In line with good corporate governance practices, Grand-Flo Berhad (“Grand-Flo” or “the Company”) has adopted the following Code of Ethics and Conduct for Directors, Management and Employees of the Company and its subsidiaries (“the Group”). The Code is established to promote the corporate culture which engenders ethical conduct that permeates throughout the Group. All Directors, Management and Employees of the Group shall be referred to as “Officer(s)” therein.

The objective of the Code of Ethics and Conduct is to enhance the standards of corporate governance and corporate behavior to achieve a standard of ethical behavior to the Officers based on trustworthiness and values that can be accepted and to ensure the spirit of social responsibility and accountability of the Group is in line with the relevant legislation, regulations and guidelines governing it.

The Code of Ethics and Conduct is to be observed by all Directors and Employees of the Group and the core areas of conduct include the following:-

i. Compliance at all times with the Code of Ethics and Conduct and the Board Charter.

ii. Observe high standards of corporate governance at all times.

iii. Adhere to the principles of selflessness, integrity, objectivity, accountability, openness, honesty and leadership, including fair dealing and the ethical handling of conflicts of interest.

iv. Not misuse information gained in the course of duties for personal gain or for political purposes.

v. Uphold accountability and act in good faith and in the best interests of the Company and the Group.

vi. Ensure the protection of the Company's legitimate business interests, including corporate opportunities, assets and confidential information.

vii. Ensure full, fair, accurate, timely and understandable disclosure.

viii. Declaration of any personal, professional or business interests that may conflict with responsibilities.

The Code of Ethics and Conduct will be reviewed from time to time and make any necessary amendments to ensure the information remains relevant and appropriate. The Code of Ethics and Conduct is made available for reference in the Company’s website.

This Code of Ethics and Conduct was reviewed and updated on 22 November 2018 by the Board.