Code of Conduct of Ethics


Purpose and Scope of the Code

The Code of Conduct & Ethics (the “Code”) provides guidance to the Board of Directors and employees (“Employees”) of Dominant Enterprise Berhad and its subsidiaries (the “Group”) on business conduct and maintaining a healthy corporate culture that engenders integrity, transparency and fairness. The Code is applicable to all employees and Directors of the Group.


This Code is not a comprehensive guide that covers every ethical situation that Employees may encounter in their course of work. For situations which are not covered by this Code or in case of any doubt, Employees shall refer to his or her Head of Department or the Company’s Head of Human Resources Department for clarification or guidance.


Conflicts of Interest

All Employees should avoid any activities or associations that may conflict with or may appear to conflict with their exercise of independent judgements in the Group’s best interests.

An Employee who has an actual or potential conflict of interest must disclose to the management the existence and nature of the actual or potential conflict of interest and all material facts known to him/her so that the management may determine whether the Employee may be involved in the matter or whether the Company may proceed with the transaction.

Types of conflict of interest may include the following:

1.     The Employee, his/her spouse and/or other immediate family members (collectively, “Immediate Family”) engaging in a business similar in nature to the  Group’s business activities;

2.     The Employee and/or his/her Immediate Family receiving a personal commission, consulting fees or any other fees arrangement or remuneration relating to or in connection with the Group’s business activities;

3.     The Employee and/or his/her Immediate Family receiving gifts or favors of substantial value from customers or suppliers of the Group; or

4.     The Employee engaging in any outside professional/other work.

Bribery and Corruption

All Employees shall not offer, give, solicit or accept any bribes in order to achieve any business or personal advantage for themselves or others or engage in any transaction that contravene any applicable anti-bribery or anti-corruption laws. Adherence to the Group’s Anti-Bribery and Corruption Policy is compulsory at all times.


Gifts and Entertainment

All Employees shall not receive nor offer directly or indirectly gifts, donations, remunerations, illegal payments or benefits unless they are nominal or reasonable under the circumstances, and are free of any intention to improperly influence business decisions.  Adherence to the Group’s Gift and Hospitality Policy is compulsory at all times.

Company Property

An Employee may be issued with the Group’s properties such as a computer, notebook, calculator, mobile phone and etc.  Every Employee is required to exercise reasonable care in handling them, and to use them only for business purposes.  Employees are responsible for the care of the Group’s properties and shall bear the repair and replacement cost of the properties if they are damaged or lost due to their negligence or wilful misconduct.


Confidential Information

All Employees shall maintain confidentiality of information belonging to the Group including the Group’s client information. The Group’s confidential and proprietary information shall not be inappropriately disclosed or used for personal gain or advantage of the employee or anyone other than the Group.

Insider Trading

Employees who are in possession of non-public price sensitive information are not allowed to trade in securities of the Group. Employees are also prohibited from disclosing such information to any third party.  Both giver and receiver of information will liable to be criminal prosecution.


Sexual Harassment

Sexual harassment by any Director, Management or Employee is unacceptable. It is the Group’s policy to provide all Employees with a working environment free from any form of sexual harassment. Any questions concerning issues of such should be directed either to the Employees’ superior or the Human Resource Department. All such reports and/or complaints shall be treated with strictest confidence.


Compliance with Laws and Regulations

All Employees shall comply with all laws, rules and regulations that govern the conduct of the Group’s business.



The Group is committed to the values of transparency, integrity, impartiality and accountability in the conduct of its business and affairs. A Whistleblowing policy has been developed to provide a structured reporting channel and guidance to all Employees and members of the public to report any improper conduct and to protect the whistleblower from retaliation, victimization, harassment or discriminatory treatment.


This Whistleblowing policy was adopted by the Board in 2017 and has been reviewed regularly by the Audit Committee with the last revision on 27 May 2021. Any revisions, amendments to the Whistleblowing policy will be communicated to all Employees.


The Whistleblowing policy is available on the Group’s website at


The Code of Conduct & Ethics was updated and adopted on 27 May 2021.