BUSINESS ETHICS AND TRANSPARENCY: CODE OF CONDUCT
The Malakoff Code of Conduct (“Code”) is the Group’s formal commitment that governs our employees’ professional conduct, enabling them to operate in a transparent, appropriate and fair manner. The following principles guide our employees in their dealings with the Group, customers, vendors, suppliers, contractors and other internal and external parties.
Malakoff Code of Conduct - Underlying Principles
- HONESTY: avoid hiding the truth;
- INTEGRITY: avoid situations where the personal interests of employees appear to be in conflict with the interest of Malakoff Group;
- LEADERSHIP: avoid abuse or misuse of the employees’ position in the company;
- PROFESSIONALISM: maintain secrecy when dealing with confidential information obtained in the course of employment and do not disclose or use such confidential information for personal advantage;
- LOYALTY: avoid jeopardising the reputation of the company;
- RESPONSIBILITY: disclose and seek clarification from relevant persons in the Group whenever in doubt or whenever ethical concerns arise;
- TRUSTWORTHINESS: avoid misuse of the company’s resources or assets for personal gain; and
- PERSONAL CONDUCT: conduct or behave in any manner at any place and time that does not bring disrepute to the Group.
Employees are required to adhere to the Code by signing a declaration. The Code is made available and accessible to all employees.
The Whistle-blowing Policy was launched in 2014 and provides employees and third parties with proper procedures to disclose cases of Improper Conduct which include criminal offences, fraud, corruption, breach of Group Policies and Code of Conduct or other malpractices.
A Whistle-blower is assured confidentiality of identity to a reasonably practicable extent. This includes protecting the Whistle-blowers from detrimental action that may result from the disclosure of Improper Conduct, provided that the disclosure is made in good faith. The Whistle-blowing Policy also serves to ensure that fair treatment is provided to both the Whistle-blower and the alleged wrongdoer when a disclosure of Improper Conduct is made.
A disclosure of Improper Conduct can be made verbally or in writing to the Chairman of the Board Audit Committee through a letter or e-mail to email@example.com. The Chief Internal Auditor is responsible for the administration, interpretation and application of the Whistle-blowing Policy and any amendment to this Policy needs to be vetted by the Chief Internal Auditor, subject to the final approval of the Chief Executive Officer, the Chairman of the Board Audit Committee and the Board of Directors.
In 2017, only one case was reported through the Whistle-blowing channel and appropriate action was taken in accordance to the Policy. A revision to the Whistle-blowing Policy was also made in 2017 to further enhance the effective implementation of the Policy.
The salient terms of the Whistle-Blowing Policy is available on our corporate website at: http://www.malakoff.com.my/About-Us/Whistleblowing-Policy/
At Malakoff, we develop frameworks and processes to comply with the relevant laws and regulations. This includes various audit and verification programs, as part of the efforts to comply with the relevant Health, Security, Safety and Environment (“HSSE”) regulations. In 2017, we have successfully conducted three different type of audits:
- QHSSE Internal Audits – Conducted by competent Internal Auditors
- SIRIM Surveillance QHSSE Audits – Conducted by SIRIM Certification Authority; and
- MCB Group Internal Audit – Conducted by Group Internal Audit Department
As a result of this systematic and structured effort, only one notice was issued by Department of Environmental (“DOE”) Johor to TBPP in 2017 as compared to two notices in 2016. The notice which was served to us related to the management of scheduled waste.
Based on this notice, we have revised and improved the current process of management of scheduled waste to ensure full compliance to the requirements.
CLEAN AIR REGULATION ACT (CAR 2014)
Changes relating to Clean Air Regulation Act will come into effect in June 2019. These changes include the inclusion of Hydrogen Fluoride (“HF”), Hydrogen Chloride (“HCl”), Polychlorinated dibenzodioxins (“PCDD”)/ Polychlorinated dibenzofurans (“PCDF”) and the introduction of new lower limits for Carbon monoxide (“CO”) and Mercury (“Hg”).
Engagement with the stakeholders are being undertaken and in progress to ensure that Malakoff is in the right course for compliance with the new Clean Air Regulation.
As part of our proactive actions, in December 2017, Malakoff appointed a consultant to conduct an Environmental Compliance Audit at our local plants to assess the readiness and compliance to the new Act.
STRATEGIC BUSINESS DEVELOPMENT
The Group has an established portfolio of international power and desalination water production assets and remains committed to the power and desalination water businesses. We continue to pursue growth opportunities, mainly to support the Malaysian Government’s target to achieve a cumulative large-scale solar capacity of 1,000 MW by 2020.
During the year under review, we explored and reviewed new local and overseas ventures and acquisitions, including potential business diversification, to deliver value for our shareholders. In keeping with global and regional trends, as well as our growing commitment to sustainable energy, we actively participated in local bidding process for commercially viable RE projects. Our plan to develop an optimised RE portfolio for the Group will not only catalyse new growth, but will help meet our sustainability agenda.
BUSINESS INNOVATION AND DIVERSIFICATION
The dynamic market trends demand businesses to continuously innovate and bring frontier solutions to the marketplace. It also calls the need for diversifying both the risks as well as the areas of growth and expansion. Therefore, we are on a constant look-out for high-potential business avenues related to waste-to-wealth and emerging technologies; servicing new customers in O&M services; electricity distribution and district cooling amongst others. All new investment opportunities are considered by the Management with stringent review and approval guidelines. Such opportunities are tabled to the Board of Directors for their approval only after a due diligence exercise has been conducted.
In June 2017, we participated in a bid to acquire National Central Cooling Company PJSC, a district cooling system company operating in the Middle-East. The bid for acquisition was however unsuccessful. During the year, in O&M Services, through our subsidiary Teknik Janakuasa, we provided technical training services as a new sustainable solution to promote and enhance skill and knowledge of professional community.
SECURITY OF SUPPLY
The security of supply to the National Grid is directly related to the available capacity during a given period and the reliability of plants operating within the same period. The outage plans for all our plants are reviewed together with the Grid System Operator on a regular basis to ensure our plants are available to support the grid system, as stipulated in the PPA, without compromising the integrity of the plants.
All our power plants (except Port Dickson Power Plant) are classified as national security zones (“Sasaran Penting”) by the relevant government agency, Jabatan Sasaran Penting Negara (“JSPN”). In 2017, we continued to review and inspect security of the plants for both adequacy and effectiveness. All our plants have been audited by JSPN whereby the result is satisfactory with the recommendation to further strengthen the security of the plant especially those which are critical to the country and categorised
as “Sasaran Penting Keutamaan Satu”.
We have the responsibility to ensure a safe, secure and reliable power supply to the national grid. We achieve high plant reliability through various maintenance plans, including preventative maintenance and condition-based maintenance. Our Engineering Group manages activities in relation to Condition Based Maintenance technologies
and O&M tools implementation, such as Reliability Centered Maintenance, Root Cause Analysis, Reliability Centered Spares, Risk Based Inspection, Process Safety Management, Hazard and Operability Study, forced outage management, and benchmarking in all plants. This is to ensure higher plant availability and reliability.
The Group also leads and participates in failure investigations and root cause analyses to avoid recurrences. It also renders support in terms of unit and part assessments during outages or inspections related to gas turbines, steam turbines, generators, and boilers.
In 2017, our Engineering Department continued to lend its engineering expertise in various aspects of operations and maintenance such as risk management, failure prevention, strategic planning, and cost optimisation to achieve performance targets. It also managed the power plants’ operational and performance (thermal and
emissions) activities and process improvements.
For local power plants, we set thermal efficiency goals for execution and continuous monitoring, with a dedicated thermal performance monitoring program consisting of performance gap identification, remedy plans and potential risk forecasts. Periodic performance review session was conducted internally and externally throughout the year. The quarterly review identities gaps and potential operational issues. It also helps the plants to properly plan the tasks to remedy the defects and schedule the required outage. The following chart indicates the thermal efficiency among our local generating plants.
OCCUPATIONAL SAFETY AND HEALTH
At Malakoff, we have established and implemented a comprehensive HSSE Assurance programme in accordance with the ISO 14001 and OHSAS 18001 standards. Having adopted these voluntary Gold Standards in HSSE management, we conduct due diligence studies on hazards and risks assessment; operational controls; training and competency systems; audit and verification; and various supporting programs. To date, our HSSE Assurance System has been audited extensively by SIRIM and we have been successful in maintaining our certification at all our sites within the certification scope. In 2017, we continued to implement various Occupational Safety and Health (“OSH”) programs such as Malakoff HSSE Day; Road Safety Campaign; HOPe; and Take 2; mainly to promote HSSE awareness within the organisation.
In 2017, we have enhanced our OSH calculation and reporting methodologies and the following table reports the incident and fatality rates.
As indicated in the table, the number of all safety incidents recorded reduced from 29 in 2016 to 22 in 2017. However, our LTIFR has shown an increase from 0.16 in 2016 to 0.59 in 2017. The increase was mainly due to the Lost Time Injury (“LTI”) cases recorded during forced outages and major inspection at Lumut and Prai Power Plants respectively. During the period 2014 to 2017, we recorded ZERO fatalities from any work-related incidents.
As testament to our commitment in ensuring excellence in OSH, Prai Power Plant has been awarded the prestigious National Occupational Safety and Health (“NOSH”) Excellence Award 2017 for the Energy Facility category.
The award was presented by the Department of Occupational Safety and Health, a division under the Human Resources Ministry. The NOSH Excellence Award aims to recognise individuals, media, journalists and various organisations with excellent track records in its occupational health and safety practices at the workplace.
EFFECTIVE MANAGEMENT OF PROCUREMENT
Supply-chain management is one of the critical factors for the success and profitability of any organisation. Therefore, our procurement policies, procedures and other governing rules are benchmarked for their effectiveness with global standards such as ISO 9001, ISO 14001 and OHSAS 18001. The key principle of our procurement is transparency and regular audits help surface constructive feedback for improvement in our approach as well as the overall governance. Our procurement policies promote fairness, curbs corruption of all kinds and creates opportunities for disadvantaged and indigenous communities based on meritocracy and value-added services.
Our suppliers consist of both local and international parties. As of 2017, we observed that there were no significant changes to our main supply chain that can contribute to significant economic, environmental and social impacts.
PROMOTING SUSTAINABLE PROCUREMENT PRACTICES
In 2016, we had launched i-Valua Portal, which is an e-procurement initiative, encouraging paperless vendor registration, development and e-auction. The digitisation of procurement system helped improve the turnaround time, and significantly improved resource allocation and management. The use of portal in itself resulted into cost savings of approximately RM3.2 million.
In 2017, the Phase 2 of the e-procurement concentrated on Contract Management, Materials Management and Purchase Requisition to Purchase Order and is expected to be completed by first quarter of 2018. The Phase 2 is expected to enhance performance in addition to improving both procurement process as well as resource optimisation.
During the year under review, we also organised a Vendor Day to raise awareness on the overall portal as well as critical aspects such as Vendor Code of Conduct, Related Party Transaction (“RPT”) or Recurring Related Party Transaction (“RRPT”) and Vendor Whistle-blower Channel. For 2017, a list of strategic procurement of certain services has been identified to minimise transactional procurement by introducing Service or Price Agreements with strategic partner/vendors.