Code of Ethics and Conduct

WHITE HORSE BERHAD ​199701039630 (455130-X) (Incorporated in Malaysia)

1. Introduction
   White Horse Berhad has adopted the following Code of Ethics and Conduct (“Code”) for Directors (“Board”), the Management and employees of White Horse Berhad (“White Horse” or “the Company”) and its subsidiaries (“the Group”) to adhere to the general principles and standards of business conduct and ethical behaviour in the performance and exercise of their responsibilities as Board, Management and employees of the Company in order to uphold good corporate integrity.
2. Responsibility and Accountability
   The Code governs all of White Horse’s business decision and therefore, it is applicable to the following:-

    

   • All Directors of the Group; and
   • All employees of the Group.

   All Directors, Management and employees of the Group shall be referred to as “Officers” hereon, unless the context otherwise stated.

   All references to “we”, “our”, “us” in this Code mean the Group, references to “you” and “your” in this Code means the Officers of the Group, unless the context otherwise requires.

3. Objective
   The Code serves as a guidance to the Officers in their business conducts, so as to enhance the standard of corporate governance and corporate behaviour, protect and promote the interests of shareholders and other stakeholders.
4. EXPECTED STANDARDS OF ETHICS AND CONDUCT
   The Officers shall adhere to the following:-

    

   • Act in a manner to enhance and maintain the reputation of the Company;
   • Act in the best interests of, and fulfill their fiduciary obligations to the Company;
   • Comply with all applicable laws, rules and regulations;
   • Act in good faith, responsibly, with due care, competence and diligence, without allowing their independent judgment to be subordinated;
   • Deal fairly with all stakeholders;
   • Not accept from or give to stakeholders gifts or other benefits not normally customary;
   • Disclose any personal interest that they may have regarding any matters that may come before the Board and abstain from discussion and where relevant, abstain from voting as a member of the Board or relevant board committee on any matter in which he/she may have an interest (direct or indirect) or where there may be potential conflict of interest;
   • Prohibited from using any confidential information or opportunity obtained in the course of their service as the Officers in a manner that would be detrimental to the Company’s interest;
   • Exercise caution and due care to safeguard the confidentiality of information relating to the affairs of the Company acquired in the course of their service as the Officers except when authorised or legally required to disclose such information; and
   • Help create and maintain
5. ANTI-CORRUPTION
   Corrupt arrangements with customers, suppliers, government officials, or other third parties are strictly prohibited. “Corruption” generally refers to obtaining, or attempting to obtain, a personal benefit or business advantage through improper or illegal means.Corrupt activities are not only a violation of this Code, they could potentially be a serious violation of criminal and civil anti-bribery and anti-corruption laws with statutory penalties. Should we become aware of any potential or actual corrupt arrangement or agreement, we have the statutory obligations to report to the relevant authority(ies).
6. ANTI-MONEY LAUNDERING
   “Money laundering” is the process by which persons or groups try to conceal the proceeds of illegal activities or try to make the sources of their illegal funds look legitimate.We shall to the best of our ability and knowledge conduct business with reputable customers with legitimate funds, for legitimate business purposes.
7. INSIDER TRADING
   In the course of performing job, you may learn of certain confidential information that qualifies as “material non-public and price-sensitive information” about the Group, our customers, suppliers or business partners or another third party.“Material non-public and price-sensitive information” means any non-public and price-sensitive information that could potentially influence the investment decisions of investors. It includes, but is not limited to, the following:-

    

   • Financial information such as sales and profits;
   • Information concerning dividends;
   • Information concerning alliances with other companies, including mergers and acquisitions;
   • Information concerning changes in major suppliers; and
   • Information concerning new products or new technologies.

   You should not disclose material non-public and price-sensitive information to anyone outside of the Group, including family members and friends.

   You should not deal in securities of the Company nor influence any third party in dealing with the securities while they have material non-public and price-sensitive information about the Group.

   In addition, you are not permitted to engage in activities that are designed to hedge or offset any decrease in the market value of the Company’s securities.

8. FRAUD
   You should not engage in any transaction involving dishonesty and/or fraud, either directly or indirectly, that reflects adversely on us. You should not mislead, provide misleading information or fail to disclose important information in any way in order to obtain financial benefit. You should not make fraudulent declaration or falsify any information in any business transactions.
9. COMPLIANCE
   The Officers shall be accountable for full compliance of the Code. In event of any breach of the Code, the Board shall take necessary actions to ratify on the non-compliance.
10. REVIEW OF THE CODE
    The Code shall be reviewed by the Board periodically to ensure the information remains adequate and appropriate.