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Code of Conduct

Code of Conduct and Ethics

Green Ocean Corporation Berhad and its subsidiaries (“the Company”) is committed to promoting a high standard of ethics and business conduct; and providing a safe and conducive working environment for all, including employees, customers and visitors. This Code has been developed with the hope that all persons can contribute to achieve these goals in a concerted effort and effective manner.

If you are confronted by or uncertain about any legal or ethical issue, then speak to your manager or any senior officer of the Company.

It is the Company’s policy to comply with all laws and regulations, particularly those that apply to the areas in which we do business and to conduct all business activities ethically.

Accordingly, you must strive to increase your awareness of the law that affects the business and your specific areas of responsibilities.

At work we may have access to a wide range of information, including confidential information about the Company or parties that we are dealing with. We have an obligation to the owners to maintain the information in strict confidence.

Every effort must be made to prevent the unauthorised use or disclosure, whether accidental or intentional, of information obtained through your employment or association with the Company. Such information may include employee information, information belonging to the Company’s customers, etc. If you are aware of a breach of this policy or if you are unsure about the way certain information should be handled, contact your manager.

At work, a situation may occur where our work responsibilities clash or potentially clash with interest we may have outside of work.

You must avoid situations, whether they are personal investment, associations, or relationships that could compromise your loyalty or ability to perform the duties and responsibilities associated with your employment. You must also not allow bias, conflict of interest or undue influence of others to override your professional or business judgements. If you are or find yourself in a situation where there is or may be potential for a conflict to arise, you should discuss the issue with your manager.

All information and records received or created in relation to the business of the Company remain the property of the Company. You are responsible for management of information and records in your control. You cannot copy or remove such information or records when you leave the Company. If you are aware of an incidence where this has taken or could take place, contact your manager.

All employees or representatives must not accept or pay bribes in relation to any business conducted in any part of the world. This type of conduct in not only against the Company’s policy, it is illegal.

You have a responsibility to report any suspicion of bribery or corruption.

The Company prohibits:

  • The use, sale, transfer or possession of drugs, or controlled substances on site, and
  • Employees, contractors, representatives of the Company or visitors being in our premises or using our vehicles while under the influence of drugs, alcohol or controlled substances.

Alcohol may be stored in confined site but only consumed at authorised functions.

Any person found to be in breach of this policy may face serious disciplinary action. If this is an issue that affects you or your work environment or any other person at your site, promptly bring this to the attention of your manager.

Access to the internet and e-mail is provided as a business tool to assist you in your work. You are expected to manage the use of these tools in a professional manner following the same standard of conduct as would be expected in normal business. Taking advantage of this right through the inappropriate use of the internet or e-mail is a serious breach of policy and could attract disciplinary action including summary dismissal.

If you are aware of a breach of this policy, contact your manager.

Sustainability is an integral part of the Company’s core business strategy. The Company is committed to managing and developing its business in an environmentally, responsible manner, with the objective of sustaining the environment for current and future generations. Our policy requires employees to minimise the actual and potential effects of business activities on the environment and a framework that ensures business environment objectives are achieved. In particular, the Company will:

  1. Responsibly source and manage all materials and resources used in an efficient manner;
  2. Invest in human resource to equip them with the right skills to adapt and thrive in this rapid changing world;
  3. Support the communities in which we operate and those impacted upon by our activities;
  4. Ensure the health and safety of all those who work with us, and those that can be affected by our activities;
  5. Comply with environmental rules and regulations, and
  6. Conduct our business lawfully and in an honest, professional and ethical manner.


The Company’s employment policy is designed to ensure fair employment practices and to extend equal employment opportunities to all individuals working in the Company. This policy applies also to all of the people that we deal with, each and every day including, for example, our work colleagues, our customers, and our suppliers. The Company is committed to ensuring that all employees and people who do business with the Company enjoy a workplace and work relationships free from discrimination, harassment and victimisation. Discrimination, harassment or victimisation on the ground of age, colour, disability, employment status, ethnic or national origin, family status, political opinion, race, religious or ethnic belief, sex or sexual orientation is against the law and will not be tolerated.

If you belief that you are or have been subject to any such conduct, you should notify your manager.

When doing business with customers, suppliers or any member of the public, it is essential that all statements that we make about the products or services we provide and the contractual relationships we are entering into are accurate and truthful and that we act honestly and with respect. It is against the law to:

  • Mislead or make false representations to any person verbally, in writing or through advertising, and
  • Engage in behaviour that may be seen to bring discredit to the Company.

In meetings or at other events where representatives from competing business are present, never enter into any discussions on any aspect of price including past, present or future prices, discounts or credit arrangements. If you are unsure whether statements you are about to make are absolutely correct or if you are in doubt about what you can or cannot discuss with competitors, speak to your manager.

On occasions, employees can be invited to functions or given gifts in appreciation or acknowledgement of a successful business partnership. However, no employee or member of their immediate family may accept gifts, entertainment or other favours in connection with the Company business where such acceptance could in any way influence a business decision. Before accepting any gifts, you should first obtain your manager’s approval. If you suspect a breach of this policy has occurred, contact your manger.

Any gift given is deemed to be given to the Company and must be disclosed because a gift often creates obligations – the Company must usually reciprocate in some way. The Company will deal with the gift as it wishes.

The Company is committed to the health and safety of all employees, contractors, visitors and the general public and to elimination of work-related illnesses and injuries. All employees, contractors and visitors to our sites are required to observe and practice safe work methods. Any unsafe conditions, work processes or equipment must be promptly reported to your manager.

At work, we may sometimes access to information that may be “sensitive”. Such sensitive information about our client if made public may have an impact on the value or price of the securities.

You may not trade any shares in any listed company if you are an “information insider” for the purpose of the Securities Industry Act, 1983. You may be an “information insider” if you:

  • Possess information that is generally not available which on becoming generally available a reasonable person would expect it to have a material effect on the value or price of the securities
  • Know or ought reasonably to know that the information is not generally available

Information that would influence a reasonable person who invests in securities in deciding whether to acquire or dispose of the securities is considered information that has a material effect on the value or price of the securities.

If you are unsure about what you can or cannot do in relation to shares in the company. Speak to your manager or any of the partners of the firm.

There are privacy laws in place providing protection against the unauthorised use of personal information about individuals such as our customers, suppliers and other employees. In collecting personal information, there are certain requirements that you must comply with, for example:

  • In most circumstances, we are not entitled to use or disclose any personal information about another person unless we have been authorised to by the person concerned, and
  • We are under an obligation to keep all personnel information we have up to date.

Theft and fraudulent activities are not only dishonest, but also illegal. The penalties for individuals can be quite severe, including termination of employment. There are a number of various types of activities, each of which may constitute theft and/or fraud. Examples of such are:

  • Taking products, services or other property of the firm for personal use
  • Submitting incorrect expense claims
  • Selling or otherwise disclosing information that belongs to the firm

You have a responsibility to report any suspicion of theft or fraud. Failure to do so means running the risk of aiding and abetting the person carrying out the illegal act.

The following are acts that are considered unacceptable. Any employee found engaging in any of these activities is subject to disciplinary action which may include warning, reprimand, suspension or dismissal.

  • Being absent from work without valid reason
  • Wilfully damaging, destroying or stealing property belonging to the Company or other employees
  • Fighting or engaging in horseplay or other disorderly conduct
  • Refusing or failing to carry out the reasonable instructions of a supervisor
  • Ignoring work duties or wasting time during working hours
  • Intentionally giving false or untrue statement in the performance of duty
  • Using threatening or abusive language towards a fellow employee
  • Wilfully or habitually violating health and safety regulations, like smoking outside the permitted areas in the office.


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