Code of Conduct

The Code of Business Conduct (the “Code”) applies to all employees. It describes the professional and ethical responsibilities all Serpent Group of companies’ employees are expected to uphold, and provide basic guidelines for conducting business on behalf of Serpent Group of companies .


Confidentiality

It is our duty to ensure their information are kept “Confidential”. This information shall not be disclosed to any external parties or to staff without the “need to know.” Our customers’ personal information would include but not limited to personal particulars, credit card information, invoices, accounting information, business information, history and etc.


Staff should seek clarifications from their supervisors if he/she is not sure. Disclosures to third parties will be made only in accordance with applicable law or company policy. Staff is required to sign a Proprietary Information Agreement with the Company. The purpose of this policy is to protect the Company’s valuable business and proprietary information from unauthorized disclosure or access.


Employees are required to maintain confidentiality of all proprietary information and materials which is made known to or access during the course of employment and shall not, at any time during employment or after the employment with the Group, use such information without authorization or communicate them directly or indirectly to any unauthorized person, or retain in possession or control any document, note or information of confidential nature (after termination of employment). Proprietary information shall include, without limitation, information, written or otherwise in computerized nature, pertaining to the Company’s turnover, financial affairs, business plans, products’ formulae, patents, trade secrets, processes, procedures and etc.


In the course of employment, staff involved in projects undertaken by the Company in collaboration with third parties shall, if required, execute confidentiality agreements whether in respect of such projects or otherwise in such form and on such terms as may be determined by the Group.


Employees shall refrain from revealing/discussing their salaries, bonuses and other confidential employment matters such as, but not limited to, Company’s turnover, financial affairs, business plans, products’ formulae, patents, trade secrets, processes, procedures and etc with their fellow colleagues and third parties who do not have any participations rights or involvement.


A breach of this provision shall constitute a breach of confidentiality and may result in disciplinary procedure taken against the relevant employee.



Non-Competition/Non – Solicitation

Due to the nature of the Company’s business and staff access to the Company’s proprietary information and trade secrets, staff is required to sign a Non competition Agreement. Staff will be subjected to the provisions stated in the non-competition/ solicitation declaration.


Employees shall not during and at any time for the period of thirty-six (36) months after termination of employment (“Non-Solicitation Period”) either on his/her own account or in conjunction with or on behalf of any person, firm or company, solicit or entice away or attempt to solicit or entice away from the Company the customer or any person, firm, company or organization who shall at any time within one year prior to the date of termination of his/her employment have been a customer or client or in the habit of dealing with the Company and/or whom he/she have had significant contact with in the course of his/her employment.


An employee shall not during the Non-Solicitation Period either for his/her own account or as representative or agent for any third party, persuade, induce, encourage or procure any staff currently in employment by the Group or whose employment with the Group was terminated within the previous year to become employed by or interested directly or indirectly in any manner in any business which is in competition with the business carried on by the Group or terminate his employment with the Group.


An employee shall not during and at any time for the period of twelve (12) months after termination of employment (“Non–Compete Period”) do or permit any of the following to be done without the prior written consent of the Company:-


a. Directly or indirectly (whether solely or jointly with or on behalf of any person, firm or corporation or otherwise) carry on or be engaged or interested in any capacity in any other business, trade or occupation whatsoever which competes with the business or proposed

business being carried on by the Company; or


b. Assist any person, firm or company with advice and/or information in relation to any activity or business which shall be in competition with the business or proposed business of the Company; or


c. Cause or permit any person or company directly or indirectly under his/her control or in which he/she have a controlling or beneficial interest to do any of the foregoing acts or things. Notwithstanding the above, the employee shall be entitled to enter into employment with any other related corporation of the Company, unless he/she left on disciplinary grounds. However he/she shall still maintains the confidentiality of information as spelled out in the above-mentioned paragraphs.