1. Purpose
The Master-Pack Supplier Code (‘SC”) is a standard requirement that we require our suppliers to adhere to, when conducting business with Master-Pack. We request that all suppliers read and understand and comply to this SC, Master-Pack Code of Business Conduct and Master-Pack AntiBribery and Anti-Corruption policy published in our company website.
Fundamental to this SC is the adoption of compliance to the Responsible Sourcing Code and SEDEX Code of Conduct, which embodies a set of standards on social, environmental, and ethical issues in the supply chain.
All vendors who do business with Master-Pack are required to read this SC requirement and by so doing shall be deem to have read and understood the terms set forth. On being approved as MasterPack supplier and through the acceptance of the Purchase Order, the supplier hereby acknowledges their commitment to take the appropriate actions to comply to the SC. However, the demonstration of compliance to SC does not create any third-party beneficiary rights to the supplier and the SC is an addition and not in lieu of any provisions of any legal agreement or contract between suppliers and Master-Pack.
2. Scope
The guiding standard is defined in the following areas:-
A. Human Rights
B. Health and Safety
C. Environment
D. Business Integrity
- E. Grievance Procedure
B. Health and Safety
Suppliers must recognize that a safe and healthy working environment will promote a conducive environment for all workers.
i. Occupational Health and Safety
Workplace environment should be provided with adequate lighting, ventilation, sanitation and personal protective equipment. Workers should be educated on health matters and provided with ongoing safety training. Potential exposure to health and safety hazard shall be identified, assessed and mitigation controls established and communicated to workers accordingly. Where necessary, to provide occupational health monitoring to routinely evaluate if workers’ health is being harmed from occupational exposure.
ii. Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impacts minimized by implementing emergency plans and responses procedures including employee notification, evacuation procedures, worker training and drills, appropriate first-aid supplies, fire detection and suppression equipment, adequate exit facilities and recovery plans. Emergency drills for evacuation shall be executed at least annually.
iii. Housing / Dormitory Conditions
Housing / dormitory should be provided for migrant workers in accordance with all applicable laws and regulations. The housing /dormitory shall be clearly segregated from the factory and productions area. There should be toilet facilities, access to potable water and proper facilities for food preparation and storage.
iv. Health and Safety Communication
Suppliers are required to communicate with their workers on workplace safety and health information during induction as well as during on job training. Workers are to be taught to handle the machinery/ hazardous materials following proper safety procedures. Updates on safety related information shall be clearly posted in the workers information notice board.
v. Occupational Injury and Illness
Procedures to prevent, manage, track and report occupational injuries and illnesses needs to be in place. Provide necessary medical treatment, investigate cases and implement corrective action to ensure workers safety at workplace.
A. Human Rights
Human Rights – Suppliers must respect human rights and this will apply to all workers including temporary, direct & indirect employees, migrant employees, contractors and sub-contractors. More importantly, suppliers are encouraged to adopt into practice the basic human rights principles including diversity and inclusion for all workers under its care.
Suppliers are to respect the basic human rights of his employees as follows:
a) to practice and promote equal treatment and opportunities to all its employees;
b) should not discriminate on the basis of gender, race, nationality or ethnicity, religion, age, disability or sexual orientation or marital status unless specific laws or regulations expressly provide for selection according to specific criteria
c) to respect the personal dignity, privacy and rights of each individual;
d) to prohibit any type of harassment and violence. These actions or behaviours include derogatory comments based on gender, racial or ethnic characteristics, unwelcomed sexual advances, spreading of malicious rumours or use of emails, voicemails and other forms of communications channels to transmit derogatory, defamatory or discriminatory materials
e) to ensure working hours are in accordance with the Employment Act/ Labor Regulation/ Minimum Wage Order of the country in which he/she works. All overtime shall be voluntary. Employees shall be allowed at least one day off every seven days. Wages and compensation paid to workers shall comply with applicable local laws including the minimum wage, overtime and the mandated contributions. At the end of each wage period, employees are provided with a payslip or statement of wages.
All employees shall receive equal pay for equal work and qualification on entry. Deductions from wages as a disciplinary measure shall not be permitted.
f) to recognize and respect the right of workers for freedom of association. Open communication and direct engagement between employees and employer are encourage. Employees can share ideas and concerns openly without fear of discrimination, reprisal and intimidation.
ii. Legal Workers -Workers employed must be legally entitled to work in the country in which they work and shall be granted the rights and protection in accordance to the regulation of the country in which they work in. As such workers employed must have valid permits and appropriate documentation duly authorized to work at stated premises
iii. Freely Chosen Employment – All work must be voluntary. Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not be used. Indentured servitude such as physical punishment, confinement, threats of violence as a method of discipline as conditional employment shall not be used.
All employment conditions shall be in written form to the workers in the language that they are able to understand. All work shall be voluntary and the workers shall be free to leave work or terminate their own employment with reasonable notice given to employers. All workers are responsible to comply with the regulations and law of the country in which they work. The employers shall ensure that proper renewal or clearance with all government authorities such as Immigration Department and Inland Revenue Board are in complied. Employer shall be responsible to bear all related recruitment fees or related expenses and such fees shall not be deducted from the employee’s wages.
iv. Prohibition of Child Labor – The use of child labor is strictly prohibited. The term “child” refers to any person under the age of 15 years old or under the minimum age for employment in the country, whichever is greatest. In Malaysia/ Vietnam the minimum age for employment is 18 years of age.
C. Environment
Suppliers are required to comply with all applicable legal environment requirements and demonstrate continual monitoring and improvement to reduce their environmental impact when providing products to Master-Pack.
i. Environment Permits and Reporting
The supplier shall be responsible to obtain, maintain and ensure that all operational permits and environmental reporting are current and within the legal limits.
ii. Hazardous Materials and Product Safety
Suppliers shall identify hazardous materials, chemicals and substances and ensure their safe handling, movement, storage, recycling, reuse and disposal. All the applicable laws and regulations related to hazardous materials, chemicals and substances shall be strictly followed.
iii. Resource Consumption, Pollution Prevention and Waste Minimization
The supplier shall optimize its consumption of natural resources, including energy and water. Supplier shall implement and demonstrate sound measures to prevent pollution and minimize generation of solid waste, wastewater and air emissions.
a) Energy Usage and Greenhouse Gas (GHG) Emission
Suppliers shall monitor their energy consumption and have proactive approach to reduce greenhouse gas emissions and combat climate change. We expect our suppliers to collect and monitor their carbon footprint and provide data when requested.
b) Water quality and Consumption
Suppliers shall adopt and have sustainable water management practices in place. We expect our suppliers to collect and monitor water consumption and provide data when requested. Prior to discharge or disposal, supplier shall treat wastewater appropriately and accordingly to applicable laws and regulations.
c) Resource Efficiency and Waste
Suppliers shall continuously improve environment management in order to reduce consumption of natural resources, minimize waste and prevent pollution at the source. Suppliers should adopt a systematic approach to identify, manage, reduce and responsibly dispose of or recycle solid waste (non-hazardous).
iv. Responsible Sourcing of Minerals
Suppliers shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Participants shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to Master-Pack upon request.
D. Business Integrity
i. Bribery and Anti-Corruption
The supplier must not directly or indirectly promise, offer, grant or authorise the giving of money, commission, facilitation payments (grease money) or anything else of value to government officials, officers of private enterprises, consultants and their connected persons to obtain or retain a business or an advantage in the conduct of business.
All suppliers must not influence others or be influenced either directly or indirectly by paying or receiving bribes or kickbacks or any other measures that are deemed illegal.
Establish a policies and procedures that ensure the confidentiality, anonymity and protection of whistleblower shall be maintained. The whistleblower shall be able to communicate to raise any concerns without fear of retaliation.
ii. Competition Act
Competition Act governs the way suppliers react and behave in the marketplace. Suppliers supplying to Master-Pack shall strive to compete vigorously but fairly
To adhere to the Competition Act suppliers should not –
* Communicate with any competitor relating price, any term that affects pricing or production levels
* Divide allocate markets or customers
* Agree with a competitor to boycott another business
* Put inappropriate conditions on purchases or sales
iii. Confidential Information
In the course of supplying products to Master-Pack, suppliers may come into possession of confidential or sensitive information relating to the Master-Pack, MasterPack customers or its business contacts. All suppliers shall commit to protect and maintain against unintentional disclosure of confidential information. Special care must be taken by supplier including supplier’s representative against any situation that could result in inadvertent disclosure of such information include: discussing confidential information in public (in cafe, elevators, airplanes; talking about confidential information on mobile phones without realising the surrounding; working on sensitive information in public areas)
iv. Personal Data Protection Act 2010
Personal Data Protection Act sets the requirements for the appropriate handling of personal information such as financial information, identification number, biometric information, physical location tracking, employee monitoring, behavioural privacy and communications privacy.
All suppliers shall commit to protecting the reasonable privacy expectations of personal information they do business with and comply to the Personal Data Protection Act when personal information is collected, stored, processed, transmitted and shared.
v. Intellectual Property, Trade Marks and Brands
All suppliers shall take appropriate steps to safeguard and maintain confidential and proprietary information such as intellectual property rights, trade marks and brands of Master-Pack including its business partners.
vi. Conflict of Interest
a) Any director or employee or their family members of the supplier should not have and must make known to the company on any conflict of interest prior to supplying
b) Any financial interest and or a family member holding a position/ designation of control in any of Master-Pack Group of companies .
c) Any business dealings or contractual arrangements with any company in the group. Business dealings however exclude staff purchases for personal consumption or purchases which are on no more favourable terms than those offered to the public.
vii. Supplier Responsibility
Master-Pack will communicate to suppliers during annual evaluation and during preapproval of a new supplier to refer to the Supplier Code. Suppliers are responsible to proactively required to meet the standards as set in Master-Pack Suppliers Code of Conduct.
viii. Training
Suppliers are encouraged to establish programs for training employees on safety and health, anti-corruption and anti-bribery, sexual harassment and other topics in line with the supplier’s policies and procedures.
viv. Supply Chains
Master-Pack also encourages suppliers to communicate with their own supply chain to progressively comply to the elements set within this Code of Conduct.
E. Grievance Procedure
This procedure covers activities related to the handling of stakeholders’ grievances with respect to the implementation of the SC. This includes recording grievances, taking actions to verify claims, rectifying any confirmed issues, reporting the verification results and actions on the ground, delivering the response to stakeholders and managing and monitoring any followup action. Grievance Procedure apply to both internal and external stakeholders
Please refer to Master-Pack Whistle-Blowing Policy at https://master.net.my/investorrelations/whistle-blowing-policy/ for the steps applicable to internal and external stakeholder reporting of grievances.
3. Audit and Termination of Supply Agreement
Master-Pack requires your support and efforts to periodically reply to Master-Pack’s assessment questionnaires and or audits to evaluate compliance with the SC besides technical, quality and commercial criteria. In the event of non-compliance, the supplier shall be given a period for corrective action and if un-remedied, Master-Pack reserves the right to terminate the supplier’s supply forthwith.
Master-Pack Supplier Code of Conduct
To : Master-Pack Group Bhd.
In the event that Master-Pack, become aware of any actions or conditions not in compliance with the SC, we reserve the right to request corrective actions. Master-Pack Group Berhad and its group of companies reserves the right to terminate an agreement/ purchase order with any supplier and/ or supplier representatives that does not comply with this Code.
| Name of Company: | |
| Name and Title: | |
| Signature: | |
| Company Stamp: | |
| Date: | 12-07-2025 |