Planters International Berhad Employee Code of Conduct

At Planters International Berhad, we are guided by our core values of environmental stewardship, innovation, integrity and respect. Our commitment to these values is unwavering as we pioneer sustainable solutions that harmonize the natural world with cutting-edge technologies.

Ethical conduct lies at the heart of our operations. We are dedicated to upholding the highest standards of integrity, transparency and accountability in everything we do. This Employee Code of Conduct outlines the ethical principles and compliance expectations that apply to all Planters personnel.

We comply with all applicable laws, regulations and company policies in the countries where we operate. However, we view ethical behaviour as more than mere compliance - it is a fundamental responsibility to our stakeholders, communities and the environment we serve.

Each of us is accountable for our actions and decisions. We must conduct ourselves with honesty, fairness and professional responsibility in all business dealings. Our ethical reputation depends on the collective commitment and diligence of every Planters employee.

This Code provides guidance on key ethical risk areas, but it cannot address every situation. We expect all employees to exercise good judgment, seek advice when needed, and speak up if they encounter any potential violations or unethical practices.

Anti-Money Laundering (AML) Commitment Statement

Planters International Berhad is committed to maintaining the highest standards of ethical conduct and integrity in all our business activities. As part of this commitment, we have established a comprehensive Anti-Money Laundering (AML) policy to prevent, detect, and report any money laundering activities within our organization.

Key principles of our AML commitment include:

1.      Compliance with Laws and Regulations:

a.      We adhere strictly to all applicable AML laws, regulations, and guidelines, both locally and internationally.

b.      Our policies and procedures are designed to ensure compliance with relevant AML legislation and regulatory requirements.

2.      Risk-Based Approach:

a.      We implement a risk-based approach to identify, assess, and manage money laundering risks. This includes conducting thorough due diligence on customers, partners, and transactions.

3.      Know Your Customer (KYC):

a.      We conduct robust KYC procedures to verify the identity and legitimacy of our customers and partners. This helps us understand the nature and purpose of business relationships and detect any suspicious activities.

4.      Ongoing Monitoring: 

a.      We continuously monitor transactions and business relationships to detect and report any unusual or suspicious activities promptly.

b.      Regular audits and reviews are conducted to ensure the effectiveness of our AML controls and procedures.

5.      Employee Training and Awareness:

a.      We provide ongoing training and awareness programs for our employees to ensure they understand and comply with AML policies and procedures.

b.      Employees are encouraged to report any suspicious activities or potential AML breaches without fear of retaliation.

6.      Reporting and Cooperation:

a.      We are committed to reporting any suspicious activities to the relevant authorities in a timely manner.

b.      We cooperate fully with law enforcement agencies and regulatory bodies in the investigation and prosecution of money laundering activities.

Planters International Berhad expects all employees, contractors, and business partners to uphold these principles and work together to prevent money laundering and protect the integrity of our organization

Planters International Berhad Anti-Bribery and Corruption Policy

1.      Policy Statement

Planters International Berhad ("Planters") is committed to conducting business with integrity, transparency and in full compliance with all applicable anti-bribery and anti-corruption laws in the countries where we operate. This policy prohibits all forms of bribery and corruption, whether involving public/government officials or private parties.

2.      Compliance with Laws

2.1 Malaysian Anti-Corruption Laws

As a Malaysian company, Planters strictly complies with the Malaysian Anti-Corruption Commission Act 2009 ("MACC Act") and all its provisions. All Planters personnel, subsidiaries, contractors and associated persons/entities must fully comply with the MACC Act. Violations carry severe penalties including fines and imprisonment.

Sections 16-18 and 23-25 of the MACC Act prohibit:

·                 Soliciting, receiving or giving any gratification as an inducement or reward

·                 Corrupt practices involving agents or use of fictitious documents

·                 Abuse of position or criminal breach of trust

Per Section 17A, Planters commit an offense if any persons associated with the company participate in corruption. Planters has implemented adequate anti-corruption procedures mandated under Section 17A(5) to prevent such violations.

2.2 Other Applicable Laws

Planters complies with all other anti-bribery and anti-corruption laws in the jurisdictions where we operate.

3.      Prohibited Conduct

Planters employees, officers, directors, contractors and third-party representatives are prohibited from:

·        Offering, promising, giving or authorizing bribes, improper payments, kickbacks or anything of value to improperly influence any individual's actions

·        Soliciting or accepting bribes, improper payments, kickbacks or anything of value that could improperly influence decisions or actions on behalf of Planters

·        Making facilitation or "grease" payments to government officials to expedite routine actions

4.      Gifts, Hospitality and Travel

Reasonable expenditures on gifts, meals, entertainment and travel involving government officials or commercial third parties are permitted if:

·        They are for a legitimate business purpose

·        They do not improperly influence, or appear to improperly influence, a business decision

·        They are reasonable in value based on guidance, pre-approved if required, and accurately recorded

5.      Books and Records

All payments, expenditures and financial transactions must be recorded accurately in Planters' books and records to reflect their true nature and purpose. No off-book accounts may be established.

6.      Reporting Concerns

Planters provides several confidential channels for employees, contractors, suppliers and third parties to report any concerns or suspected violations related to bribery, corruption or unethical conduct without fear of retaliation:

·        Email: eva@planters.com (monitored by Directors Office)

·        Hotline: 0 16-214 3444 - Available 24/7 Anonymous reporting allowed.

·        In-Person: Reports can be made to managers, Chaiman or Corporate Affairs Representative.

What to Report:

·        Solicitation, giving or accepting bribes or improper payments

·        Requests for facilitation payments

·        Concerns about inaccurate books/records or financial irregularities

·        Conflicts of interest or failure to disclose conflicts

·        Retaliation against someone for reporting a concern

Investigation Process:

·        All reports are logged into a confidential tracking system

·        The Ethics Office conducts an initial risk assessment

·        For high-risk cases, an investigation team examines relevant documents, data and interviews

·        If allegations are substantiated, disciplinary and corrective actions are taken

·        Reporters receive status updates throughout the process

7.      Protection Against Retaliation

Planters has a zero-tolerance policy prohibiting any form of retaliation against anyone who reports a concern in good faith or cooperates with an investigation. Retaliation is grounds for disciplinary action.

8.      Awareness and Communication

This policy is communicated to all employees, contractors, suppliers and other relevant stakeholders. Regular training is provided on anti-bribery and anti-corruption laws and this policy.

9.      Policy Governance

This policy is overseen by the Directors Office, which reviews and updates it periodically. The Board Audit Committee provides oversight of anti-bribery and anti-corruption compliance.