KUB Malaysia Berhad Annual Report 2021

Statement on Risk Management and Internal Control Policies and Procedures Policies and standard operating procedures (‘SOP’) are established to provide management and operating guidelines to the Group’s operating units. These policies and procedures are documented and subject to regular review, update and enhancement to reflect the current requirement and maintain its relevance. Amongst the policies are: Integrity Related Policies The Board in February 2021 has refined the Anti-Bribery and Corruption Policy (‘ABC policy’), Vendor Code of Business Ethics Policy and Whistleblowing Policy in line with the introduction of Section 17A of the Malaysian Anti-Corruption Commission Act 2009 which came into force on 1 June 2020. These policies outline the Group’s commitment to uphold all laws and regulatory requirements relating to anti-bribery and corruption. All Directors, employees and business associates are responsible to understand and comply with these policies. Violation to the policies is to be taken seriously that may subject to necessary actions by the Group including but not limited to review on employment, appointment or business arrangements that may lead to disciplinary actions, reprimand, suspension, dismissal, termination of business relationship, blacklisting and/or reporting to the authorities consistent with the applicable laws and regulations. Procurement and Strategic Sourcing (‘Procurement’) Policy Procurement Policy aims to support good and sustainable procurement practices on goods, works and services for the Group. It outlines that all procurement decisions within the Group are guided by defined principles i.e. to ensure the Group and the suppliers comply with all applicable laws and regulations throughout the procurement life cycle. The policy at all times encourages ethical vendor management via Vendor Code of Business Ethics Policy that includes ABC Policy and Conflict of Interest in the selection of vendor, tender and procurement process. Information & Communication Technology (‘ICT’) Policy ICT Policy supports to monitor, escalate and report cyber threats or information security. A Disaster Recovery Centre is maintained to support identified critical business applications during disruption. To ensure proper protection in responding to cybersecurity threats, adequate ICT security tools and procedures are in place to detect, respond and mitigate the threats. Human Resource Policies and Procedures A comprehensive set of Human Resource Policies and Procedures are established within KUB Group to ensure the Group complies with relevant legislation and applies the best human resource practices on workforce planning, recruitment, compensation and benefits, industrial relations, employee engagement, employee development, performance management and salary administration. The Code of Ethics and Conduct (‘the Code’) is communicated to all employees to reinforce the Group’s core value on integrity by providing guidance on moral and ethical behaviour that is expected from all employees. The Code is incorporated in the Employee Handbook and it covers six (6) broad categories of ethics in regards to the Group’s operation and personal conduct namely: a) Conflict of Interest; b) Misuse of Position; c) Misuse of Information; d) Integrity and Accuracy of Record/ Transaction; e) Fair and Equitable Treatment; and f) Confidentiality Project Management Policy, Procedures and Guidelines (‘PMPP’) The scope of PMPP includes project sales (prospecting, tenders and post-tender), project initiation (project authorisation, initiation and dashboard), project planning, project execution (site administration, inspection and testing, control of monitoring and measuring equipment, maintenance and repair of plant machinery and equipment) and project post execution (final inspection, project handover and defects liability). PMPP is designed to cover revenue generating projects and contracts from external parties on the acceptance, delivery and management. Staff Competency, Training and Development Programmes The Group believes that an effective organisation requires employees at all levels to be competent, skilful and capable to contribute to the achievement of the Group’s vision and mission. Training and development programmes are implemented to ensure that employees are equipped with the necessary competencies. The implementation of the training and development programmes is to address the deficiency of the competency in bridging the gap between performance and opportunity, thus assisting the Group to develop talented employees to be potential leaders in the industry. 38 KUB MALAYSIA BERHAD