Annual Declaration

Annual Declaration
Note:
- This Form consists of Part A (Conflict of interest), B (Anti bribery policy), C (Confidentiality), and D (Fit and Proper Status Declaration).
- This Form should be submitted by you annually or at any point in time when the Group requires or when a real, apparent or potential conflict of interest situation arises.
- The requirement to fill this form is in accordance with Firm Policy Manual para 1.4(d).
- This form is not intended to penalize but to be truthful and to remedy for the benefit of all.

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AuditAccountingTaxSecretariatAdmin

Part A: Conflict of interest
Conflict of interest

In McDonald Carter / McCarter Group, we believe in "People First". However, employees should avoid any situation that involves, or appears to involve, a conflict between their personal interests and the interests of the Firm. That means employees should avoid circumstances that might affect their judgement or impartiality when performing their jobs. A conflict of interest exists if any employee has any interests or activities held outside the Firm that may be advanced at the expense of the Firm or its clients. In general, employees are advised to refrain from letting personal and/or financial interests and external activities come into opposition with the Firm’s fundamental interests.

The responsibility of resolving a conflict of interest starts from the immediate supervisor and may reach Senior or Top Management. All conflicts of interest will be resolved as fairly as possible. Top Management has the responsibility of the final decision when a solution can not be found.

Employees must disclose any obligation, commitment, relationship or interest that could conflict or may be perceived to conflict with his or her duties by making a declaration with CONFIDENCE using this Conflict of Interest Disclosure Form.

Where an employee is found to have any real, apparent or potential conflict of interest but FAILED TO DECLARE, the employee is in violation of the Code of Business Conduct and Ethics and may be subject to legal claims or proceedings or disciplinary measures including termination of employment.
Instructions

Please choose "Yes" or "No" in the situations below.

The term “affiliated persons” includes:
a) Your immediate family members, i.e. spouse, children, parents, siblings or any relatives.
b) Any corporation or organisation or entity of which you are a board member, a committee member, a director, an officer, a partner or an employee; and
c) Any corporation or organisation or entity of which you are a shareholder or the beneficial owner of any class of securities (with the exception of holdings in public-listed companies, unless you have substantial holdings of 5% or more).

1. You or any of your affiliated persons are involved in a business that is in either direct or indirect competition with or in the same industry as McCarter Group of Companies.*

YesNo
Please provide further details and descriptions of the activity and/or the relationships for the situation above. You may attach additional comments, documents or materials, if necessary.
Attachment

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2. You provide accounting, tax or business advisory services externally for your personal gain which you believe is not and will not be in competition with McCarter Group.*

YesNo
Please state the services that you provide externally for your own gain.

AuditAccountingTaxSecretarialBusiness advisoryOther
Number of cases
Yearly revenue
Amount in Ringgit Malaysia (RM)

3. You recommend a client or potential client to engage a service with a competitor instead of McCarter Group.*

YesNo
4. You have an opportunity for personal gain or external business through your position or through the use of McCarter Group’s facilities, equipment, systems, files, data or other properties.*

YesNo
5. You have any financial or personal gain from the transaction or dealing between McCarter Group and its client, distributor, supplier or business partner.*

YesNo
6. Are you aware of any other events, transactions or situations that have occurred or may occur in the future that you believe should be brought to the knowledge of the McCarter Group’s Management?*

YesNo

Part B: Anti bribery policy
Anti bribery policy

McCarter Group and McDonald Carter upholds the highest standards of professional integrity and ethical conduct required of every partner, officer, employee and third parties who perform services for or on behalf of the Group.

The Group and all the employees are committed to compliance with the Malaysian Anti-Corruption (MACC) Act 2009 (“MACC Act”), subsequent amendments to the Act and all guidelines issued by relevant authorities pertaining to the same.

This Policy aims to ensure that all Employees (defined below) and Associated Persons (defined below) of the Group are aware of their obligation to disclose any corruptions, briberies, conflicts of interest or similar unethical acts that they may have, and to comply with this Policy to follow highest standards of ethical conduct of business.

All Associated Persons are not permitted to pay, offer, accept or receive a bribe in any form.

I agree to the following (please tick whichever applies):*

To not offer, pay or give anything of value to any parties in order to obtain business or anything of benefit to the Group.To not attempt to induce any parties to do something illegal, unethical and permit any parties to violate the rules.To not give some advantage inconsistent with law and wrongful or unlawful use of official position to procure some benefit or personal gain.To not offer, give, receive or solicit, directly or indirectly, anything of value to influence improperly the actions of another party.To not act illegally including bribes, blackmail, inducements, secret commissions, other rewards and similar improper actionsTo not corruptly give, promise or offer to any person gratification with the intent to secure business or an advantage for

Part C: Confidentiality
Confidentiality

In accordance with the policy of the firm, all partners, staff, subcontractors, and consultants involved in or connected with audit work, must complete, and sign a statement of confidentiality as a condition of employment.

Inappropriate use of client’s confidential information would be grounds for dismissal. A breach of the rules regarding confidential information will be considered as gross misconduct and could, subject to investigation, result in instant dismissal and, in certain circumstances, legal action.
I agree to the following (please tick whichever applicable):*

To always keep secure all working papers and client information so that unauthorised access is not gained by either the client’s staff or third parties.Not to impart information to anyone other than to a member of this firm, other than to other parties where such disclosure is normal and client-approved.Not to share confidential information of the firm to clients’ employees or third-parties without proper approval from the partner in charge or the client.Not to share private and/or confidential information as well as affairs of clients' to any member of the firm or third-parties.Not to discuss matters related to clients or firm outside of working area so as to be heard by members out of this firm.

Part D: Fit and proper status declaration
Financial integrity and reliability
In the last ten years, has a court given any judgement against you about a debt?*

YesNo
Have you ever been declared bankrupt or been the subject of a bankruptcy court order or has a bankruptcy petition ever been served on you?*

YesNo
Have you ever signed a trust deed for a creditor, made an assignment for the benefit of creditors, or made any arrangements for the payment of a composition to creditors?*

YesNo

Convictions or civil liabilities

There is no need to mention any offences committed before the age of 18 (unless committed within the last ten years) and road traffic offences that did not lead to a disqualification or prison sentence.
Have you at any time pleaded guilty to or been found guilty of any offence? If so, give details, at the end of this form, of the court which convicted you, the offence, the penalty imposed and date of conviction.*

YesNo
In the last five years have you been the subject of any civil action relating to your professional or business activities which has resulted in a finding against you by a court or a settlement being agreed?*

YesNo
Have you ever been disqualified by a court from being a director, or from acting in the management or conduct of the affairs of any company?*

YesNo

CONFIRMATION & DECLARATION
I HEREBY DECLARE that I have read and understood all the information, declarations, and restrictions provided in this Declaration. I have answered the questions above truthfully and honestly, to the best of my knowledge and belief.

I am aware of the need to keep clients’ affairs confidential.

Should any of the circumstances above change, I shall inform the Management immediately.
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Annual Declaration

Your details

Part A: Conflict of interest

Part B: Anti bribery policy

Part C: Confidentiality

Part D: Fit and proper status declaration

Financial integrity and reliability

Convictions or civil liabilities

Good reputation and character

CONFIRMATION & DECLARATION