FKS Multi Agro

CODE OF CONDUCT

Being Good

Being Good includes, among others, the Company have the responsibility to know and follow the applicable laws and regulations that apply to its business, gives positive impact in the communities we live and serve, commits to conduct our business in an economically, socially and environmentally – friendly. All employees must promptly report all suspected violations of the laws or Code of Conduct.

Being Responsible

The company is responsible to workplace environment, occupational safety and health and security, quality and product stewardship as well as compliance with internal controls, compliance in presenting financial reports, data storage and audits.

Being Respectful

The Company believes in the power of people and value a globally diverse and inclusive culture. Being respectful also shown by not tolerating any form of sexual harassment, discrimination, bullying or victimisation of any kind, which may take the form of verbal or non-verbal. The company also upholds human rights.

Being Honest

Be honest includes not tolerating bribery or taking bribes, complying all laws and regulations related to Anti-Monopoly, Business Competition and Anti-Money Laundering that apply globally where the Company operates.

Being Loyal

All employees are expected to avoid conflicts of interest wherever possible where our personal interests could inappropriately influence the business judgment, objectivity or loyalty in conducting assignments or business activities for the Company. In addition, employees are also expected to have a commitment to the confidential information and trade secrets owned by the Company and protect the company’s electronic resources from abuse and threat of use.

ANTI CORRUPTION POLICY

Anti-Bribery Principle

Any individual conducting business for or on behalf of FKS is strictly prohibited from offering, promising or paying a bribe to any third party, either directly or indirectly, whether in the public or private sector. Similarly, requesting or accepting a bribe from any third party is also strictly prohibited.

For these purposes, a ‘’bribe’’ means corruptly or improperly soliciting, promising, offering or accepting anything of value including gratification, preference, money, or gift to or from any individual or organization as an inducement or reward to do, or not to do, any act in relation to a transaction or any relevant function or activity to gain or retain a business advantage.

Gifts, Entertainment and Travel Principle

Offering or receiving business gifts, entertainment and travel hospitality may be customary practice in certain cultures and to decline such practice may be viewed as being disrespectful.

For purpose of this principle, a gift, entertainment or travel opportunity will be referred to as “business courtesy”. When deciding on the appropriateness of giving or receiving a business courtesy, employees should consider :

• The value of the business courtesy must not be lavish, extravagant, unreasonably costly or of material value according to gift-giving practices in the applicable industry and country;
• There is neither applicable existing legal nor regulatory restrictions;
• The suitability and frequency of the business courtesy being given or received;
• Whether an objective party would consider the business courtesy to be reasonable in cost and quantity or to be extravagant.
• Whether an objective party would consider the business courtesy to be reasonable in cost and quantity or to be extravagant.
• Any business courtesy in the form of cash, cash-equivalent (gift cards, gift certificates or vouchers), loans or personal services should never be accepted or given.

Offering Business Courtesy

Any business courtesy with estimated value of more than USD100 or its equivalent to be offered must be disclosed to the head of your business unit for approval. The BU heads are responsible for reviewing the appropriateness of business courtesies offered or provided by FKS.

Receiving Business Courtesy

Sebagai karyawan FKS, Anda tidak boleh menerima “kesopanan dalam berbisnis” dalam bentuk apapun. Jika timbul situasi dimana tidak mungkin atau tidak sopan bagi Anda untuk menolak, Anda harus melaporkan situasinya dan menerangkan detail dari “kesopanan dalam berbisnis” tersebut kepada pimpinan unit bisnis Anda. Penanganan terhadap penerimaan “kesopanan dalam berbisnis” ini adalah sbb:

• Perishable goods are to be shared amongst staff.
• Corporate gifts without resale value (e.g. gifts with company logo) or with estimated value of less than USD100 or its equivalent may be retained, as approved by the BU head.
• Business courtesy with estimated value of more than USD100 or its equivalent would have to be donated for staff lucky draw event either at Christmas, Eid Mubarak, New Year (Lunar) or staff event. Such business courtesy will be recorded in the Declaration of Gift / Business Courtesy Received Form and safe-kept with the HR dept.
• Tickets to entertainment events and free passages will be handled at the discretion of the heads of BU and HR. This will also be recorded in the Gift Registry kept by HR.

Any FKS employee or third-party working on behalf of FKS must not arrange for the business courtesy received to be re-directed to family members, relatives or friends.

Anti-Bribery Principle

We are committed to complying fully with all anti-money laundering and anti-terrorism laws throughout the world. FKS will conduct business only with reputable customers involved in legitimate business activities, with funds derived from legitimate sources.

Every employee or third-party on behalf of FKS, is responsible for protecting FKS from exploitation by money launderers in accordance to applicable laws and the provisions of this Code. FKS has due diligence procedures under its KYC Policy in place designed to combat money laundering activity.

• We do not tolerate any type of money laundering or fraudulent activity that may be a criminal offence and will investigate any suspicious activity.
• We maintain accurate and complete records of our business transactions, including all dealings with external individuals and organizations and maintain rigorous systems to prevent and detect fraud when it comes to financial and operational systems.
• We will not deal with any individual or organisation that are suspected to be involved in criminal or other unlawful behaviour where transactions appear designed or intended to disguise or conceal the identities of parties, the source of funds or property, or the scale of profits to be derived from the transaction.

Doing Business with Government Agencies and Contractors Principle

We are committed to conducting government contract and subcontract business in strict compliance with all applicable national, state, province and local laws and regulations and all contract requirements.

Business with government units/agencies throughout the world, including business through government contractors and subcontractors, is subject to complex requirements that are often stricter than those for commercial customers.

We may be required to disclose and certify detailed information about FKS and shareholders, including political contributions, lobbying, gifts to government officials, and communications with government officials. Making inaccurate and incomplete statements or certifications to government entities may result in serious legal consequences. Before entering into any government contract, or any agreement related to a government customer, FKS employees must consult our Risk or Legal Department.

When engaging or conducting business with the involvement of ‘’Government Officials’’, due care must be exercised. Government Official is broadly defined as:

When engaging or conducting business with the involvement of "Government Officials"’, due care must be exercised. Government Official is broadly defined as:

• Government employee or elected or appointed official;
• Political party;
• Candidate for political office (even if not currently in office);
• Employees of a government agency (police, tax and customs inspectors) or quasi-public agency and other companies or organizations partly or wholly owned or controlled by the government;
• An officer or employee of a national or regional government; and
• An employee of a company or other entity in which a governmental body has an interest or influence.