Integrity is one of SAM’s core values and the group is committed to high standards of corporate governance and accountability.

Code of Conduct

SAM is committed to promoting good business conduct and maintaining a healthy corporate culture that reflects the Core Values of SAM.




A conflict of interest exists when a Personnel, through his/her position, enables him/her to obtain an improper gain or advantage, and such gain or advantage adversely affects the Group’s interest.


All Personnel are expected to exercise prudent judgment to avoid conflicts of interest.


If an actual or potential conflict of interest arises, the affected Personnel must notify the relevant Head of Company or the Human Resource Department in writing immediately upon becoming aware of such conflict, whether real or perceived.


As an illustration, the affected Personnel must notify the relevant Head of Company or the Human Resource Department if his/her family member has any business dealings with the Group.




SAM takes a zero-tolerance approach towards bribery and corruption.


All Personnel are strictly prohibited from accepting or soliciting any bribe from, or offering any bribe to customers, suppliers or competitors (or any person affiliated with such customer, supplier or competitor).


Please report any bribery or corrupt practice or a real and genuine suspicion of such bribery or corrupt practice via the Whistleblower Hotline.


Any incident relating to accepting, soliciting, giving or offering any bribe will be dealt with under applicable laws and regulations.




As a general rule, all Personnel are discouraged from giving to or accepting from customers, suppliers or competitors (or any person affiliated with such customer, supplier or competitor) any gifts, personal favours, entertainment or other benefits that may in any way influence or appear to influence the Personnel’s professional judgment in the discharge of his/her duty to the Group.


However, the Group recognizes that it is a legitimate custom and/or practice and/or courtesy in business relationships to accept or offer modest gifts or entertainment (i.e., dinners, luncheons and refreshments of reasonable cost).


In the event that Personnel has received a gift, under such circumstances that makes it impossible, difficult or impractical to reject such a gift, the affected Personnel should as soon as possible notify and submit the gift to the Human Resource Department or his/her Manager or the relevant Head of Company who shall then notify the Chief Executive Officer of the Company.


Only the Chief Executive Officer can decide whether the affected Personnel may keep the gift. Gifts of cash or cash equivalents (i.e., gift certificates, securities and similar) of any amount are strictly prohibited.




Any person who engages in a transaction that involves proceeds of an unlawful activity, or receives or disposes of proceeds of an unlawful activity or conceals the true origin of proceeds of an unlawful activity, commits a money laundering offence.


All Personnel are prohibited from attempting or participating in any money laundering activities.


Personnel are encouraged to report any money laundering incidents, or a real and genuine suspicion of money laundering incidents via the Whistleblower Hotline.




SAM is committed to ensure compliance with all relevant laws, rules and regulations of the country where it conducts its business.

Whistle Blowing

All Personnel of the SAM Group are expected to observe high standards of ethics, honesty and integrity; and are required to comply with all relevant laws and regulations applicable to their work.


If you know of any misconduct, report it via the Whistleblower Hotline. This hotline allows you to whistleblow responsibly without fear or harassment, discrimination and/or retaliatory action with the assurance that your report will be taken seriously and investigated.


Examples of misconduct include the following:


  • concerns about the SAM Group’s accounting, internal controls or audit matters;
  • intentional misinterpretation affecting the financial statement or records of the SAM Group;
  • all forms of malpractices or impropriety such as unethical behaviour, misconduct, fraud, corruption, bribery or theft;
  • breach of law;
  • breach of the SAM Group’s policies or code of conduct;
  • conflict of interest;
  • actions that are detrimental to the health and/or safety of the environment;
  • any forms of discrimination;
  • harassment, abuse and/or misrepresentation of power and authority;
  • false and/or misleading statements to any authority;
  • instructions to deliberately conceal any of the information above; or
  • any other improper conduct that may cause significant loss and/or damage to the SAM Group’s reputation.


You can access the SAM Whistleblowing Policy here.


SAM Engineering & Equipment (M) Berhad (“SAMEE“) has its own whistleblowing portal. For all matters pertaining SAMEE and its group of companies, please whistleblow directly at their whistleblowing portal.

Making a Report

Please note that the Hotline is hosted on a third-party website and your access and use of the third-party website or other facility provided by the service provider is subject to the terms and conditions associated with it. 


If you wish to make a report on the Hotline, please click “I agree” to indicate your consent for SAM Group and/or our service-providers to:- 


  1. collect, use, transfer, store or otherwise process information that may be linked to specific individuals (“Personal Data”) in order to   report, assess, investigate and make a determination with respect to matters on which a report is made on the Hotline (“Purpose”); 
  2. disclose and/or transfer (including across borders), your Personal Data to SAM and/or our service-providers for the Purpose.