Terms: Code of Business Conduct and Ethics

Code of Business Conduct and Ethics

Aztech Group is managed by a team of dedicated and resourceful employees. Aztech offers electronics manufacturing services including design, materials management, logistics services and customer programme management. Our company is committed to operating all activities within the laws and regulations affecting its businesses and employees.

Aztech’s vision is delighting people with smarter solutions.

Aztech’s mission is to be a one-stop integrated solutions provider, working alongside their clients to achieve their goals and aspirations to produce innovative products and solutions.

Aztech’s values are values that encapsulate the culture that Aztech desires to build:

  • Integrity is doing the right thing even when it is not easy
  • Commitment is to transform a promise into a reality
  • The pursuit of Excellence is a wholehearted endeavour

Aztech promises to deliver value beyond expectations. Empowering brand owners to achieve their product aspirations.


This Code provides guidance in resolving any ethical issues that one may encounter in conducting business and sets out the standards of behaviour expected of all employees in line with Aztech’s vision, mission, values and promises.


The Code applies to the Directors, Management, Employees, Subsidiaries and all Business Partners of Aztech.

If a local law conflicts with a policy in the Code, one must comply with the local law. If a local custom or practice conflicts with a policy in the Code, one must comply with the Code.

This Code shall by no means be exhaustive nor does it include all of the policies of Aztech. The Code provides general guidance for resolving a variety of legal and ethical issues for us. We are also expected to comply with other applicable policies, procedures, guidelines, directives, rules and practices issued by Aztech and apply sound judgment in deciding on ethical means of dealing in any given situation involving Customers, Business Partners, competitors, regulators, public and Aztech matters in general and ask for help when needed.

This Code may be reviewed, changed and updated from time to time.

The latest version of the Code is available on Aztech’s Intranet Portal.

Responsibility & Compliance to The Code

It is the responsibility of every employee to act as per the policies, principles and guidelines detailed in this Code, and any update or amendment which may be issued from time to time by Aztech. It is also the employee’s responsibility to report violations or suspected violations of this Code and support the implementation of this Code. Any violation or suspected violation of this Code shall be reported to the Chief Executive Officer (CEO) (in the case of any Director) or the Senior Vice President (SVP) of Legal (in all other cases) or such other officer designated by the Company from time to time or email to whistleblower@aztech.com

Non-compliance with this Code will be treated seriously and may result in disciplinary action, including the possibility of suspension or dismissal, and if warranted, legal proceedings against the employee. Violation of applicable laws may subject the employee to civil and/or criminal penalties imposed by a governmental agency or a court, in addition to disciplinary action.

This Code is to be read and applied in conjunction with all other related or applicable policies, procedures and guidelines which are published in the Aztech Intranet Portal.

Code of Conduct & Ethics

The following code of conduct and ethics applies to all full time and part-time employees:


1) Data Integrity, Privacy & Protection

Aztech must comply with its Personal Data Protection Policy


2) Ethics

a) Accepting and Providing Gifts and Other Benefits

    • All benefits and gifts received are to be declared to the Human Resource Department
    • The practice of giving business gifts and taking part in corporate entertainment varies between countries, regions and industries as one may not be normal and acceptable in another
    • Employees are to bear in mind that what may viewed as small or insignificant in one country can be significant in another
    • Giving of gifts and corporate hospitality or entertainment is not prohibited if it is not done with the intention of influencing others, obtaining or retaining a business advantage,  if it is given openly and not offered to public officials and if it complies with any applicable laws.

b) Business Integrity

    • Aztech will engage in a dialogue with our competitors when there is a legitimate business reason to do so
    • Aztech will not exchange information with or enter into agreements with a third party in a way that improperly influences its activity
    • Aztech shall comply with prevailing competition/anti-trust laws in the countries in operates in

c) Bribery & Corruption

    • Aztech is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever it operates and in implementing and enforcing effective sytems to counter bribery and corruption.
    • Employees shall not offer, give, solicit or accept any bribes in order to achieve any business or personal advantage for themselves or others or engage in any transaction that contravene any applicable anti-bribery or anti-corruption laws .

d) Complaints & Whistle-blower

    • Aztech shall ensure the confidentiality and protection of the identity of any whistle-blower
    • Aztech shall ensure complaints are to be taken seriously

e) Intellectual Property

    • Employees must not remove Aztech physical assets or properties from its premises without permission from Aztech or use such assets or property for any inappropriate purpose

f) Money Laundering

    • Employees shall ensure that they conduct business with reputable customers for legitimate business purposes and with legitimate funds
    • Employees shall report to their immediate supervisor should they suspect any money laundering activities

g) Providing Information

Employees shall:

    • Communicate information accurately, effectively and in a proper manner
    • Comply with the statutory and regulatory requirements relating to confidentiality of information
    • Disclose information regarding business in accordance with applicable regulations and industry practices
    • Not falsify and/or misrepresent any information
    • Protect Aztech’s confidential information and guard them against unauthorized disclosure or use
    • Protect confidential information of third parties which they have access to in the course of their work
    • Not disclose confidential information for any unauthorised purpose

h) Research & Development

Employees shall:

    • Comply with the statutory and regulatory requirements relating to research and development
    • Ensure that information from research is recorded and stored in a way that complies with applicable data protection laws and enables accurate and transparent reporting
    • Ensure that the research proposal is ethically and scientifically reviewed in line with current laws and regulations and that all relevant internal review and approval procedures are followed


3) Environment Protection & Management

  1. Aztech actively participating in energy saving and waste reduction programmes
  2. Aztech continuously seeks to improve the sustainability of our activities by economising on our use of non-renewable energy and raw minerals, minimising the amount of waste we generate and minimising any adverse environmental impact associated with our products
  3. Aztech is committed to minimising any adverse environmental effects from our activities and products while working to reduce our consumption of natural resources and operating in an environmentally sustainable manner
  4. Aztech will endeavour to identify, mitigate and monitor existing and emerging risks to the environment associated with our business activities


4) Labour and Human Rights

a) Employment

    • Aztech complies with all related laws in its employment decisions
    • Every term of a contract between the Aztech and its employees are consensual
    • Aztech does not provide a contract of service to a person below the age of 18 years

b) Human Rights

    • Aztech is committed to upholding the human rights of its employees and treating its employees with dignity and respect
    • Aztech supports the U.N. Guiding Principles for Human Rights

c) Equal Opportunity & Non-Discrimination

    • Aztech treats its employees and job applicants fairly and does not engage in any form of unlawful discrimination. Aztech provides equal opportunities based on merit, qualification and the ability to perform the relevant duties
    • Aztech is committed to ensuring that no individuals receive less than favourable treatment or are discriminated against based on age, citizenship, colour, disability, gender identity, marital status, nationality, race, religion, sexual orientation or any other legally protected factor
    • Aztech aims to provide a work environment that fosters fairness and respect for social and cultural diversity that is free from unlawful discrimination determined by current and future legislation

d) Salary

    • Aztech is committed to fair pay and transparent compensation principles

e) Working Hours

    • Working hours must comply with national laws or Collective Agreement
    • Working hours, excluding overtime, shall be defined by contract, and shall not exceed local Employment Regulation
    • Every employee is allowed to have a rest day in each week without pay of one whole day which shall be Sunday or such other day as agreed


5) Management System

a) Company’s Commitment

    • Aztech strives to comply with all prevailing statutory, company policies and regulatory requirements
    • Aztech encourages employees to improve efficiency and enhance the competitive position of Aztech

b) Communication

    • Aztech has established, implemented and maintained a procedure for internal communication links between various levels and published in Aztech Intranet Portal.

c) Control of Documents

    • Records are established and maintained to provide evidence of conformity to requirements and effective operation

d) Employee’s Feedback

    • Aztech will obtain employee’s feedback and improve on this policy

e) Legal & Regulation Requirements

    • Aztech shall establish, implement and maintain procedures to identify and track legal and regulatory requirements
    • Keep track of changes in legal regulatory requirements
    • Communicate the applicable legal requirements to relevant departments

f) Operational Control

    • Identify operations and activities that are associated with identified risk where control measures need to be applied
    • Establish, implement and maintain documented procedures related to goods, equipment and services
    • Establish, implement and maintain procedures for workplace processes such as the installation and operation, of machinery
    • Stipulate operating criteria in the procedures

g) Training

    • Training on this policy forms part of the induction process for all new employees.
    • All existing employees will receive regular, relevant training on how to implement and adhere to this policy


6) Workplace Culture

a) Alcohol, Drugs & Prohibited Substances

    • Employees are expected to perform their duties free from the influence of any substance that could impair their job performance or pose an unacceptable safety risk to them and others working around them
    • Aztech prohibits working under the influence of alcohol, illegal drug and controlled substance in the premises
    • Aztech prohibits the distribution, possession and sale of alcohol, illegal drug and controlled substance in the premises

b) Harassment, Threat & Violence

    • Aztech seeks to provide a safe work environment where employees are treated with respect and free from any form of harassment, threat, intimidation, violence and any other inappropriate behaviour
    • Each employee is responsible for reporting any harassment, threat, intimidation, violence and any other inappropriate behaviour which he/she is subjected to, a witness of, or has any knowledge of


7) Workplace Safety & Health

a) Aztech will protect the safety and health of our employees by:

    • Conducting a risk assessment to identify hazards and implement effective risk control measures
    • Complying with the relevant statutory and regulatory requirements
    • Ensuring workers are provided with sufficient instruction, training and supervision so that they can work safely
    • Developing and implementing systems for dealing with emergencies
    • Making sure the work environment is safe
    • Making sure adequate safety measures are taken for any machinery, equipment, plant, article or process used at the workplace
    • Supporting policies that contribute towards safety and health and ensuring that these policies are integrated into the workplace

b) The employees must:

    • Follow the workplace safety and health system, safe work procedure and safety rules implemented at the workplace
    • Not engage in any unsafe or negligent act that may endanger themselves or others working around them
    • Use personal protective equipment provided to themto ensure their safety while working
    • Not tamper with or misuse any workplace equipment

c) Emergency Preparedness & Response

    • Aztech is to prepare, manage and execute a systematic Emergency Response Plan where necessary
    • Aztech is to ensure that emergencies are identified and prevention and response procedures are established and maintained
    • Emergency Response Team shall remain alert and accessible at all times and respond promptly when a situation requiring their action arises
    • Employees are personally responsible for familiarising themselves with and adhering to Aztech’s emergency response procedures


8) Conflict of Interest

  1. Employees must act in the best interest of Aztech at all times
  2. Employees are expected to avoid personal activates and financial interest which could cause conflict a conflict of interest with respect to their responsibilities to Aztech
  3. Employees must not misuse their position for their own personal gain
  4. In the event the employee thinks that they have an actual or potential conflict of interest, they must immediately disclose the conflict of interest to their immediate supervisor who will determine the best way to manage the situation


Any failure to comply with the code, policies or the law and regulations of the country in which the employee is in will result in the appropriate action and investigation taken against  the employee by Aztech or relevant government authorities.

How To Raise A Concern

All employees are encouraged to raise concerns about any issue or suspicion of malpractice in accordance with this policy at the earliest possible stage. If you have any other queries, it should be raised with the SVP of Legal or email to whistleblower @aztech.com.

Aztech values the help of employees who identify concerns and potential violations of the Code of Business conduct and ethics, laws or regulations.  Aztech probibits any threats, reprisals or retaliation of any kind against anyone who reports, in good faith, an actual or suspected violation of the law, the Code of Business conduct and ethics, or our other policies, or who cooperates or assists in an investigation related to reported violations.  Aztech reserves the right to discipline employees who knowingly provide false information or make false accusations.

Monitoring & Review

The SVP of Legal will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that this Policy is effective.

The SVP of Legal will report regularly on compliance with this policy to the CEO.

All Representatives are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the SVP of Legal.

This policy will be reviewed periodically by the Company and may be amended at any time. Employees, officers and directors will be fully informed of any material revisions to this policy.