• Code of Conduct (“COC”) for Directors and Employees UEM Edgenta’s Code of Conduct (“COC”) for Directors and Employees articulates our commitment to maintaining trust and integrity across all levels of the organisation. It sets clear standards for ethical behaviour, ensuring that directors and employees consistently operate with professionalism, reliability, and accountability. The COC outlines the principles and values that shape how we conduct ourselves with colleagues, clients, business partners, and the broader community. • Code of Conduct for Business Partners (“COCBP”) UEM Edgenta’s Code of Conduct for Business Partners (“COCBP”) establishes clear expectations for our suppliers, contractors, consultants, agents, and/or other business partners to uphold the highest standards of integrity, accountability, and compliance. It reflects our unwavering commitment to fostering sustainable business relationship grounded in the principles of integrity, honesty, accountability and compliance with applicable laws and regulations. By adhering to this Code, our Business Partners contribute to a shared culture of trust and integrity, ensuring that all interactions with UEM Edgenta are conducted ethically and responsibly. ANTI-BRIBERY AND ANTI-CORRUPTION GOVERNANCE At UEM Edgenta, we maintain a steadfast commitment to combating bribery and corruption through robust Anti-Bribery and AntiCorruption (“ABAC”) measures that align with national anti-corruption efforts. Guided by a zero-tolerance approach towards all forms of corruption, the Board ensures that our governance practices meet the highest legal and regulatory standards. As a benchmark for our ABAC programme, we adhere to the following legal, regulatory requirements, and guidelines: • Compliance Framework The compliance framework outlines a structured approach to managing regulatory compliance obligations and mitigating compliance risks or issues, to ensure alignment with the Group’s compliance objective. The Framework define the governance structure, roles and responsibilities to maintaining compliance across the Group. It also details the policies and methodologies that form the foundation of UEM Edgenta’s compliance management system, fostering accountability and a culture of integrity in all aspects of our operations. • Conflict of Interest (“COI”) Policy The Conflict of Interest (“COI”) Policy provides clear guidance on identifying, managing, and resolving actual, potential, or perceived conflicts of interest involving Directors and employees. This Policy is designed to safeguard UEM Edgenta’s interests by ensuring that decisions and actions are made with integrity, transparency, and ethical conduct and to ensure that any actual, potential, or perceived conflicts of interest are identified and managed effectively. By effectively managing conflicts of interest, we reinforce trust, accountability, and fairness in all our business dealings. Our ABAC programme is developed in accordance with the T.R.U.S.T principles outlined in the Guidelines on Adequate Procedures, which serve as a benchmark for maintaining corporate integrity. This aligns with the principles outlined in the Adequate Procedures Guidelines under Section 17A(5) of the Malaysian Anti-Corruption Commission Act 2009, functioning as a defense mechanism against corporate liability for bribery and corruption offences. Reinforcing our commitment to integrity and governance in all business operations, UEM Edgenta has achieved the internationally recognised MS ISO 37001:2016 Anti-Bribery Management System (“ABMS”) certification. This certification underscores our zero tolerance against corruption and our dedication to implementing the best practices in anti-bribery management. In line with our regulatory obligations and ethical values, we have established a comprehensive framework supported by policies and procedures to effectively curb bribery and corruption. The following measures serve as a foundation to promote transparency, accountability, and ethical business conduct throughout the organisation and among our stakeholders: The Malaysian Anti-Corruption Commission (“MACC”) Act 2009 Directive of The Prime Minister No. 1 Series 1 issued in October 2018 The Guideline for the Management of Integrity & Governance Unit issued by MACC The Guidelines on Adequate Procedures issued by the Prime Minister’s Department ABAC Guide Corporate Integrity and Ethical Business Conduct UEM EDGENTA BERHAD 254 Integrated Annual Report 2024
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