Code of Conduct

We are fully committed to the highest professional and ethical standards. The Firm aims to nurture a professional culture characterised by commitment, honesty, integrity and responsibility.

These core principles defines our expectations of everyone working with and dealing with our Firm. It guides our behaviour with our clients and stakeholders. The Firm is committed to being a professional and sustainable practice.

Anti-Corruption Policy Statement

The Firm will not stand for any form for bribery, corruption (in any of its forms) and takes a firm and uncompromising stand against any and all such conduct.

Corruption is any dishonest or fraudulent conduct by any person in authority, and typically involves bribery. Bribery involves the dishonest persuasion of a person to act in someone’s interest in return for a gift, gratification or inducement.

The Firm and its staff are expected to and do operate at the very highest levels of professional practice as required by the law and ethics. All who deal with the Firm must and are expected to similarly comply with these principles, without exemption.

Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) Policy Statement

It is Firm policy to prohibit and actively prevent money-laundering and any activity that facilitates money-laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the applicable legislation.

Money-laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes.

Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable legislation and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our practice.

If there is any reason to suspect that any of the principles as set out above are not adhered to, please make your report to the following person:

Compliance Administrator
Cecil Abraham & Partners
Suite 12.01, Level 12
Menara 1MK
1 Jalan Kiara
50480 Kuala Lumpur

Telephone: +603 2726 3700
Facsimile: +603 2726 3733