices, human rights and business ethics.

In respect to the commitment, we will not be tolerated should any violations of the incidents related to environmental, labor practices, human rights and business ethics where occurred in the workplace. Disciplinary action will be taken against any employee who violates the policies.

OUR ZERO TOLERANCE POLICY

We are committed to provide a socially accountable work environment to all employees and uphold ethical business practices by supporting and respecting employees’ rights.

In respect to the commitment, we will not be tolerated should any of the incidents occurred in the workplace:

  • Forced and child labor
  • Discrimination based on race, color, age, gender, sexual orientation, education, religion or disability
  • Physical abuse, harassment, mental or physical coercion and verbal abuse
  • Corruption and bribery
  • Breaching of information security
  • Money laundering
  • Fraud
  • Creating of conflict of interests

 

Disciplinary action will be taken against any employee who violates this zero tolerance policy.


OUR DIVERSITY, EQUITY AND INCLUSION POLICY

We acknowledge our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, culture, education, background, expertise, experience and other characteristics that make them unique. Understanding and managing these differences can result in creating an inclusive working environment where individual differences are valued and respected for fulfilling the responsibilities.  

We are committed to fostering, cultivating and preserving a culture of diversity, equity and inclusion basing on three key principles:

Diversity: We encourage diverse workforce which brings excellence by bringing together unique and varied perspectives that facilitate meaningful exchange, increased creativity, broadening of shared perspectives, knowledge and decision-making capacities.

Equity:  We provide fair and transparent employment practices that seek to eliminate discrimination and ensure equal opportunity across our diverse workforces.

Inclusion: We adopt inclusive recruitment measures, equitable pay and career opportunities as well as the provision of a safe, respectful and supportive working environment to our diverse workforces.

This policy will be regularly reviewed and updated to ensure its continuing suitability, adequacy and effectiveness.

 

OUR DEFORESTATION POLICY

We recognize that forests play a crucial role in climate change mitigation, providing an invaluable habitat for wildlife and supporting the livelihoods of people across the globe. We also acknowledge that forests have reduced continuously due to agriculture, logging and urbanization.

Global warming, environmental pollution, loss of biodiversity and depletion of natural resources put the earth at risk. Land rights abuse on indigenous peoples and local communities causes the loss of their homes and traditional way of living.

In view of the negative impacts exerted by deforestation, we are committed to procuring deforestation-free materials and supporting the prevention of illegal deforestation in our supply chains.

We shall:

  • Ensure all local raw rubber suppliers are registered with Malaysian Rubber Board (MRB) and possessing a valid license issued by the authority, 
  • Conduct comprehensive deforestation risk assessment on our suppliers,
  • Ensure our suppliers complying with the indigenous people and local communities’ land-use rights in sourcing the raw materials,
  • Increase the traceability and transparency for the sources of raw materials,
  • Engage and build our supplier capacity regarding land rights, human rights and environmental compliance,
  • Facilitate the inclusion of smallholders into the supply chain to support good agricultural practices,
  • Resolve all deforestation complaints and conflicts through an open, transparent and consultative process,
  • Observe all relevant deforestation laws, regulations and other compliance obligations.

OUR WHISTLEBLOWING POLICY

  1. Commitment

We are committed to high standard of transparency, accountability and ethic at the workplace. We shall practice good corporate governance and uphold integrity in all its operational activities and business dealings.

  1. Objectives

The purpose of this policy is to establish an accessible and confidential trusted reporting channel (whistleblowing channel) which may be used anonymously for internal and external parties to raise concerns in relation to real or suspected wrongdoing incidents or inadequacies of any of our Sustainability Policies.

  1. Definition

“Wrongdoing” shall include bribery and/or corruption incidents, financial transactions that may disguise corrupt payments money laundering, actual or suspected fraud, misappropriation of monies, misrepresentation, concealment of facts or information with intention to mislead, violation of laws and regulations, endangerment of personnel or public health and safety, violation of company’s policies and procedures, illegal unethical favors or privileges, criminal offences and blackmailing.

  1. Reporting in Good Faith

Personnel, business associates and all internal and external parties are to be encouraged to raise concerns and to report, in good faith, any real or suspected wrong doing incidents or inadequacies of any of our Sustainable Policies at the earliest possible stage.

  1. Protection against Retaliation and Reprisal

We note that personnel and business associates who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential wrongdoing has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

  1. Confidentiality

All complaints reported to the company are to be treated highly confidential. Information will only be disclosed on need-to-know basis. The identity of the whistleblower will not be revealed unless it is required by laws or with the permission of the whistleblower (reporting person).

  1. Reporting Channel

Any improper conduct or wrongdoing shall be reported immediately to the Integrity and Governance Unit of the Company who then will perform a preliminary assessment of the seriousness of the matter disclosed. The contact particulars of the Integrity and Governance Unit (IGU) are as follows:-

Integrity and Governance Unit (IGU)

LRG Rubber Sdn Bhd

28th Floor, Wisma Lee Rubber,

Jalan Melaka, 50100 Kuala Lumpur,

Malaysia.

Attn: Ho Han Boon

Email: hohanboon@leeselangor.com.my

Tel: +6012 7988509

Whistleblowing and reporting of concerns may be made anonymously. All whistleblowing and reporting of improper conduct in good faith and not for malicious intent will be investigated and dealt with appropriately.  However, a whistleblower is encouraged to identify himself/herself when reporting for credibility purposes and to allow an avenue for the us to follow up to ascertain the facts or to obtain further information for investigation purposes. Whistleblowers are also encouraged to attach reliable evidence to substantiate the disclosure and assist in the investigation. 

To facilitate the use of the whistleblowing or reporting channel, we have prepared a Whistleblowing Form annexed to this Whistleblowing Policy which may be used. The Whistleblowing Form may be submitted together with additional sheets for additional witnesses or supporting evidence if necessary.

Whistleblowers may make reports using the Whistleblowing Form or they may do so in any other format of letters, email or even orally. 

OUR RECRUITMENT POLICY

We are committed to apply the principles of equity, fairness and transparency to all recruitment processes. All candidates shall be communicated with this policy prior to recruitment begins.

The principles which guide us include:

  • Prohibiting discrimination based on race, color, age, gender, sexual orientation, religion or disability.
  • Not offering employment to prospective candidate in return for them or any other persons having  improperly favored the company;
  • Not offering employment to prospective candidate  to secure improper favorable treatment for the company either by reason of the candidate’s relationship with public officials or for any other reasons
  • Acquiring high performing, quality applicants who match the competencies and behavioral requirements of company.
  • Conducting recruitment and related practices with due regard that remain free from any form of favoritism, nepotism or biases.
  • Performing all related activities with due regard to privacy and confidentiality.
  • Promoting voluntary career mobility in enhancing employee career satisfaction and improving talent retention levels.
  • All recruited employees shall be paid on a fixed salary which is above the minimum wages as imposed by the laws and regulations. 
  • Priority is given to our employees to apply for open positions within the company (i.e: internal recruitment) in promoting opportunities for personal development and growth.
  • Ascertaining as far as is reasonable that it is appropriate to employ or redeploy the candidates concerned and that it is reasonable to believe that they will comply with our Anti-Bribery and Corruption Prevention Policy  and other Sustainable Policies and related policies and procedures.

OUR TRAINING AND COMMUNICATION POLICY

In consistent with our Quality Policy Statement: Quality Enhancement in our Human Resources, we recognize that a competent, motivated and well-trained employee is essential to continued company success.

It is hence our policy to upgrade our personnel through training and development. We are committed to build and maintain an environment conducive to participation, personal growth and creativity.

Training and development is intended to equip employees with the skills, knowledge and awareness to enable them to discharge their duties in a manner of competent and confident. Every manager and supervisor holds a responsibility to ensure that their team has the requisite competency. 

All measures shall be taken to ensure equal access to opportunities for training and promotion. We will endeavor to provide appropriate training to enable employees to perform their jobs efficiently and pursue career development opportunities. Training shall be given to all employees based on their training needs regardless of gender, age, disability, responsibility for dependants, belief, race, religion or ethnic origins, sexuality, pregnancy or maternity and nationality.

In particular, we will provide training and communication to our personnel and business associates covering (1) our Anti-Bribery and Corruption Prevention Policies as well as the other Sustainable Policies and related policies and procedures, (b) how to have access to our training classes and materials, (c) how to use our Reporting Channel (Whistleblowing Channel) and our Whistleblowing Policy, and (d) the consequences of any failure by personnel and business associates to comply with our Anti-Bribery and Corruption Prevention Policies as well as the other Sustainable Policies and related policies and procedures. Our training and communication will be carried out in both English and Bahasa Malaysia.

This Training Policy shall be monitored and reviewed to ensure its continued applicability and relevance to our operations.

OUR BUSINESS CONTINUITY MANAGEMENT POLICY

We are committed to:

  • safeguard the human, environmental, technological & physical resources during an incident,
  • minimize the impacts of an incident on our employees and local community,
  • deliver products whilst responding to an incident with minimum impact on our customers,
  • resume operations as quickly as possible.

OUR SUSTAINABLE PURCHASING POLICY

We recognize our responsibilities to minimize negative impacts on environmental, labor practices and human rights while upholding high ethical business practices along our supply chain.

It is our policy to:
  • Promote the purchase of sustainable resources including recycled/recyclable supplies
  • Promote goods and services that are environmentally friendly
  • Influence in upholding of the responsibility to protect the vulnerable ecosystems, biodiversity and protecting its natural environmental resources.
  • Ensure the health and safety of people at the workplace
  • Respect for the labor practices and human rights
  • Utilize the best practices in sustainable purchasing as they evolve
  • Comply with all applicable legislative requirements that govern our purchasing activity relating to environmental, labor practices, human rights and business ethics.

In accordance with our commitment o the highest standards, we also expect our suppliers to aspire to the same standards in their business operations, including but not limited to:
  • Environment
    1. Observe all the applicable environmental laws in the respective countries,
    2. Promote greater responsibility in environmental protection and pollution prevention.
  • Labor Practices and Human Rights
    1. Comply with all applicable laws and compliance obligations,
    2. Prohibit slavery and the use of forced or child labor across the supply chain,
    3. Prohibit unlawful discrimination and harassment at the workplace.
  • Business Ethics
    1. Obey all relevant local and international legislative requirements regarding ethical business practices,
    2. Zero tolerance to money laundering, fraud, bribery, corruption, creating conflict of interest and breaching of security issues.

OUR SUPPLIER POLICY

We are committed to work with our suppliers in high ethical business practices for the creation of professional and sustainable partnerships.

We expect our suppliers to:
  • Have zero-tolerance for corruption and bribery in any form and in particular, to undertake not to corruptly give, agree to give, promise or offer to any person any gratification with intent to obtain or retain business for us or to obtain or retain an advantage in the conduct of or business,
  • Be prohibited from participating or supporting fraud activities, or money laundering under any circumstances,
  • Refrain from presenting any lavish or excessive gifts, entertainment, hospitality or invitations that would create a conflict of interest to the company’s employees,
  • Refrain from presenting any lavish or excessive gifts, entertainment, hospitality or invitations to any third party when performing any services for or on our behalf,
  • Respect the protection of human rights and labor rights in the issues of remuneration, working times, child labor, forced labor, discrimination, harassment and freedom of association,
  • Respect and safeguard intellectual property rights and confidential information of our company and others in conducting business,
  • Provide a safe, healthy and well-managed working environment and prevent incidents and accidents,
  • Exercise measures to ensure socially and environmentally responsible sourcing of materials in our supply chain in preventing environmental incidents and damage,
  • Show good corporate citizenship in areas of operations, in complying with laws and regulations related to bribery and corruption, money laundering, corporate governance, occupational safety and health, human and labor rights, environmental management and taxation.

In contrast, we shall define clearly the terms of payment and make punctual payments of the purchased products and services for the sustainability of our own supply chain.  

OUR ANTI-BRIBERY AND CORRUPTION PREVENTION POLICY

We take a “zero tolerance” approach to bribery and corruption. This is an articulation of how the company views acts of bribery and corruption in relations to its business and activities that we:

prohibit bribery or corruption under any circumstances,
  • encourage raising concerns in good faith, or on the basis a reasonable belief in confidence, without fear of reprisal,
  • assign competence personnel with granted sufficient authorities and work independently to undertake the anti-bribery compliance function,
  • respond robustly and decisively to such acts.

We are committed to:
  • act professionally, fairly, honestly and with the highest level of integrity and ethics in all our business dealings and relationships wherever we operate,
  • manage the key corruption risks we face effectively,
  • satisfy the adopted anti-bribery management system requirements,
  • comply fully with all applicable laws and regulatory requirements on anti-bribery and corruption prevention,
  • improve the anti-bribery management system continually.

We will not be tolerated should any violations of the incidents related to the bribery and corruption issues. Disciplinary action will be taken against any employees who are not complying with the Anti-bribery and Corruption Prevention Policy.

OUR FACILITIES MANAGEMENT POLICY

We recognize our responsibilities in managing and maintaining an effective facility management system which leads to a safe, healthy, reliable and secure working environment to our employees as well as persons at the workplace.

We are committed to:
  1. fulfill relevant facility legislations and other compliance obligations,
  2. keep all facilities in good operating conditions,
  3. minimize the risk of major facility defects which might adversely affect the core work of the organization,
  4. prevent pollution by adopting reduce, re-use and recycle (3R) practices where possible during facility maintenance,
  5. use materials, energies and related resources efficiently for facility management,
  6. create strong awareness among employees and other parties whom maybe involved on the importance of facility management,
  7. conduct regular reviews and audits of facilities to ensure compliance,
  8. improve the effectiveness of existing facility management system continually to enhance the organization’s sustainability performance.

OUR INFORMATION SECURITY POLICY

We are committed to safeguard the confidentiality, integrity and availability of all physical, electronic information and associated assets of the company to ensure that regulatory, contractual and legal requirements are fulfilled.

We shall:

  • Ensure that all information hold or responsible for, is safeguarded against inappropriate disclosure and secured from any threats that will breach the confidential information of the company,
  • Ensure that information is only accessible to those authorized to access it,
  • Safeguard the accuracy and completeness of information,
  • Ensure the availability of appropriate contingency and data backup plans and security incident reporting,
  • Establish controls for protecting the company’s information systems against theft, abuse and other forms of harm or loss,
  • Ensure information technology users within the company to understand both their legal and ethical responsibilities concerning information, and empower them to collect, use, store and distribute it in appropriate ways,
  • Ensure the protection of personal data,
  • Dispose of information in an appropriate and secure manner when it is no longer in use,
  • Ensure compliance with the applicable regulations, legislative and other operational obligations,
  • Review this policy regularly to ensure its suitability, adequacy and completeness.

All employees shall be made aware of their responsibility in protecting the information assets of the company. Disciplinary action will be taken against any employees who are not complying with the Information Security Policy.

OUR DATA PROTECTION AND PRIVACY POLICY

General Statement

We highly value your privacy as it matters to us. This Data Protection and Privacy Policy is formulated to allow you to understand how we handle your personal information. We aim to build trust and transparency with you. To achieve the objectives, we will explain what data we collect, how we use and process it, and the steps to keep it safe.

  1. Types of Personal Data Collected

We believe in transparency and ensuring the security of your data. The personal data (hereinafter referred to as “Personal Data”) in which we may collect from you are:

General Personal Data

  1. Personal Information: Name, identification card or passport details, photograph of you, date of birth, age and other related information.
  2. Contact Information: Company name, contact address, telephone number, fax number, email information or any other way to contact you wherever relevant.
  3. Expertise and Social Information: Educational background, languages, professional skills, employment records, current occupation, qualifications, certifications, work experience, any memberships in associations or professional bodies.
  4. Payment Information: Your billing address and payment details such as bank information but only when necessary.
  5. Transaction Information: Information regarding purchases initiated by us.
  6. Perspective and opinions: Any feedback or views you shared with us.
  7. Others.

Sensitive Personal Data

The personal data that we process may include those data defined as 'sensitive personal data' under the Personal Data Protection Act 2010 with records linked to race, religion, health, personal misconduct, disciplinary action or criminal offence.

We view your sensitive data is our top priority. We only collect and process the sensitive data under specific circumstances such as:

  1. Compliance: To meet the legal requirements.
  2. Crime Prevention: When necessary to detect or prevent crimes.
  3. Legal Rights: To uphold and protect the company’s legal rights or those of relevant parties.
  4. With Your Consent: We will not release your sensitive personal data to a third party without your explicit consent unless it is necessary to protect our legitimate interests or when compelled by law.

E-Invoice Data

In conjunction with the Inland Revenue Board of Malaysia (IRBM)’s latest e-Invoicing implementation, we may collect additional data necessary for billing and transaction purposes from our suppliers, customers, and/or business partners. This may include personal information, contact details, Tax Identification Number (“TIN”), transaction details, invoice amounts, product or service descriptions and other required information.

  1. Collecting Sources of Personal Data

We may gather your Personal Data from the sources as follows:

  1. Data Provided by You: We get your information when you reach out to us through emails or phone calls, fill in details on our company’s forms or share your business card.
  2. Data We Get in Person: We may collect your Personal Data during our business interactions, seminars and conferences or any other business-related activities.
  3. Data from Commercial Transactions: In the course of performing or completing commercial transactions, we may gather additional information necessary for billing, invoicing, and fulfilling contractual obligations. This information comes from documents such as quotations, purchase orders, purchase contracts, sales orders, supplier registration form or service agreements. It includes transaction details, payment information, and other pertinent data crucial for the smooth execution of business transactions.
  1. Purposes of Processing Personal Data

We process your Personal Data securely for the purpose of:

  1. company’s business dealings and operations,
  2. contractual and legal obligations,
  3. IRBM’s e-Invoice implementation,
  4. other necessary purposes when required by laws and regulations.

We will apply and maintain appropriate measures to protect your Personal Data against accidental, unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network.

Access to Personal Data is strictly limited to authorised personnel of the company who have appropriate authorisation and a clear business need for that data.

  1. Safeguarding of Personal Data

We are committed to take all reasonable steps to ensure your personal data is kept confidential, secure and to take appropriate safeguards to prevent any unauthorized and/or unlawful processing, accidental loss, alteration, destruction or damage to your personal data.

The measures taken include but not limited to the followings:

  1. Restricting access to personal data to individuals who require access;
  2. Maintaining technology products to prevent unauthorised computer access or,
  3. Implementing other security measures as required.

It has to be stressed that no method of electronic transmission is completely secure. However, we will regularly review and enhance our information security measures to ensure the compliance.

  1. Storing of Personal Data

Your Personal Data might be stored in hard copies or on servers, either operated by us or our trusted service providers. We will retain your personal data as long as necessary to fulfil the needs for which it was collected and to comply with legal requirements.

  1. Sharing of Personal Data

We will not share your Personal Data with third parties except in circumstances where such sharing is necessary as part of our business operations.

Occasionally we use external third-party service providers for delivering services on our behalf and on our instructions as set out in a data processing agreement with the relevant service provider. We use such service providers for consultancy purposes, recruitment services, financial services, security services, IT services, communication services and integrity due diligence services. In such instances, we may share your Personal Data with such parties to the extent necessary to perform such work.

We will not knowingly disclose your Personal Data to third parties for the purposes of allowing them to market their products or services.

When required by laws, we may share your Personal Data for legal reasons but only to the extent we are required to do so.

  1. Retention of Personal Data

We will only retain your personal data so long as it is necessary to fulfil the purposes as set out in this Data Protection and Privacy Policy. 

However, we may need to retain your personal data for a longer period if it is required to:

  1. comply with our legal obligations or,
  2. respond to any disputes, claims or complaints made related to you.

Upon the expiration of retention, the personal data will be destroyed from our system accordingly.

  1. Amendments to Data Protection and Privacy Policy

We may update our Data Protection and Privacy Policy from time to time. If such updates are minor and do not have a material meaning for your rights or the way we use Personal Data, we may make such changes without posting a specific notice on our website. You are advised to review this Data Protection and Privacy Policy periodically for any changes.

  1. Data Breach Notification

We are committed to ensuring the security of your personal data. We will communicate to you if there is any personal data breach without undue delay. If you suspect or anticipate the likelihood of a data breach, please contact us using the contact details provided below.

  1. Contact Us

Should you have any queries, concerns or complaints in relation to this Data Protection and Privacy Policy or how we handle your personal data, kindly contact us accordingly.

The Sustainability Policies shall be reviewed to ensure its continued applicability and relevance to our operations. We will create transparency by communicating the sustainability details to employees, customers and all other stakeholders.

ESG

ENVIRONMENTAL

CORPORATE GOVERNANCE

CSR RECOGNITION

WHISTLE­BLOWING
CHANNEL

    Section A: Disclosure Details

    Questions



    Section B: Whistleblower Details

    Questions