CODE OF CONDUCT

1. PURPOSE

1.1 The purpose of this Code of Conduct (this “Code”) is to outline the expectations regarding the behaviour of employees of Broadway Industrial Group Limited (the “Company”) and its subsidiaries (together the “Group”) towards their colleagues, supervisors and the overall organisation.

1.2 The Company promotes freedom of expression and open communication and encourages employees to foster a well-organised, respectful and collaborative environment.

1.3 The Company is also committed to ensuring that its affairs are conducted in accordance with the highest standard of business conduct and integrity and in compliance with the law.

2. SCOPE

This Code applies to all employees of the Group regardless of designation or job grade.

3. OBLIGATIONS

3.1 All employees are expected to comply with this Code and all relevant policies. Employees should consult their immediate manager or the Human Resources Department when in doubt.

Compliance with Law

3.2 Employees must protect the Group’s legality and comply with all environmental, safety and fair dealing laws at all times. 

3.3 Employees are expected to be ethical and responsible when dealing with the Group’s finances, products, partnerships and public image. 

3.4 Employees should deal with the Group’s stakeholders in a fair manner and must not take unfair advantage of any party through manipulation, concealment, abuse of privileged or confidential information, misrepresentation of facts or through any other unethical means. 

Anti-Corruption

3.5 The Company strictly prohibits employees from accepting gifts or any form of bribery from any person including customers, suppliers and business partners. Employees should refer to the Company’s Declaration of Interest Policy and Whistleblowing Policy.

Professionalism

3.6 Employees must show integrity and professionalism at the workplace.

Respect at Workplace

3.7 The Company adopts an open communication policy. All employees should be open for communication with their colleagues, supervisors or team members.

3.8 Employees should respect their colleagues. Managers must not abuse their authority. The Company does not allow any form of discriminatory behaviour, harassment or victimisation. 

3.9 Employees should be friendly and collaborative. Employees should not disrupt the workplace or present obstacles to their colleagues’ work.

Protection of Property

3.10 Employees should treat the Group’s property, whether material or intangible, with respect and care, and protect the Group’s facilities and other material property from damage and vandalism, whenever possible. Employees should not misuse the Group’s equipment or use it frivolously.

Confidentiality

3.11 Employees must maintain the confidentiality of all information about the Group and other parties that have business dealings with the Group except when disclosure is authorised or legally mandated. Employees must not use price sensitive information that is not generally disclosed to the public unless it is necessary for the purpose of carrying out work related duties and such information shall only be disclosed or made public in accordance with the Company’s guidelines. Employees should refer to the Company’s Securities Trading Policy.

4. REPORTING VIOLATIONS

Employees should immediately report any suspected violation of this Code to their Human Resources Department. This will be investigated, and appropriate action will be taken in the event that a violation of this Code has occurred. 

5. DISCIPLINARY ACTIONS

5.1 The Company shall take disciplinary action against employees who repeatedly or intentionally fail to follow this Code. Disciplinary actions will vary depending on the degree of the non-compliance.

5.2 Possible consequences may include:

(i) Demotion

(ii) Reprimand

(iii) Suspension or termination for more serious offences

(iv) Detraction of benefits for a definite or indefinite time

6. RESPONSIBILITIES

The HR is responsible for monitoring and reviewing this Code.