Act with Integrity & Ethics

• Avoid Conflict of Interest

  A conflict between an Employee’s personal interests and the interest of Sunway REIT is a conflict of interest. All Employees must avoid such conflicts and situations that may be perceived as creating a conflict of interest that may influence their judgment in the discharge of responsibilities. Directors and Employees of the Manager must not use their positions or knowledge gained directly or indirectly on the course of their duties or employment for private or personal advantage (directly or indirectly).

• Corrupt Practices are Strictly Prohibited

  Corrupt practices are operationally defined as the misuse of entrusted power for private gain. Directors and Employees of the Manager must comply strictly all provisions of the Malaysian Anti-Corruption Commission Act (MACC) 2009 accordingly.

• Acceptance and Provision of Gifts and Entertainment

  It is important not to accept or provide inappropriate gifts or entertainment as it may create conflict of interest and influence business decisions. Generally, acceptance of inexpensive “token” non-cash gifts which are occasional, customary gifts during festive or special occasions and gifts from social events attended by Directors or Employees of the Manager is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local social events and celebratory meals with clients can be appropriate aspects of promoting good business relationships, provided that they are not excessive and do not create the appearance of impropriety.

• Solicitation of Sponsorship

  The Manager discourages its Employees, whether directly or indirectly, from soliciting, accepting or agreeing to accept, from any party any form of sponsorship or gifts and hospitality from business partners. Sponsorship gifts and hospitality may be in the form of cash or cash equivalent, personal services, loans, events or meals where the business partner is absent or during periods when important business decisions are being made. Sponsorship gifts and hospitality must never influence your business decisions and must not place the Employee or the Manager under any obligation.

• Insider Trading

  An Employee should not buy or sell and should not recommend and suggest anyone else buy or sell the units of Sunway REIT either directly or indirectly when he/she is aware of insider information about Sunway REIT, for personal benefit. A violation of this policy can result in civil and criminal penalties.

• Fraud

  An employee must not engage in any forms of fraudulent acts or any dishonest conducts involving property or assets, or on the financial reporting and accounting of Sunway REIT or third party. This may not only entail sanctions but also result in criminal charges.

Comply with Laws & Regulations

• Ensure Compliance with Applicable Laws & Regulations

  The Manager and Sunway REIT will comply will all applicable laws, rules and regulations of the governments, commissions and exchanges in jurisdictions and countries within which Sunway REIT operates. Each of the Employee is responsible for taking appropriate actions to understand and comply with the laws, rules and regulations that are applicable to their positions and/or work.

Working with One Another

• Health & Safety

  The Manager strives to provide a safe, secure and conducive workplace environment. Every employee must diligently observe and comply with all Occupational Safety and Health laws and regulations of any country and the Manager’s environmental safety rules and regulations.

• Sexual Harassment & Violence

  The Manager will not tolerate and condone any form of harassment and violence. Any Employee of the Manager who believes that he/she has been subjected to harassment can lodge a report to Group Human Resources who will be responsible to review the case and consider the appropriate course of action where applicable.

• Respect, Equal and Non-Discrimination

  The Employee will be treated with respect and dignity. The Manager endeavor to provide equal opportunity to ensure that employment decision are based on merits and performance without regard to race, religion, gender, age, nationality or disability, and shall not create any form of discrimination or prejudice in the workplace.

Protect Sunway’s Assets & Intellectual Property

• Protect Sunway REIT’s Information & Assets

  The Manager values and protects all proprietary and confidential information of Sunway REIT and is committed to protecting its assets and resources. Directors and employees of the Manager are expected to exercise reasonable care to safeguard Sunway REIT’s assets to avoid loss, damage, misuse or theft. In addition, we must safeguard proprietary, confidential information, plus personally identifiable information at all time to prevent harm to Sunway REIT, our unitholders, and individuals or other third parties that have trusted us with their information.

• Confidential Information

  All Directors and Employees of the Manager must exercise caution and due care to safeguard any information of a confidential and sensitive nature relating to Sunway REIT which is acquired in the course of their employment, and are strictly prohibited to disclose to any party, unless the disclosure is duly authorised or legally mandated. In the event that a Director or an Employee of the Manager know of material information affecting Sunway REIT which has not yet been publicly released, the material information must be held in the strictest confidence by the Director or Employee of the Manager involved until it is publicly released.

• Records Management & Control

  All books, records and accounts must be controlled and maintained so that they are prepared timely and conform to generally accepted and applicable accounting principles and to all applicable laws and regulations.

Ensure Financial and Non-Financial Integrity & Controllership

• Maintain Books & Records

  The Manager is responsible for ensuring that the Manager and Sunway REIT’s books and records are recorded accurately, fairly and reasonably reflect the substance of transactions. They must comply with company accounting policies and internal control requirements.

  Purposely misrepresenting information or activities on the Manager and Sunway REIT’s documents and reports may be considered falsification of documentation, which is a serious offence. The Manager reserves the right to report any act of misrepresentation suspected of being criminal in nature to the police or other relevant authorities.

• Comply with Internal Controls & Procedures

  Maintain and adhere to sound internal controls and procedures to ensure critical risks are managed to the best of ability and that financial and operational information accurately reflects all business transactions timely and unbiased, financial forecasts and assessments are genuine and assets are safeguarded.

Environment

• Sustainable Development

  The Manager strives to achieve sustainable development by focusing on safeguarding people’s health, operating the business responsibly, protecting the environment, and fostering good relationships with the communities in which the Manager operates.