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Lion & Lion needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the laws.
Lion & Lion may change, revise and/or amend this policy from time to time in accordance with the relevant laws. The updated version of such changes will be effective starting from the date that it is published.
WHY THIS POLICY EXISTS
This data protection policy ensures Lion & Lion:
• Complies with data protection laws and follows good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach
DATA PROTECTION LAW
Data Protection Law, in general, governs how organisations, including Lion & Lion, must collect, handle and store personal information.
Data Protection Law applies regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
Each of the entities under the Lion & Lion Group adheres to its local data protection law (if any); namely;
• Malaysia – Personal Data Protection Act 2010 (PDPA)
• HK – Personal Data (Privacy) Ordinance (Cap. 486)
• Singapore – Personal Data Protection Act 2012 (No. 26 of 2012)
• Vietnam – Law on Cyber-Information Security (LCIS)
• Taiwan – Personal Data Protection Law (‘PDPL’)
In addition, Lion & Lion Group will also adhere to the General Data Protection Regulations (GDPR) when applicable (ie. when personal data is processed for activities and transactions occur within the European Union).
The General Data Protection Regulations are underpinned by six important principles. These say that personal data must:
• Be processed fairly and lawfully and in a transparent manner in relation to individuals;
• Be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Be processed in accordance with the rights of data subjects and in a manner ensuring appropriate security of the personal data
PEOPLE, RISKS AND RESPONSIBILITIES
This policy applies to:
• All staff of Lion & Lion
• All authorised agents, contractors, suppliers, third party service providers and other people working on behalf of Lion & Lion where they are required to use personal data collected by Lion & Lion (including but not limited to its external professional advisors and auditors)
• Any related and affiliated companies of Lion & Lion (including Lion & Lion’s intermediate owners and ultimate beneficial owner)
It applies to all data that the company holds relating to identifiable individuals. This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Any other information relating to individuals and relevant to customer surveys and/or offers
• IP addresses and cookie strings
• Sensitive data (if any)
DATA PROTECTION RISKS
This policy helps to protect Lion & Lion from some data security risks, including:
• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
• Lion & Lion will also conduct a Risk Management Plan to assess risk and mitigate harm to the data that is collected and stored. This Risk Management Plan, created by the Project Manager of any project, defines how risks associated with any project will be identified, analyzed and managed and such plan will outline how risk management activities will be performed, recorded and monitored throughout the lifecycle of the project.
Everyone who works for or with Lion & Lion has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
• Lion & Lion’s Board of Directors are ultimately responsible for ensuring that Lion & Lion meets its legal obligations.
• The Data Protection Officer is responsible for:
- Keeping management updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Lion & Lion holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
• The Head of Operations and appointed IT Manager is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
• The marketing execution teams are responsible for:
- Approving any data protection statements attached to communications such as emails and letters.
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
DATA USE AND COLLECTION
Personal data is of no value to Lion & Lion unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft. The following guidelines will govern how Lion & Lion collects and uses personal data:
• Personal data will only be used for the purposes for which they were collected.
• The purposes for which personal data are being collected will be explained to individuals. These purposes may include the following; Contractual Necessity and Compliance with Legal Obligations
• Consent should always be obtained from the individual to use this personal data for a secondary purpose.
• Individuals will be provided with the opportunity to decline to provide personal data and the consequences of refusing to provide personal data will be clearly explained to individuals.
• A visible and easy to use mechanism will always be provided to individuals to withdraw their consent for processing their personal data.
• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. Data must be encrypted before being transferred
• All data stores and laptops that hold or process personal data will be equipped with encryption software.
• Personal data processed within the EU (if any) should never be transferred to a country or territory outside of the European Economic Area unless the country or territory ensures adequate level of security and unless there is a written consent.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
• Privacy / data protection compliance should always be taken into consideration in the:
- design of new and/or redevelopment of existing systems or business processes.
- specification, procurement and testing of new items of hardware used to support business processes
- specification, design and testing of new items of software used to support business processes.
These rules describe how and where data should be safely stored. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smartphones.
• All servers and computers containing data should be protected by approved security software and a firewall.
Personal data will only be retained for as long as necessary for the purpose(s) for which they were collected. The following controls in place to ensure that personal data are destroyed of or transferred back to another party in a manner that prevents improper access:
Data deletion or transfer requests should be made by email, addressed to the data controller at email@example.com. The data controller will supply a standard request form and will aim to address the request within 14 days.
The data controller will always verify the identity of anyone making a request before handing over any information.
The applicable laws require Lion & Lion to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Lion & Lion should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months and to record the status after each check.
SUBJECT ACCESS REQUESTS
All individuals who are the subject of personal data held by Lion & Lion are entitled to:
• Ask what information the company holds about them and why.
• Ask how to gain access to it, request for transfer, updates or amendments of data
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.
• Raise complaints or report any breach of data protection law
• Request for erasure of data
Subject access requests from individuals should be made by email, addressed to the data controller at firstname.lastname@example.org. The data controller will supply a standard request form and will aim to provide the relevant data within 14 days.
The Data Protection Officer will always verify the identity of anyone making a subject access request before handing over any information.
All requests (including but not limited to data breach notification and complaints) shall be free of charge and will be recorded in the Company’s system.
DATA BREACH, COMPLAINTS AND INQUIRIES
Detailed information and guidance on data breach, complaints and inquiries procedures, can be found here.
DISCLOSING DATA FOR OTHER REASONS
In certain circumstances, Personal Data may be required to be disclosed to law enforcement agencies or authorities without the consent of the data subject.
Under these circumstances, Lion & Lion will disclose the requested data. However, Lion & Lion will ensure the request is legitimate, seeking assistance from the company’s legal advisers where necessary.
PRIVACY CONTROL MANAGEMENT
The Data Protection Officer will conduct annual Privacy/ Data Protection Compliance Audits at a designated time between the month of July and August. Staff of Lion & Lion are required take the annual privacy and data protection training with an assessment to acknowledge the policy.
GENERAL STAFF GUIDELINES
• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• Lion & Lion will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
Scope and Objective
This Lion & Lion Code of Conduct (“Code”) embodies the guidelines and policies applicable to all employees (including but not limited to the directors, etc) of the Lion & Lion Group of Companies, in relation to the standards, ethical conduct, integrity and the highest standards of professionalism that all employees (at all levels) under the Lion & Lion Group of Companies are expected to comply with, at work and any external engagements with third parties. This Code aims to regulate and maintain order, structure and discipline among all employees to advocate industrial harmony at the workplace and during any external engagements, as well as to ensure that all applicable laws are adhered to. It is every employee’s responsibility to comply with the guidelines and policies stipulated in this Code as well as any updates or amendments issued by Lion & Lion from time to time.
This Code is not a comprehensive guide that covers every ethical situation or issue employees may face in their course of work. From time to time, Lion & Lion is entitled to update or amend this Code upon any changes in applicable laws, any changes to Lion & Lion’s internal policies, or any other relevant factors. Employees are expected to regularly visit this Code to ensure that they are properly updated and informed as to any amendments to the Code. It is also the employees’ continuous obligation to familiarise themselves with all applicable laws relating to their work responsibilities and Lion & Lion’s policies and regulations.
Employees shall refer to Lion & Lion’s People & Culture Department for clarification or guidance in any situation or circumstances not covered by this Code, or in case of any doubt.
In relation to any violation or suspected violation of this Code, employees shall report such violation or suspected violation to the People & Culture team/Department.
The employees acknowledge that non-compliance with this Code is a grave offence and will result in disciplinary action. Non-compliance with this Code may also result in the suspension or termination of the employee, and if warranted, legal proceedings against the employee, in addition to any disciplinary action.
This Code is to be read and applied together with all other related or applicable policies and guidelines issued and may be issued by Lion & Lion.
Standards of Conduct
Lion & Lion believes that a safe, clean and healthy work environment plays a major role in contributing to the happiness of the employees, and Lion & Lion is committed to providing a conducive workplace/work environment to achieve this goal. In return, employees are expected to play their role in also making sure that the workplace is safe, clean and healthy.
In Lion & Lion, our workplace consists of a diversified workforce and we promote equal opportunity, non-discrimination and fair treatment in all aspects of employment. We strongly believe in recruiting, developing and retaining employees based on their abilities, competency and merit. Together with Lion & Lion, the employees work together to uphold a working environment and culture where everyone is treated fairly and equally, regardless of age, religion, race, sex, ethnic origin, colour, marital status, disability, veteran status or sexual preference.
Lion & Lion strongly opposes any form of disrespect, harassment, threat, intimidation, violence or any other inappropriate behaviour in the workplace. It is every employee’s responsibility to report to the People & Culture team/Department any harassment, discrimination, threat, violence, and offensive or inappropriate behaviour an employee may face during his or her course of work. All complaints will be treated in the strictest confidence and shall be investigated. Upon the completion of the investigation, an appropriate action will be taken to stop and prevent such conduct. A flow chart of the complaint, reporting and investigation process can be found here.
Sexual harassment in the workplace is any unwelcome conduct of a sexual nature that might reasonably be expected or be perceived to cause humiliation or offense. It can be any conduct of a verbal, non-verbal or physical nature, including written and electronic communications, and may occur between persons of the same or different genders. Any employee that believes an incident or incidents of sexual harassment has taken place in the office, the employee should report this to the People & Culture team/Department. Such complaint(s) shall be taken seriously and shall be investigated swiftly and without prejudice. A flow chart of the complaint, reporting and investigation process can be found here.
The abuse of power/authority is defined as the misappropriation or the improper use of a position of power, influence or authority by a person towards others. Abuse of power can include a one-time incident or a continuous incident. Abuse of power may consist of conducts that create an abusive or a hostile work environment. Employees are requested to report any abuse of power incidents (or if they suspect that abuse of power has occurred in the workplace) to the People & Culture team/Department.
For the avoidance of doubt, decisions made through the proper use or process of managerial/supervisory responsibilities are not considered as an abuse of power/authority.
A flow chart of the complaint, reporting and investigation process can be found here.
Lion & Lion expects its employees to perform their duties diligently and avoid any influence of any substance that could affect their job performance or pose unacceptable safety risk to themselves and others. In situations where the serving of alcoholic beverages is permitted (e.g. functions or company-sponsored activities or events), employees are expected to consume the alcoholic beverages responsibly. Employees are also expected to behave/act reasonably and responsibly as well as to comply with all relevant laws and regulations in regard to the serving and the consumption of alcoholic beverages (e.g. employees shall not drink and drive, etc).
It is the employees’ duty to protect Lion & Lion’s confidential information from any unauthorised use or disclosure. It is also the employees’ responsibility to safeguard any confidential information of third parties that is in the employees’ possession and which the employees have access to in the course of their work.
Lion & Lion keeps data and records collected for a duration that is in accordance with the relevant statutory and regulatory requirements. It is everyone’s responsibility to retain and store proper records of data, etc to ensure compliance with Lion & Lion’s policies, legal and regulatory requirements.
Lion & Lion believes in doing business in an appropriate way hence internal procedures and controls have been developed to ensure that. Lion & Lion has set up proper internal controls, among others, in terms of the execution of external agreements where only designated persons are authorised to execute external agreements.
A conflict of interest exists when two or more contradictory interests relate to an activity by an individual or an institution. It is the employees’ responsibility to act in the best interests of Lion & Lion at all times, and are prohibited from misappropriating their knowledge or position gained in the course of their work or employment for any personal or private gain/advantage.
Employees are expected to disclose any potential or actual conflict of interest promptly to the People & Culture team/Department. Together with the employees, Lion & Lion shall assess and determine the existence and seriousness of the potential or actual conflict. The employees are expected to adopt the highest standard of conduct in times of doubt.
A flow chart of the complaint, reporting and investigation process can be found here.
Lion & Lion prides itself on being a professional organisation and is committed to acting with integrity in all its business relationships and dealings. Lion & Lion strongly prohibits its employees from offering, giving, soliciting or accepting any bribes by anyone of any third party in order to achieve any business or personal gain. Lion & Lion upholds and is committed to being in compliance with all applicable anti-bribery and anti-corruption laws. Employees are urged to report any suspicious activities to the People & Culture team/Department. A flow chart of the complaint, reporting and investigation process can be found here.
For the avoidance of doubt, the limit for any cash/gift/vouchers that can be received by employees is capped at USD50 per gift and an annual limit of USD250. Any amount that is more than the allowed limit should be declared to the People & Culture team/Department.
Money laundering can be defined as the process of concealing the proceeds of illegal activities or the act of converting or trying to make the sources of their illegal funds look legitimate (e.g. converting “dirty” money to a legitimate source of income or asset).
Employees are expected to be aware of the applicable anti-money laundering laws and should ensure that they are adequately and appropriately informed of any developments in the laws with regard to money laundering. Employees should always ensure that business dealings are conducted for legitimate business purposes, with customers who/that are reputable, and with funds that are legitimate. It is the employees’ responsibility to be mindful of the risk of Lion & Lion’s business being used for any money laundering activities and to report any suspicious activities to the People & Culture team/Department.
A flow chart of the complaint, reporting and investigation process can be found here.
Any employee who has any knowledge of, or suspects, any violation of this Code is encouraged to report his or her concerns through our holding company’s (Septeni) Whistleblower Hotline. Matters that may be the subject of whistleblowing and consultation using the Hotline include (but are not limited to);
Any complaints or disclosure shall be made to the following email address: email@example.com
Further information on the process (ie. investigations, etc) can be seen in Septeni’s Hotline Handbook.
Review of the Code of Conduct
Compliance with this Code will be monitored closely by the management of Lion & Lion and it’s designated person(s). This Code will be regularly reviewed to ensure that it continues to remain relevant and up to date in accordance with all applicable laws and regulations.
This Code of Conduct is approved by;
Fredrik Baek Gumpel