Preamble
We at SPMLTechnologies have a consistent commitment to the
philosophy of transparency, adequate disclosure and fairness
to all and independent monitoring & supervision in the
conduct of the business operation.
Corporate
Business Opportunities
In carrying out their duties and responsibilities, the directors
and the Senior Management Personnel are prohibited from:
Appropriating corporate business opportunities for themselves
that are discovered through the use of Company resources or
information or their position as directors or employees; and
Competing with the Company, directly or indirectly, except
with the permission of the Board of Directors.
A corporate business opportunity is an opportunity (1) which
is in the Company’s line of business or proposed expansion,
(2) which the Company is financially able to undertake and
(3) which may be of interest to the Company.
Legal
Compliance
In carrying out their duties and responsibilities, the Board
Members and the Senior Management Personnel must comply with
applicable codes, laws, rules regulations and statutes.

Gifts
and Donations
The Board Members and the Senior Management Personnel shall
neither receive nor offer or make, directly or indirectly,
any illegal payments, remuneration, gifts, donations or comparable
benefits that are intended to, or perceived to obtain business
or uncompetitive favors for the conduct of its business. However,
they may accept and offer nominal gifts which are customarily
given and are of commemorative nature for special events.
Avoiding
of conflict of interest
The Board Members and the Senior Management Personnel shall
not engage in any business, relationship or activity which
might detrimentally conflict with the interest of the Company
or the Group. A conflict of interest occurs when the personal
and/or external business interest of the Board Members and
the Senior Management Personnel interferes or may interfere
with the interest of the Company. Conflicts, if any or potential
conflict must be disclosed to higher management for guidance
and action as appropriate.
All directors and senior management personnel shall ensure
that in their dealings with suppliers and customers, the Company’s
interests are never compromised. Acceptance of gifts, donations,
hospitality and/or entertainment beyond the customary level
from existing or potential suppliers, customers or other third
parties which have business dealings with the company will
be viewed as serious breach of discipline as this could lead
to compromising the Company’s interests.

Proctection
Company Assets
In carrying out their duties and responsibilities, the Board
Members and the Senior Management Personnel shall ensure that
they use the Company's assets, properties, information and
intellectual rights for legitimate official purpose only or
as per the terms of their appointment.
Company
Facilities
No director and senior management personnel shall misuse Company
facilities. In the use of Company facilities, care shall be
exercised to ensure that costs are reasonable and there is
no wastage.
Health,
Safety and Envirnoment
The Company attaches great importance to a healthy and safe
work environment and is committed to provide good physical
working conditions and encourages high standards of hygiene
and housekeeping. The company shall be committed to prevent
the wasteful use of natural resources and minimise any hazardous
impact of the development, production, use and disposal of
any of its products and services on the ecological environment.
No
Rights Created
This Code sets forth guidelines for conduct of the senior
management officers and directors of the Company. This Code
is not an expressed or implied contract.
