MD Capital Bhd is committed to conducting its business operations in accordance with the highest standards of legal and regulatory compliance. This Compliance Policy sets forth the principles and guidelines to be followed by all employees, officers, and directors of MD Capital Bhd in order to ensure compliance with applicable laws, regulations, and internal policies. Compliance with this policy is a condition of employment and is vital to maintaining our reputation and integrity.

Compliance with Laws and Regulations

1.1. MD Capital Bhd is committed to complying with all applicable laws, regulations, and legal requirements in the jurisdictions in which we operate. All employees must familiarize themselves with the laws and regulations relevant to their roles and responsibilities and ensure compliance with them.

1.2. Employees shall not engage in any activity that violates local, national, or international laws, including but not limited to laws related to anti-corruption, insider trading, money laundering, fraud, intellectual property rights, and data privacy.

1.3. If an employee becomes aware of any actual or potential violation of laws or regulations, they must report it promptly to the appropriate channels as outlined in the company’s reporting procedures.

Ethical Conduct

2.1. MD Capital Bhd expects all employees to uphold the highest ethical standards in their professional conduct. This includes but is not limited to honesty, integrity, fairness, and respect for others.

2.2. Employees shall avoid conflicts of interest that may compromise their ability to act in the best interest of MD Capital Bhd. If a potential or actual conflict of interest arises, it must be disclosed promptly to the appropriate channels as outlined in the company’s policies and procedures.

2.3. Employees shall not engage in any form of bribery, kickbacks, or other corrupt practices. Accepting or offering gifts, entertainment, or favors must comply with the company’s Gift and Entertainment Policy and applicable laws and regulations.

Data Privacy and Security

3.1. MD Capital Bhd is committed to protecting the privacy and security of personal information entrusted to us by employees, customers, partners, and other stakeholders. Employees must adhere to the company’s Privacy Policy and applicable data protection laws.

3.2. Employees shall handle and protect personal information with the utmost care and only use it for legitimate business purposes. Unlawful or unauthorized access, use, disclosure, alteration, or destruction of personal data is strictly prohibited.

3.3. In the event of a data breach or unauthorized disclosure of personal information, employees must report it immediately to the appropriate channels as outlined in the company’s data breach response procedures.

Reporting and Non-Retaliation

4.1. MD Capital Bhd encourages employees to report any concerns, suspected violations, or potential breaches of this Compliance Policy, laws, or regulations through the company’s reporting channels, such as the Whistleblower Hotline or designated compliance officers.

4.2. MD Capital Bhd prohibits retaliation against individuals who report in good faith violations or suspected violations of this policy. Reports will be treated confidentially to the extent permitted by law, and appropriate action will be taken to address reported concerns.

Training and Education

5.1. MD Capital Bhd will provide regular training and education programs to employees to ensure their understanding of this Compliance Policy and the importance of compliance with applicable laws, regulations, and internal policies.

5.2. Employees are expected to actively participate in and complete all compliance training and education programs as required by MD Capital Bhd.

Monitoring and Enforcement

6.1. MD Capital Bhd will monitor compliance with this policy through internal audits, assessments, and other appropriate measures. Non-compliance may result in disciplinary action, up to and including termination of employment.

6.2. MD Capital Bhd reserves the right to update and modify this Compliance Policy as necessary. Employees will be notified of any material changes to this policy.

By adhering to this Compliance Policy, MD Capital Bhd and its employees contribute to maintaining a culture of integrity, ethics, and legal compliance, ensuring the trust of our stakeholders and the long-term success of the organization.