Code of Conduct & Business Ethics

This Code of Conduct & Business Ethics sets out the standards of behaviour expected of everyone who works for or on behalf of SK Luxury Construction Sdn. Bhd. (“the Company”). It reflects the values on which the Company builds its reputation: integrity, accountability, and respect.

1. Purpose and Scope

This Code applies to all directors, officers and employees of the Company, and its principles extend to subcontractors, suppliers and business associates acting on the Company’s behalf. It is not exhaustive; where a situation is not specifically addressed, personnel are expected to act in good faith and in the Company’s best interests, and to seek guidance from Management when in doubt.

2. Our Core Principles

• Integrity — we are honest and fair in all our dealings and do not tolerate dishonesty or deception.
• Accountability — we take responsibility for our actions and the quality of our work.
• Respect — we treat colleagues, clients, partners and communities with dignity and fairness.
• Safety — we protect the health and wellbeing of our people and everyone affected by our work.

3. Compliance with Laws and Regulations

The Company and its personnel comply with all applicable laws, regulations and industry standards governing construction and its business operations in Malaysia. Where this Code sets a higher standard than the law, the higher standard applies.

4. Integrity and Anti-Corruption

The Company maintains a zero-tolerance stance on bribery and corruption. All personnel and associated persons must comply with the Company’s Anti-Bribery & Anti-Corruption Policy, which forms part of this Code.

5. Conflicts of Interest

Personnel must not allow personal interests to interfere with their duties to the Company. Any actual, potential or perceived conflict — including outside interests, related-party dealings, or personal relationships that affect business decisions — must be disclosed to Management for appropriate management.

6. Confidentiality and Data Protection

Personnel must safeguard the confidential information of the Company, its clients and its partners, and must handle personal data responsibly and in accordance with the Personal Data Protection Act 2010. Confidential information must not be used for personal gain or disclosed without proper authority.

7. Health, Safety and Environment

Safety is fundamental to construction work. The Company is committed to providing a safe working environment and complying with the Occupational Safety and Health Act 1994 and related requirements. All personnel must follow safety procedures, report hazards and incidents, and take reasonable care for their own safety and that of others. The Company seeks to minimise the environmental impact of its operations.

8. Fair Dealing

The Company deals fairly and honestly with clients, suppliers and subcontractors. Personnel must not take unfair advantage of anyone through manipulation, concealment, misuse of confidential information, or misrepresentation. Selection of suppliers and subcontractors is based on merit and objective criteria.

9. Workplace Conduct

The Company is committed to a workplace free from harassment, bullying and unlawful discrimination. Personnel are expected to treat one another with respect and professionalism.

10. Company Assets and Records

Personnel must protect the Company’s assets against loss, theft and misuse, and must keep accurate and complete business records. Financial records must properly reflect the Company’s transactions.

11. Raising Concerns

Personnel who become aware of conduct that may breach this Code should raise it through the Company’s Whistleblowing Policy or with Management at admin@skluxury.com.my. Reports made in good faith are treated in confidence and will not result in retaliation.

12. Review

This Code is reviewed periodically and updated as necessary to reflect the Company’s values and legal obligations.