Telekom Malaysia Berhad

Telekom Malaysia BerhadAll rights reserved. No part of this publication may be reproduced, stored in a retrievalsystem, or transmitted in any form or by any means, electronic, mechanical, photocopying,recording or otherwise, without the prior permission of Telekom Malaysia Berhad.3rd Edition November 2010Telekom Malaysia BerhadCode of Business Ethicsi

TM GENERAL BUSINESS PRINCIPLETM, a leading integrated telecommunications service provider in Malaysia is committed indelivering cutting-edge communications, information and entertainment services.Our Vision"To be Malaysia‟s leading new generation communications provider, embracing customerneeds through innovation and execution excellence"Our Mission Strive towards customer service excellence and operational efficiency;Enrich consumer lifestyle and experience by providing innovative new generationservices;Improve the performance of our business customers by providing high valueinformation and communications solutions;Deliver value for stakeholders by generating shareholder value and supportingMalaysia‟s growth and development. Our Core Values – Tree of ChangeThe Fruits Our DesiredCultureThe Stem System &Support LeadershipRewards & RecognitionBehaviour & CompetencyInnovativenessTeamworkOwning CustomersPerformance DrivenThe Root Our Core(KRISTAL)Values(k(Kristal(KRISTAL) ValuesProactive,Sensitive andResponsive Total Commitment To Customers Uncompromising Integrity Respect & CareHonesty, Trustworthiness,Sincerity, Dedication,FairnessTeam Spirit &Cooperation,Mutual Respect& Courtesy,Understanding& Open-minded3rd Edition November 2010Telekom Malaysia BerhadCode of Business Ethicsii

FOREWORDThe economic and business environment today is very challenging and dynamic. As ourCompany strives and competes to stay put in business, we must not at any cost neglect thecode of business ethics. This is because good ethics promotes integrity in business dealingsand in turn stimulates a growing and healthy economy.In Malaysia, the agenda of business ethics can be found within the third target of theNational Integrity Plan; namely “to enhance corporate governance and business ethics”amongst private sector role players.Corporate governance is a concept which calls for transparency, integrity and accountability.In Malaysia, this concept is entrenched either statutorily into various legislation that regulatecorporate activities or, by way of non statutory code of ethics. In this respect, theGovernment applies the concept of good corporate governance for Malaysian companies tovoluntarily adopt and inculcate the best practices.The TM‟s Code of Business Ethics (“Code”) sets forth the standards that guide our everyaction at TM and its Group of Companies, and applies to the Board of Directors,Management, Employees and all representatives of the Company. It shall act as the guidingprinciples in inculcating the business ethics mindset in all.The Code describes and reinforces conduct that is based on our guiding core values,consistent with our policies and practices, and essential to TM‟s legal and regulatorycompliance obligations. Our ongoing commitment to these values is necessary to ensurethat we will operate with the highest ethical standards and achieve our vision to beMalaysia‟s leading new generation communications provider.Thank you.DATO’ SRI ZAMZAMZAIRANI MOHD ISAGroup Chief Executive OfficerTelekom Malaysia Berhad3rd Edition November 2010Telekom Malaysia BerhadCode of Business Ethicsiii

TABLE OF CONTENT1.1.11.21.3INTRODUCTION . 1Objective . 1Scope . 1Compliance to the Code . 22.DEFINITIONS AND INTERPRETATIONS . 33.3.13.23.3RESPONSIBILITIES REGARDING CODE OF BUSINESS ETHICS . 7Responsibilities of Directors . 7Responsibilities of Management . 7Responsibilities of Employees: . 84.4.14.24.34.44.54.64.74.84.94.104.114.12OUR DEALING WITH EMPLOYEES . 9Respect for Individual . 9Harassment . 9Safety, Health and Environment . 9Drugs, Alcohol and Prohibited Substances . 10Weapons . 10Threats and Violence. 10Immoral Activities . 10Criminal Breach of Trust . 11Subversive and Other Criminal Activities . 11Offences Relating to Racial and Religious Harmony . 11Giving Evidence in Court . 11Equal Opportunity . 115.5.15.25.35.45.55.65.7OUR DEALING WITH CUSTOMERS . 12Total Commitment to Customers . 12Product and Service Quality and Safety . 12Sales and Marketing . 12Customer Information . 12Privacy of Customer Communications . 13Government as Customer. 13Business Dress and Attire . 136.6.16.26.36.46.56.66.76.8OUR DEALING WITH SUPPLIERS AND BUSINESS PARTNERS . 14Doing Business with Others. 14Agents and Consultants . 14Contractors and Sub-contractors . 14Joint Ventures and Alliances . 14Procurement Practices . 14Gratification . 15Suppliers and Business Partners' Commitment to Business Ethics . 16Raising Concerns . 167.OUR DEALING WITH SHAREHOLDERS 178.8.18.2OUR DEALING WITH COMPETITION . 18Competition Law. 18General Competition Practices . 183rd Edition November 2010Telekom Malaysia BerhadCode of Business Ethicsi

9.9.19.29.39.4OUR DEALING WITH COMMUNITIES . 19Community Services. 19Personal Community Activities . 19Environment . 19Communicating to External Audiences . 1910.10.110.210.310.410.5OUR DEALING WITH GOVERNMENTS . 20Compliance with the Law . 20Political Donation . 20Political Activities . 20Anti-Corruption Laws . 20Crossing National Borders . 2111.11.111.211.311.411.511.6OUR DEALING WITH COMPANY ASSETS . 22Protecting TM's Assets . 22Confidential Information . 25Trading on Insider Information . 26Accuracy of Company Records . 27Recording and Retaining Business Communications. 27Sharing Best Practices . 112.12CONFLICT OF INTERESTS . 28General Considerations . 28Outside Business Appointments, Directorships/Undertakings . 28Ownership of Equity in Entities Having a Business Relationship with TM . 29Family or Close Personal Friendship Interest . 30Contractual Dealings with Employees . 30Proprietary Information . 30Investments . 31Gifts . 31Entertainments . 33Travel . 34Public Services, Recreational, Sporting and Community Activities . 34Disclosures and Declarations . 3413.WHISTLE-BLOWING POLICY . 3514.INTERNAL NOTIFICATION PROCEDURES . 3715.PROCESS . 3816.CERTIFICATION OF COMPLIANCE TO TELEKOM MALAYSIA’S CODE OFBUSINESS ETHICS .393rd Edition November 2010Telekom Malaysia BerhadCode of Business Ethicsii

1.INTRODUCTION1.1ObjectiveThe objective of the Code of Business Ethics (hereto referred as the "Code") is tosupport TM's vision and Core Values "KRISTAL" by informing the Board of Directors,Management, Employees and all representatives of the Company of the acceptableand unacceptable business conducts. The Code is designed to be in line with TM'sinitiatives to instil, internalize and uphold the value of "UNCOMPROMISINGINTEGRITY" relating to the behaviour and conduct of all stakeholders of theCompany.1.2ScopeThe scope of the Code covers the Board of Directors, Management, Employees andall representatives, including all agents, consultants, independent contractors andsuppliers (“Representative”) of TM and its Group of Companies.The policies that is set out in the Code apply across TM and its Group of Companies,in all businesses and countries world wide. If a local law conflicts with a policy in theCode, one must comply with the local law. If a local custom or practice conflicts witha policy in the Code, one must comply with the Code.Though some of the policy in the Code may be in compliance with the local law;different business, region or country may have policies and practices that requiremore than the requirement of the Code. In all instances, one must follow the stricterlaw, policy or practice. The Code acts as a baseline or a minimum requirement,which must always be complied with, unless doing so, will violate the local law. If theapplicable local law conflicts with the Code, but could permit different alternatives,one must choose the one most closely aligned with the Code‟s requirement. Shouldyou have any doubt, please consult the Legal Division.TM provides the Code as guidance in recognizing and resolving any business ethicalissues that one may encounter in conducting business of the Company. This Codeshall by no means be exhaustive nor does it includes all of the policies of theCompany. Board of Directors, Management, Employees and all Representatives ofthe Company are expected to apply sound judgement in deciding on the mostbusiness ethical means of dealing with any given situation involving Customers,Suppliers, competitors, regulators, public and the Company matters in general.This Code may be reviewed, changed and updated from time to time in keeping withany new developments in business practice, environment and legal requirement.Therefore, the Board of Directors, Management, Employees and otherRepresentatives of the Company are required to be familiar with its contents. Themost current version of the Code is available on TM's 1intra at http://1intra.3rd Edition November 2010Telekom Malaysia BerhadCode of Business Ethics1

1.3Compliance to the CodeAll Board of Directors, Management, Employees and other Representatives of theCompany are responsible for complying with all applicable laws and regulations andfor knowing and complying with the Code and other policies of the Company.All Board of Directors, Management and Employees are required to declare his/herunderstanding and compliance to the Code within one (1) month from the date oftheir appointment/employment or whenever required by the Company, by executingthe Certification of Compliance to the Code, which is attached at the back of theCode.Any disclosure required under the law and the Code shall be based on the relevantfacts and information, which is to the best knowledge of the Board of Directors,Management and Employees.Violation of the law or the Code or other policies of the Company could result indisciplinary actions including but not limited to withholding of bonuses, incrementsand merits award, denial of promotion, and termination or dismissal of employment.Line of Business, Central Functions, Support Functions, and Subsidiary Companieswithin TM and its Group of Companies are responsible for ensuring that their policiesand procedures are consistent with the Code and the respective Board of Directorsmust adopt to the Code. For Associate Companies of TM, this Code shall serve asguidance for their business ethical procedures and practices.The Board of Directors of TM has approved that should there be other policies andprocedures of the Company that are in conflict with this Code, the policies ascovered in this Code shall prevail over the others."Under unusual circumstances, the Board of Directors, Management andEmployees and other Representatives of the Company may seek approval ofactions that otherwise would not be compliant with the Code. Approval of anyaction not compliant with the Code must be sought in advance and may begranted only by the Group Chief Executive Officer or the Board of Directors ofthe Company. Waiver of the Code must be promptly disclosed to the Board ofDirectors. When a waiver is granted, the Group Chief Executive Officer or theBoard of Directors shall ensure that appropriate controls are in place toprotect the Company and its shareholders. "3rd Edition November 2010Telekom Malaysia BerhadCode of Business Ethics2