Ethics &
Integrity

Setting High Standard

Our integrity stands as one of our paramount assets. We adhere to standards that not only comply with the applicable laws and regulations but also reflect our principles, which are centered on surpassing our clients expectations.

Business conduct and ethics

Our Code of Business Conduct and Ethics establishes fundamental guidelines to direct employee behavior. This code is reinforced by employee conduct policies and initiatives and is further bolstered through comprehensive employee training.

We maintain a strict stance against any form of illegal or unethical behavior, as outlined in our relevant policies, which encompass conflicts of interest, gifts and hospitality, anti-money laundering and counter-terrorism financing, fraud, sanctions compliance, external engagements, political contributions, and bribery and corruption. Any employee found in violation of the Code of Business Conduct and Ethics or any of our other policies may face disciplinary measures.

BBM holds representatives to the same exacting standards and conducts thorough due diligence on our business partners to assess associated risks, including the risk of corruption.

The confidence bestowed upon us by our clients must be continually earned.

BBM’s Guidelines for Anti-bribery and Corruption Compliance

BBM, along with its subsidiaries, affiliates, and joint ventures (referred to collectively as "BBM" or the Firm), as well as its employees, pledge to conduct business activities with the utmost ethical and professional standards. The Firm's reputation for integrity is esteemed as one of its most valuable assets, and adherence to anti-bribery and corruption regulations is essential to business practices. BBM maintains a strict stance against bribery and corruption: all unauthorized payments in interactions with public officials or private individuals are explicitly prohibited, as is the offering or provision of anything of value for illicit purposes.

Our Global Anti-Bribery and Corruption Policy (referred to as the "Policy") mandates that all BBM directors, officers, employees, agents, advisors, consultants, partners, and representatives conduct their activities in complete compliance with all relevant anti-corruption laws. This includes, but is not limited to, the Malaysian Anti-Corruption Commission Act 2009, as well as any other anti-corruption legislation applicable in the countries where the firm operates. BBM prohibits any transaction, including facilitation payments, that could potentially constitute a bribe or corrupt payment to or from a public official or entity, or a private individual or organization. In addition to the Policy, BBM has implemented the following to manage associated risks as well as meet regulatory principles:

  • Global Gifts and Entertainment Policy

  • Global Sponsored Visitor Policy

  • Global Third-Party Risk Management Policy

  • Private Advisory Consultants Policy

  • Direct Private Transaction Origination and Oversight Policy

  • Sourcing and Vendor Management Policy

  • Global Fraud Policy

BBM personnel are required to undergo compulsory training sessions on the Anti-Bribery and Corruption Policy and relevant regulations at least annually. These sessions involve assessments to gauge employees comprehension of the Policy, with a minimum passing score required for successful completion. Furthermore, employees participate in tailored training sessions, although not obligatory, designed to raise awareness of specific risks associated with certain business activities and regional nuances, often utilizing hypothetical scenarios for illustration.

The Anti-Bribery and Corruption Policy and associated training form the cornerstone of BBM's Global Anti-Bribery and Corruption Program (referred to as the "Program"), overseen and regularly evaluated by Compliance. An Enterprise-wide Anti-Bribery and Corruption Risk Assessment, encompassing all business sectors and geographical areas, is conducted to assess control effectiveness using a risk-based testing approach. The outcomes of these assessments drive improvements, including the implementation of governance and oversight mechanisms concerning transactions or relationships deemed to carry higher corruption risks. Additionally, the Program undergoes periodic evaluations by the Firm's auditors.

Employees are encouraged to utilize BBM's Admin to report any suspicions or actual breaches of the Policy. All reports of potential policy violations are thoroughly investigated and reported to relevant risk and governance committees, overseen by the firm's leadership. The Firm's proxy statement elaborates further on the role of our Board of Directors in risk management oversight.

For more detailed information on BBM's Business Ethics, please visit the Code of Business Conduct and Ethics.

Whistleblowing Policy & Procedure

1.Objective

The Company is firmly committed to upholding ethical, moral, and legal standards in all aspects of its business and operations. In line with this dedication, it has implemented the Whistleblowing Policy and Procedure (WBP) to provide a platform for employees, interns, unit trust consultants, contractors, vendors, suppliers, and unitholders to report any illegal, unethical, or questionable practices, or instances of improper conduct within the Company, whether ongoing or anticipated. All reports will be treated with the utmost confidentiality, and individuals making disclosures will be protected from any form of retaliation.

2. Scope of Reporting

Any irregularity and improper conduct, including but NOT limited to the following:

  1. Fraud or Dishonesty
  2. Theft or Embesslement
  3. Bribery, Corruption
  4. Abuse of Power
  5. Breach of Applicable Law and Regulations, Including Any Illegal Activities
  6. Breach of Company's Policies and Procedures (e.g. Code of Ethics, Staff Conduct and Discipline)
  7. Insider Trading
  8. Conflict of Interest
  9. Improper Use or Falsification of Management and Financial Information
  10. Misuse of Company's Property and Information
  11. Bullying, Harassment, Sexual Harassment
  12. Intimidation
  13. Gross Mismanagement or Dereliction of Duties

3. Reporting Procedure

  • To report any deviation or misconduct, whether it has already occurred or is anticipated (including potential criminal activity), a whistleblower is required to provide relevant details and send an email to [email protected].
  • The whistleblower must act in good faith and report the information honestly, without any personal ulterior.
  • This protocol firmly disallows insincere, harassing, malicious, or fabricated disclosures made for personal benefit or with personal motives. It also does not serve as a platform for addressing individual complaints or grievances.
  • Should the investigation determine that the disclosure was made with malicious intent, the whistleblower may face appropriate consequences.

4. Reporting Channel

  • Disclosure via Protected Email Address at: [email protected] All of the above are secured and protected channels accessible only by authorized personnel.

5. Protection Accorded to Whistleblower

  • The Company will ensure that the whistleblower's confidentiality is protected to the extent reasonably necessary for conducting a thorough investigation.
  • The Company will make every effort to safeguard the whistleblower from discrimination, retaliation, or harassment, in accordance with its internal policies and within its authority and jurisdiction.

6. Withdrawal of Disclosure

If the whistleblower desires to retract their disclosure, they must email [email protected], along with the reasons for withdrawal. Despite this, the Company retains the prerogative to investigate issues stemming from the initial disclosure.

7. Other Reporting Channels

In addition to reporting to the Company, a whistleblower has the option to file a report with the police, the Securities Commission (SC), the Malaysian Anti-Corruption Commission (MACC), or any other enforcement agency specified in the Whistleblower Protection Act 2010, and provide a copy of the report to the Company for internal investigation purposes.