Effective Date: January 1, 2025
Last Updated: January 1, 2025

1. Introduction
1.1 Net Onboard Sdn Bhd is committed to upholding the highest ethical standards in business conduct and professional behavior.
1.2 This Code of Business Conduct & Ethics (Code) sets forth the principles, policies, and expectations that guide employees, management, board members, vendors, and business partners in maintaining integrity, responsibility, and transparency in all company activities.
1.3 This Code applies to:
– All employees, directors, officers, business partners, and third-party vendors of Net Onboard.
– All business operations, decisions, and interactions with stakeholders, customers, and government authorities.

2. Core Ethical Principles
2.1 Integrity & Honesty:
– Employees must act with honesty and transparency in all business dealings.
– False reporting, misrepresentation, and deceptive practices are strictly prohibited.
2.2 Accountability & Responsibility:
– Each individual is responsible for their actions and decisions in the company.
– Managers and supervisors are accountable for ensuring compliance with this Code.
2.3 Respect & Fair Treatment:
– Net Onboard promotes a respectful, inclusive, and harassment-free workplace.
– Discrimination based on race, gender, religion, nationality, disability, or any other protected status is not tolerated.
2.4 Confidentiality & Data Protection:
– Employees must protect sensitive company and customer data.
– Unauthorized access, sharing, or misuse of confidential information is strictly prohibited.

3. Compliance with Laws & Regulations
3.1 Regulatory & Legal Compliance:
– Net Onboard complies with all Malaysian laws, industry regulations, and international legal frameworks.
– Employees must follow applicable laws, including Malaysia’s Companies Act 2016, PDPA 2010, AMLA 2001, and Competition Act 2010.
3.2 Anti-Bribery & Corruption (MACC Act 2009):
– Bribery, kickbacks, or offering anything of value to influence business decisions is strictly prohibited.
– Employees must report any attempts of bribery or unethical business influence.
3.3 Conflict of Interest:
– Employees must avoid situations where personal interests conflict with company business.
– Any potential conflict of interest must be immediately disclosed to management.

4. Ethical Business Practices & Fair Competition
4.1 Fair Dealing & Competitive Integrity:
– Net Onboard competes fairly and ethically, without engaging in price-fixing, market manipulation, or unfair trade practices.
– All advertising and marketing practices must be truthful and non-deceptive.
4.2 Gifts, Entertainment & Hospitality:
– Accepting or offering excessive gifts or entertainment to gain undue business influence is prohibited.
– Employees must seek approval before offering or accepting gifts exceeding a reasonable value.
4.3 Whistleblower Protection & Reporting Misconduct:
– Employees are encouraged to report any violations of this Code confidentially via [email protected].
– Whistleblowers will be protected from retaliation for reporting violations in good faith.

5. Workplace Conduct & Employee Responsibilities
5.1 Health, Safety & Well-Being:
– Net Onboard is committed to maintaining a safe and healthy work environment.
– Employees must follow all workplace safety policies and report hazards.
5.2 Substance Abuse & Zero Tolerance for Harassment:
– The use of drugs, alcohol, or other impairing substances in the workplace is strictly prohibited.
– Any form of workplace harassment, bullying, or violence will result in disciplinary action.
5.3 Protection of Company Assets & Intellectual Property:
– Employees must use company resources responsibly and protect intellectual property rights.
– Unauthorized use of company assets for personal gain or external businesses is not allowed.

6. ESG Commitment & Social Responsibility
6.1 Sustainability & Environmental Responsibility:
– Employees must support energy-efficient and environmentally sustainable business practices.
– Compliance with Net Onboard’s ESG and Sustainability Framework is mandatory.
6.2 Diversity, Equity & Inclusion (DEI):
– The company fosters equal opportunities, fairness, and respect for all employees.
– Discriminatory behavior is not tolerated at any level of the organization.

7. Disciplinary Actions & Policy Enforcement
7.1 Consequences of Violating the Code:
– Violations of this Code may result in disciplinary action, including suspension, termination, or legal prosecution.
7.2 Investigation Process:
– All reports of misconduct will be investigated promptly and confidentially.
– If violations are found, corrective actions will be taken in accordance with company policies and legal requirements.

8. Governing Law & Dispute Resolution
8.1 This Code is governed by Malaysian law.
8.2 Disputes related to business ethics or violations of this Code will be resolved through mediation before arbitration or litigation.

9. Amendments & Updates
9.1 Net Onboard reserves the right to update this Code of Business Conduct & Ethics at any time.
9.2 Employees will be notified of material changes via email or company announcements.
For ethics-related inquiries or to report concerns, contact [email protected].