1.0 Introduction
The AEON Group has established the AEON Foundational Ideals with shared values for all its people to practice—centered on pursuing peace, respecting humanity, and serving society—while advancing the AEON Group Future Vision of becoming a market leader in enriching lives through innovative and sustainable solutions. AEON Financial Service, as a trusted and integral part of the AEON Group, operates under the guiding philosophy of Our Purpose. This philosophy reflects AEON Credit Service (M) Berhad and its subsidiaries (“the Group”) commitment to delivering trusted financial services that foster prosperity and brighten everyday lives with peace of mind and smiles.
Built on these shared values and philosophy, this Code of Ethics and Conduct (“the Code”) reflects the Group’s collective identity and serves as a roadmap for ethical decision-making. It ensures that every action we take, from the boardroom to the front lines, aligns with the Group’s mission to create sustainable value for customers, trusted business partners, dedicated employees, regulatory bodies, and local communities.
2.0 Purpose
The purpose of the Code serves as a fundamental guide to ethical decision-making, ensuring compliance with legal and regulatory frameworks, and protects the interests of stakeholders of the Group.
The Code helps Directors, employees and other authorized personnel navigate complex situations, providing clear guidance on what constitutes acceptable behaviour. It aims to foster a corporate culture that prioritizes ethical conduct, transparency, and accountability. By establishing uniform standards of behaviour, the Code seeks to promote consistency across business operations, enhancing the Group’s reputation and ensuring the trust and confidence of customers, investors, regulators, and the general public.
3.0 Scope
This Code applies to Directors, employees and any other persons authorized to perform duties or tasks within the Group, including but not limited to in-source and out-source vendors, secondees, interns, merchants, and agency employees.
The Code forms part of the terms and conditions of employment, employees are expected to adhere to the high standard of professionalism and ethics in the conduct of their daily activities. Non-compliance with the requirements set up in this Code shall be deemed as a breach of discipline that can lead up to dismissal.
4.0 Definition of Terms
| Terms | Definition |
| The Group | AEON Credit Service (M) Berhad and its subsidiaries. |
| The Company | AEON Credit Service (M) Berhad |
| Subsidiary Company | A subsidiary is a company that either fully owned or more than 50% controlled by a parent or holding company. |
| Board of Directors | Board Chairman; Non-independent and Non-Executive Director; Senior Independent and Non-Executive Director; Independent and Non-Executive Director; Managing Director and Executive Director. |
| Board Committee | Board Risk Committee, Audit Committee and Nomination & Remuneration Committee |
| Key Senior Management | Managing Director, Executive Director, Executive Officer and Head of Division. |
5.0 Roles and Responsibilities
| Roles | Responsibilities |
| Board of Directors (“BOD”) | 1. Approve the Code of Ethics and Conduct: To review and formally approve the Code, ensuring it reflects the Group’s vision; values and legal requirements; 2. Set the tone at the top: Demonstrate a strong commitment to ethical behavior and compliance by embodying the principles of the Code in their own conduct; 3. Provide strategic oversight: To oversee the implementation of the Code and ensure the Code is integrated into the Group’s governance framework; and 4. Promoting Ethical Culture: To foster a corporate culture that prioritizes ethical behavior and professional integrity. |
| Board Committee | 1. Audit Committee: Oversees financial reporting, internal controls and compliance in ensuring alignment with the Code; 2. Board Risk Committee: Identifying, assessing and mitigating ethical risks; address whistleblower reports and ensure investigations are conducted fairly and transparently; and 3. Nomination and Remuneration Committee: Integrate the Code into governance and leadership practices. |
| Key Senior Management | 1. Leadership and implementation: Lead the development and implementation of the Code; 2. Integration: Ensure the Code is integrated into business processes and decision-making; 3. Monitoring and Reporting: Review the effectiveness of the Code of Ethics and Conduct and report to the Board on any significant issues or breaches and any necessary improvements; and 4. Crisis Management: Lead the response to any major ethical or compliance crises to regulator and shareholders, ensuring transparency and accountability. |
| Internal Audit Division | 1. Independent assessment and assurance: Assess compliance with the Code and identify areas for improvement; and 2. Reporting: Report findings to the Audit Committee. |
| Human Resources and Administration Group | 1. Code development: Collaborate with internal stakeholders on drafting, reviewing and integrating the Code into relevant policies and procedures; 2. Training & education: Develop and deliver training programs to educate employees about the Code; and 3. Performance Management: Integrate the Code into employee on-boarding; performance evaluations and disciplinary processes. |
| Legal Department | 1. Alignment with legal framework: Review the Code to ensure alignment with relevant laws, regulations, policies or guidelines on statutory requirements. 2. Guidance: Provide guidance on legal risks related to ethical issues; and 3. Monitoring: Keep track of changes in laws that may impact the Code and update it accordingly. |
| Compliance Department | 1. Regulatory compliance: Review the Code to ensure compliance with regulations; 2. Guidance: Provide guidance on compliance risks related to ethical issues; and 3. Monitoring: Keep track of changes in regulations that may impact the Code and update it accordingly. |
| Risk Management Department | 1. Safeguarding reporting mechanism: Manage anonymous reporting channels for ethical concerns; and 2. Timely and fair investigation: Ensure timely and fair investigation of reported issues. |
| Corporate Communication Department | 1. Internal & external dissemination: Develop clear and accessible communication materials about the Code; and 2. Managing Group’s reputation: Manage the Group’s reputation in relation to ethical practices. |
| Employees | 1. Adhering to Code: Read, understand and comply with the Code; 2. Participating in Training and awareness: Attend training sessions and apply the Code’s principles in their daily work; and 3. Reporting Violations: Report any suspected violations of the Code through the appropriate channels or reporting mechanism. |
6.0 Policy
6.1 Code of Ethics
6.1.1 The Code of Ethics reflects AEON Foundational Ideals and stands as a testament to the Group’s commitment to ethical principles. It serves as a moral compass, guiding all decisions and actions taken in alignment with the AEON Group Future Vision of building a lifestyle that leads to a smile for everyone. This code is also integral to achieving Our Purpose of fostering trust and confidence in the Group’s products and services. It ensures that the Group operate with the highest ethical standards, prioritizing the needs of customers and communities while brightening their lives with peace of mind and smiles. The Group bases the Code of Ethics on the fundamental values outlined in the Code of Ethics for the Financial Services Industry developed by the Financial Services Professional Board (FSPB).
6.1.2 All employees shall continuously adhere to and uphold the following five guiding ethical principles in their professional dealings:
Competence
- All employees shall develop and maintain the relevant knowledge and skills to perform their roles in accordance with the Guideline of ACSM Competency (HRG-GDL-AC-G01) set by the Group to ensure that their activities are conducted professionally and proficiently.
Integrity and Sincerity
- Integrity and sincerity are the foundation of the Group’s ethical standards, and the Group is committed to conducting business with honesty, transparency, and ethical principles.
- All employees are expected to uphold integrity and sincerity in all business dealings. This includes behaving in an accountable and trustworthy manner, while refraining from any actions that could harm the Group’s reputation or bring disrepute to the Group at any time. They must proactively manage compliance risks as part of their ethical duties.
Respect and Fairness
- The Group upholds respect and fairness as fundamental principles of an inclusive, supportive, and collaborative workplace. Therefore, every individual shall be treated with dignity and impartiality, acknowledging diverse perspectives and ensuring equal opportunities.
- All employees are expected to demonstrate respect in every interaction, fostering an environment where everyone feels valued and empowered. Employees must also act fairly and transparently in their business practices, always considering the impact of their actions and decisions on stakeholders.
Confidentiality
- Safeguarding the confidentiality of customer, employee, and corporate information is essential to maintaining the Group’s reputation and trustworthiness. All information regarding the business or affairs of the Group, or of a customer of the Group, acquired in the performance of duties, shall be treated as confidential. This includes:
- Using the information solely for its intended purpose and not to be used for personal gain.
- Not divulging information to any unauthorized parties without the consent of those involved, unless disclosure is required by law or regulation.
- Ensuring all employees comply with the Personal Data Protection Act (PDPA).
Objectivity
All employees must maintain objectivity in their business and professional judgment, ensuring that no conflict of interest, bias, or external influence overrides their decisions. Employees should not be swayed by personal friendships or associations when performing their duties. Decisions must be made based on an objective approach and an arm’s length business basis.
6.2 Code of Conduct
6.2.1 The Code of Conduct operationalizes the AEON Foundational Ideals by defining the behaviors and practices that uphold the Group’s values in everyday operations. It reinforces the Group’s commitment to the AEON Group Future Vision by ensuring that everyone in the Group acts in a manner that promotes sustainable good values. This code is also a critical enabler of Our Purpose, ensuring that team members deliver financial solutions with a deep sense of responsibility, maintaining trust and building long-lasting relationships with all stakeholders.
6.2.2 Relationship with our stakeholders
a) Company as a Whole
Basic Principles
- Everyone in the Group must uphold the interest and integrity of the Group at all times, ensuring that there is no conflict or potential conflict between the self-interest of any employee and their responsibility to the Group.
Preserving the Reputation of the Group
- All directors, employees, and representatives of the Group are expected to uphold and enhance the reputation of the Group through their actions and behavior in all business dealings and interactions, both within and outside the Group. Activities that could represent a conflict of interest with respect to the Group’s business or cause regulatory breaches must be prevented. No one shall present themselves as an employee of the Group for any purpose except in connection with the Group’s business. The Group’s reputation must always prevail.
Anti-Bribery and Corruption
- Employees must adhere to the Group’s policy of Anti-Bribery and Corruption Management System (BPD-POL-ABCMS-A01) and comply with the local anti-bribery and corruption laws and regulations at all times.
- No employees shall offer any bribe or similar consideration to any person or company in order to obtain business or secure any license or certification for the Group. The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all directors, employees and representatives of the Group.
Conflict of Interest
- Employees must not engage directly or indirectly in any business activity that conflict with the Group’s interest. When a conflict of interest, whether actual or potential occur and confront the employee in performing his duties, the employee must disclose its existence promptly to the Human Resource and Administration Group and abstain from participating in any discussion or decision-making processes related to the matter in which they have a conflict of interest.
Integrity and Accuracy of Records/Transactions
- All transactions, contracts, assets, liabilities, revenues and expenses of the Group must be recorded in such form and for such period as determined by the Group. Employees shall never make entries or allow entries to be made, altered or deleted, for any account, record or document of the Group that would obscure the true nature of the transactions as well as mislead the true authorization limits or approval by relevant authority of such transaction.
- Employees should also report to their superior in the event of discovery of any unauthorized copying, entries, deletions or alterations in the Group’s records.
Insider Trading
- Insider trading or dealing is the purchase or sale of a company’s listed entity securities effected by or on behalf of a person with knowledge of relevant but non-public information regarding the Group that may affect the price of the securities (price sensitive information) if made public. Insider trading undermines fair markets and is both unethical and illegal.
- Employees with access to confidential or material non-public information about the Group are prohibited from trading securities based on this information. Employees are also barred from sharing this information with others who might use it to gain a financial advantage.
Gift & Entertainment Policy
- To prevent undue influence on business decisions, employees are prohibited from giving or receiving gifts or entertainment that are, or appear to be, inappropriate, frequent, or excessive, considering all relevant facts and circumstances. However, exceptional consideration may be granted for specific circumstances to satisfy the Key Principles outlined in the Policy of Gift and Entertainment (COM POL-PGE-A01).
Confidentiality and Data Privacy
- All employees are responsible for protecting and maintaining the confidentiality of sensitive information they encounter in their roles. This includes, but is not limited to, customer data, employee records, financial data, trade secrets, and proprietary business information. Unauthorized access, sharing, or misuse of such information is strictly prohibited and could result in serious legal and disciplinary consequences.
- The Group values customer trust and is committed to upholding data privacy laws and standards. Employees are expected to implement measures that ensure data security and promptly report any breach of confidentiality or privacy to Risk Management Department.
Misuse of Position
- Employees must not misuse their position in the Group to influence other employees, current and potential customers or business partners of the Group to act in their personal interest or for the interest of anyone else.
Use of Group’s Assets
- All assets owned by the Group, including physical property, information technology, and intellectual property, must be used responsibly and for the Group’s legitimate business purposes only.
- Employees are expected to safeguard the assets from loss, theft, damage, or misuse, and to prevent unauthorized access or use by third parties. Misusing the Group’s resources for personal gain or other improper purposes is strictly prohibited.
- Employees are also reminded that Group assets include proprietary information are to be treated with the same respect and caution as tangible assets.
Use of Social Media
- Employees are required to be mindful and not post any content personally or on behalf of the Group that is likely to provoke, attack, defame or offend any fellow colleagues, the Group and its customers/business partners that would adversely affect the image and reputation of the Group.
Making Public Statement
- All requests for public statements intended for use in broadcasts, newspapers, magazines, or any other media related to affairs of the Group must be referred to the Corporate Communications Department. This is to ensure that the information is accurately and appropriately communicated. Only designated spokespeople or individuals designated by Corporate Communication Department are authorized to make public statements on behalf of the Group.
- If an employee wishes to seek permission to publish or write a book or article based on official information, or use the Company logo, they must obtain prior approval from the Corporate Communications Department and relevant personnel or department as outlined in the Approval Matrix.
External Training/Guest Speaker/Author
- Employees may accept invitations to conduct external training, give talks, or participate in seminars, symposiums, or similar events, provided that prior written approval is obtained from their Head of Division and Head of Human Resources & Admin Group. Any fees or emoluments received for such services must be paid to the Group.
Whistle Blowing
- The Group encourages employees to report any known or suspected violations of Group’s policies, or applicable laws. Whistleblowers may report anonymously, and the Group ensures that there will be no retaliation or adverse action taken against individuals who report in good faith.
- Reports of violations can be submitted through designated whistleblowing channels. All reports will be fairly and thoroughly investigated, and appropriate corrective action will be taken as necessary, ensuring transparency and accountability in all aspects of operations.
Workplace Health and Safety
- The Group is dedicated to ensuring a healthy and safe workplace environment for all its employees. The Policy of Occupational Safety and Health (ADM-OSH-A01) underscores the significance of maintaining a safe and conducive working environment, while also ensuring compliance with relevant legislation and industry standards.
- Moreover, the Group strictly prohibits any behavior that humiliates or intimidates others, which may be deemed inappropriate or create a hostile work environment based on, but not limited to, a person’s race, gender, religion, marital status, and other factors.
b) Valued Customers
Basic Principles
- The Group strive to offer relevant financial products and services that can be easily accessed by customers to enrich their daily lives. All dealings with existing and prospective customers of the Group must be handled fairly, with integrity, and high ethical standards. This commitment is embedded in our corporate culture, ensuring that customers are protected from unfair practices and provided with clear, timely information to make informed decisions. Employees exercise due care and diligence, offering suitable advice tailored to customers’ needs, and addressing complaints promptly and effectively.
Acting with Integrity, Professionalism and Diligence
- All employees, including agency employees must conduct themselves with due care, fidelity and diligence while performing their duties towards customers. Communication with customers must be transparent and honest in the provision of information about a product and / or service, including its features, risks and rewards.
Dealings or Transactions on Customers’ Accounts or Repayments
- Any dealings or transactions on customers’ behalf or accounts must be conducted with customers’ instruction based on the requirements stipulated in Group policies and procedures.
- No employee may perform any dealing or transaction without the customer’s consent or authorisation. Misappropriation of customer’s funds is a serious violation of the trust and confidence placed in us as custodians of their money.
Handling Customer Complaints
- The Group value customers’ opinions, requests, and complaints as essential inputs for management decisions. Therefore, all complaints, disputes, or dissatisfaction regarding the Group’s products and services must be addressed fairly and promptly.
- A customer complaint should be handled by a qualified and experienced individual, ensuring they are not personally involved in the complaint.
- In the event of a complaint of a severe or unusual nature that may impact the Group’s reputation, it must be immediately escalated to the attention of the Risk Management Department or the respective Division Head.
c) Trusted Business Partners
Basic Principles
- The Group respect innovative partners who help the Group achieve its purpose by bringing “finance” closer to everyone. The Group maintain equality with all business partners and ensure our connections are formalized through formal agreements based on integrity and contractual compliance.
Objective and Fair Evaluation in Procurement
- Employees shall comply with all relevant Group policies and procedures, ensuring transparent vendor selection and evaluation processes.
d) Dedicated Employees
Basic Principles
- All interactions with the Group’s dedicated employees must align with the core values outlined in the AEON Foundational Ideas and Our Purpose. This includes fostering a work environment that upholds human rights. Every employee is expected to conduct themselves professionally, treat all members of the Group with the highest respect without any discrimination, and maintain clear and appropriate communication with one another.
Diversity and Non-Discrimination
- The Group values diversity and aims to provide an inclusive work environment where all individuals are treated with respect, dignity, and fairness. Discrimination or harassment based on gender, race, religion, age, disability, or any other characteristic is not tolerated.
Equality
- The Group is dedicated to providing equal opportunities in hiring, promotion, and other employment decisions. The Group ensure that all individuals have the chance to succeed based on their merits and qualifications.
Competence and Adequate Skill
- Employees must continually strive to improve their competence and skills ensuring their knowledge remains up-to-date.
- All employees must attend all mandatory training programs as defined by the Group within the specified timeframe, whether via e-learning platforms or physical training conducted internally or externally. At the same time, superiors are expected to provide training and guidance to ensure subordinates understand and adhere to the right conduct guided by the Code.
Employee Discipline
- Employees are expected to adhere to the highest standards of professional conduct. This includes, but is not limited to, honesty, integrity, respect for others, and compliance with Group’s policies and procedures.
- Any breach of conduct may result in disciplinary action, ranging from verbal warnings to termination of employment, depending on the severity of the violation.
e) Regulatory Bodies
Basic Principles
- The Group shall engage with regulators in a responsive, open and cooperative manner.
Compliance
- It is the responsibility of the Group and all employees for maintaining a transparent, cooperative, and responsive relationship with all regulatory bodies. All interactions with regulators must be conducted with integrity and in full compliance with applicable laws and regulations to mitigate risks of non-compliance.
Regulatory Reporting
- The Group is committed to provide accurate and timely information to regulators at all times, including during inquiries and audits. All employees must fully cooperate with relevant regulators and adhere to all regulatory requirements and guidelines.
- Additionally, employees must promptly report any regulatory concerns or potential violations to the Compliance Department without delay.
Strict Adherence to Regulator Policies
- Employees must strictly adhere to the Group’s Policy on Anti-Money Laundering, Countering the Financing of Terrorism, Countering Proliferation Financing, and Targeted Financial Sanctions (COM POL-AML-A01). This policy is established to prevent, detect, and report any suspicious activities related to money laundering.
- All employees must avoid engaging, directly or indirectly, in any transactions that may involve proceeds from unlawful activities. This includes conducting thorough due diligence on customers, monitoring transactions for unusual or suspicious activity, and promptly reporting any concerns to Compliance Department.
f) Local Community
Basic Principles
- The Group shall foster collaborative and positive community relations and being a responsible and ethical neighbour to the communities in which the Group operate.
Social Responsibility
- The Group treat local communities with respect in all interactions and prevent all actions that may harm the community’s well-being or culture heritage.
Environmental Stewardship
- The Group is committed to minimize the environmental impact of operations on local communities by fulfilling the Sustainable Development Goals (SDGs) and promote sustainable practices.
Cultural Sensitivity
- The Group respect and preserve the cultural heritage and traditions of local communities by avoiding actions that may disrupt or disrespect local customs and practices.
