The Board of Directors (“the Board”) of Hup Seng Industries Berhad, hereby establishes its Code of Ethics and Conduct (“Code”) to provide guidance in maintaining a business environment committed to high standards of ethics and integrity, corporate responsibility and legal compliance.

This Code is applicable to all directors, officers, managers, employees and temporary employees (“Concerned Persons”) of Hup Seng Industries Berhad and its subsidiaries namely Hup Seng Perusahaan Makanan (M) Sdn. Bhd., Hup Seng Hoon Yong Brothers Sdn. Bhd. and In-Comix Food Industries Sdn. Bhd. (collectively, “the Group”).


Conflict of Interest

All Concerned Persons are required to conduct themselves in a manner of ethics and integrity so as to avoid any conflicts of interest, either real or perceived. A conflict of interest is considered to be any situation or arrangement where personal activities or interests conflict with responsibilities to the Group. A conflict situation can arise when a Concerned Person takes actions or has interests that may make it difficult to perform his or her work on behalf of the Group objectively and effectively. The following are examples where actual or potential conflict may arise:

  • Having an ownership interest or personal financial interest in any supplier, customer, distributor, contractor or competitor of the Group.

  • Conducting business on behalf of the Group with immediate family members, which include spouses, children, parents and siblings.

  • Receiving or giving improper benefits/gifts as a result of the Concerned Persons’ position in the Group.

  • Using property, information, asset or position in the Group for personal gain.

Any situation that involves, or may be perceived as involving, a conflict between a Concerned Person’s interests and the interests of the Group should be disclosed to the Board of Directors of the Group.



All Concerned Persons of the Group must avoid giving or accepting gifts or entertainment, if these may improperly influence the recipients’ judgement or create a sense of obligation. Gifts can be in the form of goods, favours, travels, services, loans or use of properties. While at times, gifts exchange in business may be appropriate, each Concerned Person must practice good judgement and be guided by ethical responsibility in this situation. Gifts that are of token or nominal value and not excessive in frequency are generally permissible. Giving and receiving gifts in the form of cash or cash equivalent are prohibited and all Concerned Persons must never solicit gifts from others. Gifts that are offered in exchange for a business referral or to gain any other form of advantage are also unacceptable.


Proper Use of The Group’s Resources

The Group’s Assets. All Concerned Persons are expected to appropriately manage the Group’s tangible and intangible assets. Assets can include the Group’s properties, products, equipment, facilities, time, information, fund and any other possessions of the Group’s. All Group’s assets should only be used for legitimate business purposes and all Concerned Persons are prohibited from using these assets for personal gain or use unless approved by senior management. 


Intellectual Property. All Concerned Persons are required to safeguard the Group’s intellectual property (i.e. trademarks, ideas, copyrights, recipes, designs and trade secrets), just as they have the obligation to respect that of others.


Confidential Information

Confidential information is information belonging to the Group that is not disclosed to the public. Such information may include but not limited to marketing strategies, new product launches, financial information, intellectual property, and information on employees, suppliers and stakeholders. All Concerned Persons must ensure such information remain confidential and not divulge to anyone other than the person(s) for whom it is intended, unless authorised or legally mandated. Each Concerned Person is responsible in safeguarding confidential information entrusted to them depending on their roles in the Group, and shall practise caution when handling these information, for instance:

  • Keep electronic and paper documents and files containing confidential information in a safe place;

  • Avoid unnecessary copying of confidential documents;

  • Not discuss confidential matters where they could be overheard, for example, in public places such as elevators, restaurants, airplanes and gyms;

  • Exercise caution when discussing confidential matters on telephones or other wireless devices;

  • Avoid sharing and communicating significant and sensitive business information through open social media, such as Facebook, WeChat, Whatsapp or LINE; and

  • Transmit confidential documents by electronic devices, such as by fax or e-mail, only when it is reasonable to believe this can be done under secure conditions.


Uphold the Laws

The Group’s commitment to integrity starts with complying with all applicable laws, rules and regulations where the Group operates. Each Concerned Persons must have an understanding of the Group’s policies, laws, rules and regulations that apply to their specific roles.


Reporting of Unlawful or Unethical Behaviour

The Group encourages all Concerned Persons to report any unlawful or unethical behaviours including any actual or suspected violations of this Code, laws, rules and regulations. The Group do not tolerate any kind of retaliation against anyone for providing information in good faith. All reports and concerns received will be investigated and appropriate response, including preventive measures and corrective actions, will be taken.



The Board will review this Code from time to time to ensure it remains relevant and current.

HS  logo.jpg

Hup Seng Industries Berhad  199101015786 (226098-P)  (Incorporated in Malaysia)