Code of Conduct

This Supplier Code of Conduct (the "Code") defines the minimum standards of business conduct and practice expected of all suppliers, vendors, contractors, consultants, agents, and any other third parties, including their employees and subcontractors, who provide goods or services to Media Prima Berhad and its subsidiary companies (the "Group" or "MPB"). Compliance with this Code is a mandatory, contractual condition for conducting business with the Group. Where the standards set forth in this Code are stricter than applicable local laws and regulations, suppliers are expected to adhere to these higher standards.

MPB is committed to legal compliance and ethical business practices in all its operations and seeks to do business with suppliers who share that commitment. This Code is not merely a set of rules but the foundation for a collaborative partnership built on the shared values of integrity, transparency, accountability, and sustainability. We believe that a responsible supply chain is essential to our long-term success and our role as a responsible corporate citizen. We are committed to working with our suppliers to uphold these principles and continuously improve performance throughout our value chain.

MPB upholds a zero-tolerance approach to all forms of bribery and corruption. Suppliers must share this commitment in all their dealings with or on behalf of the Group.

• Zero-Tolerance Stance: Suppliers are strictly prohibited from engaging in, either directly or indirectly, any form of bribery, corruption, extortion, or embezzlement.
• Prohibited Conduct: Suppliers must not offer, give, solicit, or accept any form of "gratification," as defined by the Malaysian Anti-Corruption Commission (MACC) Act. This includes, but is not limited to, money, gifts, loans, fees, rewards, or any other improper advantage to or from any person, including MPB employees or public officials, to obtain or retain a business advantage.
• Facilitation Payments: Facilitation payments—small payments made to secure or expedite a routine government action—are a form of bribery and are strictly prohibited. The only exception is in circumstances where there is a credible threat to an individual's life, health, or safety. Any such payment must be immediately and accurately reported to MPB Group Corporate Governance.
• Dealing with Public Officials: Extreme caution must be exercised when dealing with public officials. Providing any gift, entertainment, or hospitality to a public official or their family members is a high-risk activity and may be perceived as bribery. Suppliers must comply with all local laws and ensure that any interaction is transparent, properly documented, and does not create any perception of impropriety.

To avoid conflicts of interest or the appearance of impropriety, suppliers must respect MPB's internal policies on business courtesies.

• 'No Gift' Policy: MPB maintains a 'No Gift Policy'. Suppliers and their representatives must not offer or provide gifts, lavish entertainment, or other business courtesies to MPB employees or their family members with the intent to influence a business decision or gain an unfair advantage. MPB employees are instructed to politely decline such offers.
• Permissible Exceptions: The only exceptions are infrequent and modest token items of nominal value, such as corporate-branded promotional materials (e.g., pens, diaries), which cannot be construed as an attempt to influence business decisions. Cash or cash equivalents (e.g., gift cards, vouchers) are never permissible.

Suppliers must conduct their business in full compliance with all applicable antitrust and fair competition laws. They are prohibited from engaging in anti-competitive practices such as price-fixing, bid-rigging, market allocation, or the exchange of sensitive competitive information.

Suppliers must avoid all conflicts of interest or situations that could be perceived as such. Suppliers are required to proactively and immediately disclose to MPB any actual or potential conflict of interest. This includes any personal, financial, or family relationship between the supplier's personnel and any MPB employee that could influence business dealings.

• Confidentiality: Suppliers must safeguard MPB's confidential information and intellectual property and are prohibited from disclosing it without prior written authorization.
• Personal Data Protection: Any supplier that collects, stores, processes, or has access to personal data on behalf of MPB must comply strictly with MPB's Personal Data Protection Notice (Personal Data Protection Notice | Media Prima Berhad) and all applicable data protection laws, including the Personal Data Protection Act 2010 of Malaysia. Suppliers must implement and maintain appropriate technical and organizational security measures to protect such data from unauthorized access, use, or disclosure.

Suppliers are required to maintain accurate and transparent financial books and business records that reflect all transactions related to their business with MPB. The creation of false, misleading, or artificial entries is strictly prohibited.

Suppliers shall not use any form of forced, bonded, indentured, or involuntary prison labor. All work must be voluntary, and workers shall be free to terminate their employment upon reasonable notice. The use of human trafficking is prohibited, and suppliers shall not withhold workers' government-issued identification, passports, or work permits as a condition of employment.

Suppliers shall not employ children. The minimum age for employment shall be the higher of: (i) 15 years of age (or 14 where permitted by local law in accordance with ILO Convention 138), (ii) the age for completing compulsory education, or (iii) the legal minimum age for employment in the country of operation.

Suppliers must ensure that compensation paid to workers complies with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits. All overtime must be voluntary. Working hours must not exceed the maximum set by local law, and workers should be provided with their statutory rights to rest periods, leave, and public holidays.

Suppliers shall foster a workplace free from harassment and unlawful discrimination. Suppliers are expected to provide equal employment opportunities, and all employment decisions—including hiring, compensation, promotion, and termination—must be based on merit, skills, and performance, not on personal characteristics such as race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, or union membership.

The workplace must be free of harsh and inhumane treatment. Suppliers shall not permit or engage in sexual harassment, corporal punishment, mental or physical coercion, or verbal abuse of workers.

In accordance with local law, suppliers shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly, as well as respect the right of workers to refrain from such activities.

Suppliers must comply with all applicable workplace health and safety laws and regulations. They shall implement procedures and controls to identify, assess, and manage occupational health and safety hazards. This includes providing workers with appropriate personal protective equipment (PPE) at no cost and ensuring access to clean toilet facilities, potable water, and sanitary food preparation and storage facilities.

Suppliers must identify and assess potential emergency situations and events and implement emergency plans and response procedures. These procedures should include emergency reporting, employee notification and evacuation procedures, worker training, and appropriate fire detection and suppression equipment.

Suppliers must comply with all applicable environmental laws, regulations, and standards. They must obtain, maintain, and keep current all required environmental permits, approvals, and registrations.

Suppliers are encouraged to reduce the consumption of resources, including energy and water. Suppliers must establish a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste. All hazardous waste must be handled, stored, and disposed of in an environmentally safe manner.

Suppliers must monitor, control, and treat air emissions generated from their operations as required by applicable laws. Suppliers are encouraged to implement measures to reduce their overall greenhouse gas emissions and carbon footprint.

Suppliers are encouraged to source materials responsibly to minimize negative environmental and social impacts. This includes efforts to avoid materials that contribute to deforestation, biodiversity loss, or human rights violations in their extraction or production.

Suppliers should provide an accessible mechanism for their employees to report grievances or suspected violations of this Code, policies, or the law, without fear of retaliation or reprisal. This approach is consistent with MPB's own Whistleblowing Policy, which promotes secure and responsible disclosure.

MPB reserves the right to verify a supplier's compliance with this Code through mechanisms such as self-assessments, audits, or inspections. If a violation of this Code is identified, the supplier will be expected to develop and implement a timely and effective corrective action plan. Failure to comply with this Code or to address identified violations may result in the re-evaluation of the business relationship, up to and including termination.

As a condition of doing business with the Group, each supplier must acknowledge and agree to comply with this Code. Please confirm your agreement with all of the foregoing by having an authorized representative sign in the space below.