CODE OF CONDUCT AND ETHICS
1. PURPOSE
The guidelines provide guidance and set common ethical standards to promote consistency in behavior across all levels of employment.
AIMS PAY Sdn Bhd (“AIMS PAY”) being a responsible corporate citizen is strongly committed to the highest standard of conduct in all its business dealings and its relationships with its Employees, and customers.
This Code of Business Conduct and Ethics guidelines applies to everyone. This guideline helps everyone to focus on areas of ethical business conduct, provides guidance in recognising and dealing with ethical issues and provides mechanisms to report unethical conduct without fear of retribution.
2. WORK ENVIRONMENT & HUMAN RIGHTS
AIMS PAY respect everyone as individuals and treat them with dignity. AIMS PAY embraces individual differences in a spirit of inclusiveness that welcomes all people and seeks to provide them with the opportunity to unleash their potential. By treating each other with respect, dignity, courtesy and fairness, AIMS PAY can continue to succeed through effective teamwork and collaboration.
2.1 Equal Opportunity and Non-Discrimination
2.1.1 AIMS PAY provides equal opportunities to all and endeavours to ensure that employment-related decisions are based on relevant qualifications, merit, performance and other job-related factors and in compliance with all applicable laws and regulations.
2.1.2 Any discrimination based on gender, race, disability, nationality, religion, age or sexual orientation are prohibited unless specific laws or regulations expressively provide for selection according to specific criteria.
2.2 Harassment and Violence
Any types of harassment and violence will not be tolerated. These actions or behaviours include derogatory comments based on gender, racial or ethnic characteristics, and unwelcomed sexual advances, spreading of malicious rumours or use of emails, voicemail and other forms of communication channels to transmit derogatory or discriminatory material. All Employees of AIMS PAY are required to comply with all anti-harassment laws in the locations where they work.
2.3 Illegal Substances
AIMS PAY strictly prohibits the use or transfer of illegal drugs or other illegal substances in the workplace.
2.4 Criminal Activities
You must not engage or become involved in any behaviour or activities that may be categorised as subversive or commit any wrongdoing, criminal or otherwise that is punishable under the laws of any country. If you are found guilty by a court of law or found to be involved in subversive activities or commit a criminal offence, you will be dealt with in accordance with AIMS PAY’s relevant policies and procedures.
2.5 Environment, Occupational Safety and Health
2.5.1 AIMS PAY strives to remove or reduce the risks to health, provide safety and welfare of all Employees, contractors/ suppliers and visitors and anyone else who may be affected by our business operations and ensure all work or activities are done safely.
2.5.2 AIMS PAY is also responsible in ensuring compliance with applicable laws, contractual regulations and all applicable requirements in order to prevent the workplace accidents in violation of rules on the protection of health and safety at work by eliminating hazards and reduce Quality, Safety, Health and Environment risk.
2.6 Favourable Working Conditions
2.6.1 AIMS PAY respect the rights of our Employees, our workers in our operations and our communities through our commitments by ensuring decent living and working conditions for all our Employees. We strive to provide a fair wage and access to basic needs for all our Employees and workers in our operations.
2.7 Personal Data Protection
2.7.1 AIMS PAY respects the privacy and confidentiality of its Employees, Directors, Counterparties, Business Partners and customers' personal data. Personal data should be kept private and protected, unless access is granted for legitimate business purposes.
2.7.2 If you have access to such data, you are required to comply with the applicable laws, such as Personal Data Protection Act, and also AIMS PAY's policies. Appropriate measures must be taken if you are dealing with personal data in terms of collection, processing, disclosure, security, storage and retention.
3. DEALING WITH CONFLICTS OF INTERESTS
All Directors and Employees are expected to make business decisions in the best interests of AIMS PAY.
3.1 General Guidance
3.1.1 A conflict of interest arises when you have a personal interest that could be seen to have the potential to interfere with your objectivity in performing duties or exercising judgement on behalf of AIMS PAY. You should avoid conflicts of interests.
3.1.2 You must not use your position, official working hours, AIMS PAY resources and assets for personal gain or for the advantage of those you are associated with.
3.1.3 If you find yourself in a situation of conflict whether actual or potential, speak to your head of department so that it could be managed properly. Such situation must be reported in writing as soon as practicable stating the facts, nature and extent of the conflict.
3.1.4 Report to your respective head of subsidiary, if you are an Employee at the subsidiary.
3.1.5 Report to your head of department if you are an Employee of AIMS PAY.
3.2 Reporting a Conflict of Interest
3.2.1 Employee who is in a situation of actual or potential conflict must complete the conflict-of-interest disclosure form as soon as the situation arises. The completed form shall be submitted to the respective head of department for approval. The head of department shall consult with the relevant party as prescribed in the form to facilitate deliberation, depending on the nature of the conflict. If you are uncertain on any matter relating to the disclosure, you can seek advice from the Human Resource Development Department or LCD.
3.2.2 The respective head of department shall then take such action as is considered necessary to safeguard the interests of AIMS PAY and/ or provide dispensation under allowable circumstances. Where the conflict involves an award of contract or proposed contract with AIMS PAY, the terms of the contract must be deliberated and decided independently e.g. through an independent tender committee if the approval is via a tender committee. You are also to refrain from participating in any of the tender process.
3.2.3 Director must disclose the nature and extent of any conflict of interests to the respective board, and if required, the prior approval of board/ shareholders must be sought, in accordance with applicable laws, regulations and in accordance with AIMS PAY’s policies.
3.3 Dealings with Suppliers, Customers, Agents and Competitors
3.3.1 Any Director or Employee or their family members must not have:
3.3.1.1 Any financial interest in a supplier, customer, agent or competitor of AIMS PAY, except that in the case of a public listed company whereby an interest of less than 10% in the equity will be disregarded; and
3.3.1.2 Any business dealings or contractual arrangements with any AIMS PAY of companies. This excludes staff purchases for personal consumption, or purchases which are on no more favourable terms than those offered to the public.
3.3.2 In the case of payments by AIMS PAY of companies to officially appointed selling agents, the buyer should have knowledge of the normal commercial practice that commission is payable to the agents, and consequently specific approval from the buyer is not required.
3.3.3 With the exception of the above instances, Employees of AIMS PAY of companies are prohibited from receiving commissions from Counterparties, Business Partners and competitors of AIMS PAY.
3.4 Outside Employment and Activities Outside AIMS PAY
3.4.1 As a full-time Employee, you must not take up employment outside AIMS PAY or engage in any outside business/ service which may be in competition with AIMS PAY or give rise to actual or perceived or potential conflict of interests with your duties in AIMS PAY.
3.4.2 Unless written approval is obtained as per item 6.2, you are not allowed to be a member of the government, quasi-government or statutory bodies or become office bearers, council member, committee member of trade or professional associations. This restriction does not apply to social or community-related clubs and associations.
3.5 Family Members and Close Personal Relationships
3.5.1 A Director or Employee should not hire, recommend hiring, exert influence over hiring decisions, supervise, affect terms and conditions of employment or influence the management of any family members engaged by AIMS PAY. Family members of Directors or Employees may be hired as Employees or consultants only if the appointment is based on qualification, performance, skills and experience, and in accordance with AIMS PAY’s hiring policies and procedures.
3.5.2 A Director or an Employee must also disclose business activities in AIMS PAY which involve family members and refrain from any related decision-making process.
3.5.3 Any substantial interest held by the Director’s or Employee’s family members in a competing company or other related companies must be declared.
4. GIFTS, ENTERTAINMENT AND TRAVEL
4.1 GIFTS, ENTERTAINMENT AND TRAVEL
4.1.1 AIMS PAY prohibits the use of improper gifts, entertainment and travel to influence business decisions. You must comply with all applicable policies, procedures, laws and regulations related to the use of gifts, entertainment and travel in all countries in which AIMS PAY operates.
4.1.2 It is acknowledged that the practice of business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. Gifts of more than nominal value, frequent gifts or entertainment, or entertainment that is more than a routine social amenity can appear to be an attempt to influence you or the other party. The intention behind the gift should always be considered, so that it does not create an appearance of bad faith and impropriety and should not be misunderstood by others to be a bribe.
4.2 Gifts
4.2.1 You or your family members must not solicit any gifts from Counterparties or Business Partners directly or indirectly. You or your family members are also discouraged from accepting gifts from these parties. Occasional acceptance of gifts is allowed to promote good business relationships.
4.2.2 Similarly, you may offer gifts to promote good business relationships. However, you must be sensitive to the recipient organisation’s gifts receiving policy.
4.2.3 You or your family members may accept or offer the gifts subject to the criteria and approvals set out in AIMS PAY’s established procedures.
4.2.4 You must never accept or offer, with or without approval, gifts in the form of cash or cash equivalents, personal services or those otherwise that may put yourself in a position of conflict, influence your business decision or was otherwise intended or given with the expectation of gaining any advantage, or which may adversely affect AIMS PAY’s reputation.
4.3 Entertainment
4.3.1 You and your family members must not solicit any form of entertainment from Counterparties or Business Partners directly or indirectly. You may accept invitations to social events or entertainment within reason according to the scope of your work provided these events or entertainment are not lavish or become a regular feature that may influence business decision making process.
4.3.2 You may also offer modest entertainment that is legal and reasonable within the scope of your work. When offering entertainment, you must be sensitive to the recipient organisation’s entertainment receiving policy. You must consult and obtain prior approval from the MD/GCEO. As for Director, you must consult the board Chairman.
4.3.3 You must not accept, engage or offer any entertainment that is indecent, sexually oriented or that otherwise might put yourself in a position of conflict or adversely affect AIMS PAY’s reputation.
4.4 Travel
4.4.1 You may accept lodging and other expenses (e.g. food, transportation) provided by Counterparties, Business Partners or other stakeholders within the host country if the trip is for business purposes and prior approval in accordance with established procedures has been obtained. The cost of travelling to the host country must be borne by AIMS PAY.
4.4.2 Unless prohibited by law or the policy of the recipient organisation, AIMS PAY may bear the costs of transportation and lodging for Counterparties, Business Partners or other stakeholders in connection with a visit to AIMS PAY’s facility. The visit must be for a legitimate business purpose e.g. on-site examination of equipment, contract negotiations or training. Prior approval in accordance with established procedures must be obtained.
5. ANTI-BRIBERY AND CORRUPTION
5.1 AIMS PAY takes a zero-tolerance approach towards bribery and corruption, and is committed to behaving professionally, fairly and with integrity in all our business dealings and relationships wherever AIMS PAY operates and implementing and enforcing effective systems to counter bribery and corruption.
5.2 AIMS PAY intends to fulfil the requirements set forth in the Guidelines on Adequate Procedures pursuant to subsection (5) of section 17A of the Malaysian Anti-Corruption Commission Act 2009 (Act 694) (MACC Act 2009), as stated in the Malaysian Anti-Corruption Commission (Amendment) Act 2018 (MACC Amendment Act 2018)
5.3 You must comply with all applicable anti-bribery and corruption laws and regulations and treaties in all countries in which AIMS PAY operates. You must also comply with the Company Anti-Bribery and Corruption Policy.
5.4 You must not directly or indirectly involve in any corrupt conduct, which include but not limited to the abuse of position/ authority and falsification of documents.
5.5 You must not influence others or be influenced, either directly or indirectly, by paying or receiving bribes or kickbacks or any other measures that are deemed unethical or will tarnish AIMS PAY’s reputation.
5.6 You must not accept a benefit from or provide a benefit to a third party by reason only of him/her being a director or employee or him/her doing something or refraining from doing anything as a director or employee unless he is permitted to do so by the company’s constitution, and it is not contrary to any written law.
5.7 You will not suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes even if such refusal may result in the company losing its business or not meeting the targets.
5.8 All Counterparties (when representing AIMS PAY of companies) are under a duty not to promise, offer or give any improper advantage on behalf of AIMS PAY. Directors and Employees must endeavour to ensure that these Counterparties do not promise, offer or give any such improper advantage on behalf of AIMS PAY.
6. DONATIONS AND SPONSORSHIPS
6.1 All sponsorships and donations shall not be used as a subterfuge for bribery. AIMS PAY needs to be certain that donations to charities or beneficiaries are not disguised illegal payments to government officials and must ensure that the charity does not act as a conduit to fund illegal activities in violation of anti-money laundering, anti- terrorism and other applicable laws.
6.2 In accordance with AIMS PAY’s commitment to contribute to the community coupled with its values of integrity and transparency, all sponsorships and donations must comply with the following:
6.2.1 ensure such contributions are allowed by applicable laws;
6.2.2 obtain all the necessary internal authorisations;
6.2.3 be made to well established entities having an adequate organisational structure to guarantee proper administration of the funds;
6.2.4 be accurately stated in AIMS PAY’s accounting books and records; and
6.2.5 not to be used as a means to cover up an undue payment or bribery;
6.3 You should also avoid situations where conflicts of interests could arise from making donations or sponsorships.
6.4 The giving of charitable donations or the payment of expenses for, or on behalf of, public officials or a public entity is governed by a complicated array of regulations, which vary from jurisdiction to jurisdiction. Before making any expenditure for, or on behalf of, public officials or public entity you must consult LCD for consultation prior to getting necessary approval. Donations and sponsorships should be made transparently and recorded.
7. Disclosure of Information
All business dealings shall be transparently performed and accurately reflected on the AIMS PAY’s business books and records. Information regarding labor, health and safety, environmental practices, business activities, structure, financial situation, and performance shall be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
8. Fair Business Advertising and Competition
Standards of fair business, advertising, and competition shall be upheld.
Rev 1.0 (18 Aug 2024)
The guidelines provide guidance and set common ethical standards to promote consistency in behavior across all levels of employment.
AIMS PAY Sdn Bhd (“AIMS PAY”) being a responsible corporate citizen is strongly committed to the highest standard of conduct in all its business dealings and its relationships with its Employees, and customers.
This Code of Business Conduct and Ethics guidelines applies to everyone. This guideline helps everyone to focus on areas of ethical business conduct, provides guidance in recognising and dealing with ethical issues and provides mechanisms to report unethical conduct without fear of retribution.
2. WORK ENVIRONMENT & HUMAN RIGHTS
AIMS PAY respect everyone as individuals and treat them with dignity. AIMS PAY embraces individual differences in a spirit of inclusiveness that welcomes all people and seeks to provide them with the opportunity to unleash their potential. By treating each other with respect, dignity, courtesy and fairness, AIMS PAY can continue to succeed through effective teamwork and collaboration.
2.1 Equal Opportunity and Non-Discrimination
2.1.1 AIMS PAY provides equal opportunities to all and endeavours to ensure that employment-related decisions are based on relevant qualifications, merit, performance and other job-related factors and in compliance with all applicable laws and regulations.
2.1.2 Any discrimination based on gender, race, disability, nationality, religion, age or sexual orientation are prohibited unless specific laws or regulations expressively provide for selection according to specific criteria.
2.2 Harassment and Violence
Any types of harassment and violence will not be tolerated. These actions or behaviours include derogatory comments based on gender, racial or ethnic characteristics, and unwelcomed sexual advances, spreading of malicious rumours or use of emails, voicemail and other forms of communication channels to transmit derogatory or discriminatory material. All Employees of AIMS PAY are required to comply with all anti-harassment laws in the locations where they work.
2.3 Illegal Substances
AIMS PAY strictly prohibits the use or transfer of illegal drugs or other illegal substances in the workplace.
2.4 Criminal Activities
You must not engage or become involved in any behaviour or activities that may be categorised as subversive or commit any wrongdoing, criminal or otherwise that is punishable under the laws of any country. If you are found guilty by a court of law or found to be involved in subversive activities or commit a criminal offence, you will be dealt with in accordance with AIMS PAY’s relevant policies and procedures.
2.5 Environment, Occupational Safety and Health
2.5.1 AIMS PAY strives to remove or reduce the risks to health, provide safety and welfare of all Employees, contractors/ suppliers and visitors and anyone else who may be affected by our business operations and ensure all work or activities are done safely.
2.5.2 AIMS PAY is also responsible in ensuring compliance with applicable laws, contractual regulations and all applicable requirements in order to prevent the workplace accidents in violation of rules on the protection of health and safety at work by eliminating hazards and reduce Quality, Safety, Health and Environment risk.
2.6 Favourable Working Conditions
2.6.1 AIMS PAY respect the rights of our Employees, our workers in our operations and our communities through our commitments by ensuring decent living and working conditions for all our Employees. We strive to provide a fair wage and access to basic needs for all our Employees and workers in our operations.
2.7 Personal Data Protection
2.7.1 AIMS PAY respects the privacy and confidentiality of its Employees, Directors, Counterparties, Business Partners and customers' personal data. Personal data should be kept private and protected, unless access is granted for legitimate business purposes.
2.7.2 If you have access to such data, you are required to comply with the applicable laws, such as Personal Data Protection Act, and also AIMS PAY's policies. Appropriate measures must be taken if you are dealing with personal data in terms of collection, processing, disclosure, security, storage and retention.
3. DEALING WITH CONFLICTS OF INTERESTS
All Directors and Employees are expected to make business decisions in the best interests of AIMS PAY.
3.1 General Guidance
3.1.1 A conflict of interest arises when you have a personal interest that could be seen to have the potential to interfere with your objectivity in performing duties or exercising judgement on behalf of AIMS PAY. You should avoid conflicts of interests.
3.1.2 You must not use your position, official working hours, AIMS PAY resources and assets for personal gain or for the advantage of those you are associated with.
3.1.3 If you find yourself in a situation of conflict whether actual or potential, speak to your head of department so that it could be managed properly. Such situation must be reported in writing as soon as practicable stating the facts, nature and extent of the conflict.
3.1.4 Report to your respective head of subsidiary, if you are an Employee at the subsidiary.
3.1.5 Report to your head of department if you are an Employee of AIMS PAY.
3.2 Reporting a Conflict of Interest
3.2.1 Employee who is in a situation of actual or potential conflict must complete the conflict-of-interest disclosure form as soon as the situation arises. The completed form shall be submitted to the respective head of department for approval. The head of department shall consult with the relevant party as prescribed in the form to facilitate deliberation, depending on the nature of the conflict. If you are uncertain on any matter relating to the disclosure, you can seek advice from the Human Resource Development Department or LCD.
3.2.2 The respective head of department shall then take such action as is considered necessary to safeguard the interests of AIMS PAY and/ or provide dispensation under allowable circumstances. Where the conflict involves an award of contract or proposed contract with AIMS PAY, the terms of the contract must be deliberated and decided independently e.g. through an independent tender committee if the approval is via a tender committee. You are also to refrain from participating in any of the tender process.
3.2.3 Director must disclose the nature and extent of any conflict of interests to the respective board, and if required, the prior approval of board/ shareholders must be sought, in accordance with applicable laws, regulations and in accordance with AIMS PAY’s policies.
3.3 Dealings with Suppliers, Customers, Agents and Competitors
3.3.1 Any Director or Employee or their family members must not have:
3.3.1.1 Any financial interest in a supplier, customer, agent or competitor of AIMS PAY, except that in the case of a public listed company whereby an interest of less than 10% in the equity will be disregarded; and
3.3.1.2 Any business dealings or contractual arrangements with any AIMS PAY of companies. This excludes staff purchases for personal consumption, or purchases which are on no more favourable terms than those offered to the public.
3.3.2 In the case of payments by AIMS PAY of companies to officially appointed selling agents, the buyer should have knowledge of the normal commercial practice that commission is payable to the agents, and consequently specific approval from the buyer is not required.
3.3.3 With the exception of the above instances, Employees of AIMS PAY of companies are prohibited from receiving commissions from Counterparties, Business Partners and competitors of AIMS PAY.
3.4 Outside Employment and Activities Outside AIMS PAY
3.4.1 As a full-time Employee, you must not take up employment outside AIMS PAY or engage in any outside business/ service which may be in competition with AIMS PAY or give rise to actual or perceived or potential conflict of interests with your duties in AIMS PAY.
3.4.2 Unless written approval is obtained as per item 6.2, you are not allowed to be a member of the government, quasi-government or statutory bodies or become office bearers, council member, committee member of trade or professional associations. This restriction does not apply to social or community-related clubs and associations.
3.5 Family Members and Close Personal Relationships
3.5.1 A Director or Employee should not hire, recommend hiring, exert influence over hiring decisions, supervise, affect terms and conditions of employment or influence the management of any family members engaged by AIMS PAY. Family members of Directors or Employees may be hired as Employees or consultants only if the appointment is based on qualification, performance, skills and experience, and in accordance with AIMS PAY’s hiring policies and procedures.
3.5.2 A Director or an Employee must also disclose business activities in AIMS PAY which involve family members and refrain from any related decision-making process.
3.5.3 Any substantial interest held by the Director’s or Employee’s family members in a competing company or other related companies must be declared.
4. GIFTS, ENTERTAINMENT AND TRAVEL
4.1 GIFTS, ENTERTAINMENT AND TRAVEL
4.1.1 AIMS PAY prohibits the use of improper gifts, entertainment and travel to influence business decisions. You must comply with all applicable policies, procedures, laws and regulations related to the use of gifts, entertainment and travel in all countries in which AIMS PAY operates.
4.1.2 It is acknowledged that the practice of business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. Gifts of more than nominal value, frequent gifts or entertainment, or entertainment that is more than a routine social amenity can appear to be an attempt to influence you or the other party. The intention behind the gift should always be considered, so that it does not create an appearance of bad faith and impropriety and should not be misunderstood by others to be a bribe.
4.2 Gifts
4.2.1 You or your family members must not solicit any gifts from Counterparties or Business Partners directly or indirectly. You or your family members are also discouraged from accepting gifts from these parties. Occasional acceptance of gifts is allowed to promote good business relationships.
4.2.2 Similarly, you may offer gifts to promote good business relationships. However, you must be sensitive to the recipient organisation’s gifts receiving policy.
4.2.3 You or your family members may accept or offer the gifts subject to the criteria and approvals set out in AIMS PAY’s established procedures.
4.2.4 You must never accept or offer, with or without approval, gifts in the form of cash or cash equivalents, personal services or those otherwise that may put yourself in a position of conflict, influence your business decision or was otherwise intended or given with the expectation of gaining any advantage, or which may adversely affect AIMS PAY’s reputation.
4.3 Entertainment
4.3.1 You and your family members must not solicit any form of entertainment from Counterparties or Business Partners directly or indirectly. You may accept invitations to social events or entertainment within reason according to the scope of your work provided these events or entertainment are not lavish or become a regular feature that may influence business decision making process.
4.3.2 You may also offer modest entertainment that is legal and reasonable within the scope of your work. When offering entertainment, you must be sensitive to the recipient organisation’s entertainment receiving policy. You must consult and obtain prior approval from the MD/GCEO. As for Director, you must consult the board Chairman.
4.3.3 You must not accept, engage or offer any entertainment that is indecent, sexually oriented or that otherwise might put yourself in a position of conflict or adversely affect AIMS PAY’s reputation.
4.4 Travel
4.4.1 You may accept lodging and other expenses (e.g. food, transportation) provided by Counterparties, Business Partners or other stakeholders within the host country if the trip is for business purposes and prior approval in accordance with established procedures has been obtained. The cost of travelling to the host country must be borne by AIMS PAY.
4.4.2 Unless prohibited by law or the policy of the recipient organisation, AIMS PAY may bear the costs of transportation and lodging for Counterparties, Business Partners or other stakeholders in connection with a visit to AIMS PAY’s facility. The visit must be for a legitimate business purpose e.g. on-site examination of equipment, contract negotiations or training. Prior approval in accordance with established procedures must be obtained.
5. ANTI-BRIBERY AND CORRUPTION
5.1 AIMS PAY takes a zero-tolerance approach towards bribery and corruption, and is committed to behaving professionally, fairly and with integrity in all our business dealings and relationships wherever AIMS PAY operates and implementing and enforcing effective systems to counter bribery and corruption.
5.2 AIMS PAY intends to fulfil the requirements set forth in the Guidelines on Adequate Procedures pursuant to subsection (5) of section 17A of the Malaysian Anti-Corruption Commission Act 2009 (Act 694) (MACC Act 2009), as stated in the Malaysian Anti-Corruption Commission (Amendment) Act 2018 (MACC Amendment Act 2018)
5.3 You must comply with all applicable anti-bribery and corruption laws and regulations and treaties in all countries in which AIMS PAY operates. You must also comply with the Company Anti-Bribery and Corruption Policy.
5.4 You must not directly or indirectly involve in any corrupt conduct, which include but not limited to the abuse of position/ authority and falsification of documents.
5.5 You must not influence others or be influenced, either directly or indirectly, by paying or receiving bribes or kickbacks or any other measures that are deemed unethical or will tarnish AIMS PAY’s reputation.
5.6 You must not accept a benefit from or provide a benefit to a third party by reason only of him/her being a director or employee or him/her doing something or refraining from doing anything as a director or employee unless he is permitted to do so by the company’s constitution, and it is not contrary to any written law.
5.7 You will not suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes even if such refusal may result in the company losing its business or not meeting the targets.
5.8 All Counterparties (when representing AIMS PAY of companies) are under a duty not to promise, offer or give any improper advantage on behalf of AIMS PAY. Directors and Employees must endeavour to ensure that these Counterparties do not promise, offer or give any such improper advantage on behalf of AIMS PAY.
6. DONATIONS AND SPONSORSHIPS
6.1 All sponsorships and donations shall not be used as a subterfuge for bribery. AIMS PAY needs to be certain that donations to charities or beneficiaries are not disguised illegal payments to government officials and must ensure that the charity does not act as a conduit to fund illegal activities in violation of anti-money laundering, anti- terrorism and other applicable laws.
6.2 In accordance with AIMS PAY’s commitment to contribute to the community coupled with its values of integrity and transparency, all sponsorships and donations must comply with the following:
6.2.1 ensure such contributions are allowed by applicable laws;
6.2.2 obtain all the necessary internal authorisations;
6.2.3 be made to well established entities having an adequate organisational structure to guarantee proper administration of the funds;
6.2.4 be accurately stated in AIMS PAY’s accounting books and records; and
6.2.5 not to be used as a means to cover up an undue payment or bribery;
6.3 You should also avoid situations where conflicts of interests could arise from making donations or sponsorships.
6.4 The giving of charitable donations or the payment of expenses for, or on behalf of, public officials or a public entity is governed by a complicated array of regulations, which vary from jurisdiction to jurisdiction. Before making any expenditure for, or on behalf of, public officials or public entity you must consult LCD for consultation prior to getting necessary approval. Donations and sponsorships should be made transparently and recorded.
7. Disclosure of Information
All business dealings shall be transparently performed and accurately reflected on the AIMS PAY’s business books and records. Information regarding labor, health and safety, environmental practices, business activities, structure, financial situation, and performance shall be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
8. Fair Business Advertising and Competition
Standards of fair business, advertising, and competition shall be upheld.
Rev 1.0 (18 Aug 2024)