Business Code of Conduct

BUSINESS CODE OF CONDUCT FOR EMPLOYEES 2020

I. AVOIDING AND HANDLING CONFLICTS OF INTEREST

  1. Business Code of Conduct

Avoid any conflict between your own personal interests and the interests of MM Mega Market (Vietnam) Company Limited. In terms of business relationships with third parties, only objective criteria are to be considered relevant. Avoid even giving an impression of any conflict of interest. 

All employees are obligated to immediately disclose any potential conflicts of interest to their immediate supervisor and the Human Resources Division. 

Action even if the conflict has not adversely impacted the Company.

If you realize that you have a conflict of interest or are uncertain whether a conflict of interest exists or may arise, contact your Line Manager.

2. Why should you comply with this Business Code of Conduct?

Conflicts of interest may, in particular, result in financial losses and damage the reputation of MM Mega Market (Vietnam) Company Limited. In addition, conflicts of interest may adversely affect the working environment, because colleagues might consider it unfair or improper if you appear to be putting your own personal interests first. A violation of this Business Code of Conduct may also lead to the violation of Article 18 of Company internal labour regulations, and any related Company policies, as well as any applicable laws of Vietnam from time to time. The Company in such case shall reserve the right to immediately inform to the relevant competent authorities of any acts relating to this, if necessary.

II. OFFERING AND GRANTING BENEFITS

1. Business Code of Conduct

As an employee of MM Mega Market (Vietnam) Company Limited, you may not offer or grant any personal benefits

(e.g. gifts) to any employee of another company or any other third party in connection with business matters. You should avoid even giving an impression of any intent to influence third parties by improper means.

The only exceptions, subject to the approval matrix following Company related policies, are as follows:

  • Symbolic and low-value gifts for special occasions or giveaways, or gifts which are – exceptionally – reasonable in an individual case, where by cash payments or comparable benefits (e.g. shopping vouchers or telephone cards) are generally prohibited;
  • Business lunch or business dinner invitations to the extent reasonable.

If you are uncertain whether or not a certain form of conduct is prohibited, contact your Line Manager. If in doubt, do not offer or grant benefits to third parties.

2. Why should you comply with this Business Code of Conduct?

Non-compliance with this Business Code of Conduct may result in a violation of anti-corruption related regulations and financial losses, and damage the reputation of MM Mega Market (Vietnam) Company Limited. In addition, you may be subject to administrative sanctions and criminal prosecution as a result of non-compliance with this Business Code of Conduct and also leads to the violation of Article 17 of Company internal labour regulations and any Company related policies. The Company in such case shall reserve the right to immediately inform to the relevant competent authorities of any acts relating to this, if necessary.

III. SOLICITING AND ACCEPTING BENEFITS

1. Business Code of Conduct

As an employee of MM Mega Market (Vietnam) Company Limited, you may not solicit or accept any personal benefits (e.g. gifts) from any employee of another company or any other third party in connection with business matters. This prohibition applies even if you would have made the same decision had no benefits been solicited or accepted. You should avoid giving the impression that your decisions are influenced by improper means. This prohibition applies without limitation in respect of soliciting benefits.

In respect of accepting benefits, subject to the approval matrix following Company related policies, the only exceptions are as follows:

  • Symbolic and low-value gifts for special occasions or giveaways, or gifts which are – exceptionally – reasonable in an individual case, whereby cash payments or comparable benefits (e.g. shopping vouchers or telephone cards) are generally prohibited;
  • Business lunch or business dinner invitations to the extent reasonable.

If you are uncertain whether or not a certain form of conduct is prohibited or if you have any questions in this regard, contact your Line Manager. If in doubt, do not solicit or accept benefits from third parties.

2. Why should you comply with this Business Code of Conduct?

Non-compliance with this Business Code of Conduct may result in a violation of anti-corruption related regulations and financial losses and damage the reputation of MM Mega Market (Vietnam) Company Limited. In addition, a violation may render you subject to blackmail by third parties. Moreover, the violation of this Business Code of Conduct also leads to the violation of Article 16 of Company internal labour regulations and any Company related policies. Last but not least, you may be subject to administrative sanctions and criminal prosecution as a result of non-compliance with this Business Code of Conduct. The Company in such case shall reserve the right to immediately inform to the relevant competent authorities of any acts relating to this, if necessary.

IV.  APPROPRIATE HANDLING OF CORPORATE INFORMATION

1. Business Code of Conduct

As an employee of MM Mega Market (Vietnam) Company Limited and unless authorized to do so, you are prohibited from disclosing confidential information or confidential documentation to third parties, or otherwise making such information or documentation externally accessible during the term of your employment agreement or thereafter. All inquiries by representatives of the news media, analysts or other third parties must be forwarded to the responsible Corporate Communications Department and you may not respond to such inquiries yourself in the name of MM Mega Market (Vietnam) Company Limited.

The only exceptions are as follows:

  • You have been expressly authorized to disclose the information or documentation concerned;
  • The information or documentation concerned has been previously published by MM Mega Market (Vietnam) Company Limited;
  • The information or documentation concerned has been published by third parties, but only if and to the extent that the content of the publication has been publicly confirmed by MM Mega Market (Vietnam) Company Limited.

In many cases it is difficult to determine whether or not information or documentation is of a confidential nature. In such cases and in any other cases of uncertainty, contact your Line Manager or Corporate Communications Department. If in doubt, do not disclose information or documentation.

2. Why should you comply with this Business Code of Conduct?

Non-compliance with this Business Code of Conduct may, in particular, result in competitive disadvantages for MM Mega Market (Vietnam) Company Limited and violate insider trading rules. Violation of this code of conduct also leads to the violation of Article 19 of Company internal labour regulations, any Company related policies, and commitment under the labour contract, as well as any applicable laws of Vietnam, from time to time.

V. DIVERSITY, EQUAL OPPORTUNITY AND TOLERANCE – NON – DISCRIMINATION

1. Business Code of Conduct

MM Mega Market (Vietnam) Company Limited is committed to diversity, equal opportunity and tolerance. Therefore, you should avoid any direct or indirect discriminatory conduct, in particular discrimination based upon race, ethnic origin, religion and beliefs, disability, age, sexual orientation and gender and any other types of discrimination. In addition, any harassment in any form, in particular mobbing and sexual harassment, is prohibited. 

The above Business Code of Conduct applies between managers and employees, protecting both managers and employees. It also applies between employees. Third parties, e.g. customers, temporary employees, etc., also fall within its scope.

If you encounter discrimination or harassment, please contact your Line Manager.

2. Why should you comply with this Business Code of Conduct?

The diversity of our workforce is one of our greatest assets for sustainable success. We promote employees based upon ability and performance. We deal with one another with an open mind and tolerance. As an equal opportunity employer, we offer all employees and job applicants’ equal opportunities regardless of gender, age, race, ethnic origin, sexual orientation, disability, religion or beliefs. Violation of this code of conduct also leads to the violation of Article 20 of Company internal labour regulations, any Company related policies, as well as any applicable laws of Vietnam, from time to time.

VI. COMPLIANCE WITH APPLICABLE LAWS AND COMPANY REGULATIONS

1. Business Code of Conduct

The Business code of Conduct set forth above cannot, and are not intended to, serve as a detailed code of conduct covering all conceivable scenarios that may arise within the scope of your employment with MM Mega Market (Vietnam) Company Limited. Instead, they are intended to serve as practical guidelines for scenarios that are of particular relevance and importance. Nonetheless, as an employee of MM Mega Market (Vietnam) Company Limited, you are obligated to perform your work entirely in compliance with relevant laws and applicable company guidelines, both internal and external. Compliance with applicable laws takes precedence over any contradicting instructions issued by managers

 

You must therefore familiarize yourself with and know the laws, regulations, and other legal provisions and guidelines relevant to your areas of responsibility. As the law is undergoing rapid changes in certain areas, you must continuously keep up to date with any changes in the areas of law relevant to you

 

Laws, regulations, etc. are often difficult to understand. It is therefore not always a simple matter to determine whether a particular form of conduct complies with the applicable law in all respects. Therefore, if you are uncertain whether a certain form of conduct is in compliance with this Business Code of Conduct, contact your Line Manager, the legal department to discuss the appropriate course of action. If you are uncertain whether your conduct is in compliance with applicable laws and the company guidelines, do not engage in such conduct.

2. Why should you comply with this Business Code of Conduct?

 Non-compliance with this Business Code of Conduct may, in particular, result in financial losses and damage the reputation of MM Mega Market (Vietnam) Company Limited. Even the impression that laws have been violated can affect public opinion and, for example, result in adverse changes in the conduct of our customers. In addition, non-compliance with this Business Code of Conduct may result in claims for damages as well as administrative sanctions and criminal prosecution against you personally.