With reference made to Ranhill’s Code of Conduct and Business Ethics (‘CCBE’), the Company has addressed its stance against bribery and corruption. Ranhill has zero tolerance towards bribery and corruption. No one shall make, offer to make payment to an establishment, a person or a group of people to secure, obtain or retain a business. The established principles on anti- bribery and corruption are:

1. Conflict of Interest

Employees are expected to make business decisions / judgements in the best interest of Ranhill and shall at all time avoid being in a situation of conflict.

The following are the overall ethical tenets:

1. 1. No employee may benefit directly or indirectly from Ranhill’s dealings with others.
   2. No employee may serve business interest that competes with Ranhill.
   3. No employee shall allow outside business or work activities interfere with their Ranhill job performance

Employees who are in a situation of conflict shall make a report in writing to their HOD as soon as possible stating the nature of details of the conflicts.

2. Gift

Soliciting and accepting gift(s) is discouraged as accepting gifts or favours from anyone with whom Ranhill does or might do business with, may place him/her or Ranhill in a compromising position. Wherever possible, expensive gifts should be declined and explained in terms of the strict Ranhill Policy to be followed.

If, under any circumstances, refusal appears impossible or would create business repercussions, then gifts on relatively rare occasions can be accepted, but their ultimate disposition should then be discussed as soon as possible with the Group Human Resource Division. In some cases, employees can avoid the conflict by donating the gift to charity or having it become Ranhill property.

3. Discount and Preferential Treatment

Employee shall not accept any discount or other preferential treatment conferred, that maybe view as an inducement to secure favoured treatment in return. In some cases, business firms extend modest discounts across the board to all employees simply to encourage sales of their product. These types of discounts may be accepted.

4. Travel and Entertainment Expenses

Consistent with the need to maintain an appropriate image, Ranhill shall pay all relevant and reasonable expenses for employees’ business trips. Trips shall not be financed by anyone with whom the employees are doing business. If an employee finds himself/herself in such a situation, he/she should be aware of the opportunities for abuse.

5. Donation

Contributing to the society is part of Ranhill values. However, there is a risk if the donation exercise is not properly managed. All donations request from outside Ranhill shall be referred to and managed by the Group Corporate Communication Department.

6. Political Contribution

No contributions of corporate funds may be made to election campaigns, political action committees or referenda unless such contributions have been approved by the President/Chief Executive’s office and all requirements for disclosure and reporting have been met. All requests for such contributions must be referred to the President/CE’s office.

Any report on the above issues, shall be send to Azmi Mahmood via email at azmee@ranhill.com.my