17th September 2015

NO. 95, Jalan Masai Utama 1,

Taman Masai Utama,
81750 Masai,
Johor
Dear TMG Pyramid Sdn Bhd Supplier,

COMPASS GROUP CODE OF BUSINESS CONDUCT

You are receiving this letter as your company has been invited to tender for supply to Compass Group
Asia & Pacific
As part of Compass Groups corporate responsibility, we would like to remind you of your obligations
under our Code of Business Conduct (Compass CBC), and detail is enclosed to this letter.
As a supplier of Compass, you must carefully review the Compass CBC, ensure that the Compass
CBC is disclosed to all your personnel; and undertake and agree that, in connection with your
performance under your agreement with Compass, all of your personnel shall act consistently with the
principles of the Compass CBC.
Please read the documents, and then acknowledge your receipt by signing this letter below, including
a job title and date. Return to Compass Group Supply Chain with your RFP submission.
We thank you for adherence to our Code of Business Conduct and Code of Ethics, and for your
request for proposal submission.
I hereby agree that I have read, understand and will adhere to the Compass Group Code of Business
principles.
SIGNED for and on behalf of TMG Pyramid Sdn Bhd by its duly authorised representatives:

Signature

FAZIRA DIANA
SALES COORDINATOR
Date:

17th September

2015

Compass Group Malaysia Sdn Bhd

Suite 25.03, Level 25, Johor Bahru City Square Office Tower,
106-108, Jalan Wong Ah Fook,
80000 Johor Bahru, Johor

Details regarding Compass Group Code of Business Conduct

1. Supplier shall comply with the Compass Group Code of Business Conduct, AntiCorruption Undertakings and the Code of Ethics, as set out below. Any noncompliance to the provisions may lead to immediate termination of this Agreement.
(A) Compass has a Code of Business Conduct (the Compass CBC). An electronic

copy can be downloaded from the following web site:

http://www.compass-group.com/1124.htm
Supplier shall:
o

Carefully review the Compass CBC;

Ensure that the Compass CBC is disclosed to all Suppliers personnel; and

Undertake and agree that, in connection with Supplier performance under this
Contract, all Supplier personnel shall act consistently with the applicable
principles of the Compass CBC in all material respects.

(B) Anti-corruption undertakings

As a matter of corporate policy and as strictly prohibited under the Compass
CBC, Compass expressly prohibits payments or offers of bribes and/or
facilitation payments (otherwise known as grease payments) in connection
with Compass business operations by any supplier or agent engaged to
provide goods or services to Compass.
1. Supplier undertakes and agrees that in connection with this Contract and
the transactions contemplated by this Contract, it will comply with all
applicable laws, rules, regulations, decrees and/or official governmental
orders of the United Kingdom, the United States of America and the country
of operations relating to anti-corruption and anti-money laundering.
2. Supplier agrees, undertakes and confirms that it and each member of the
Supplier Group, has not made, offered, promised to make, authorized the
making of, and will not make, offer, or promise to make, or authorize the
making of, any payment or other transfer of any financial or other advantage
or anything else of value, including without limitation the provision of any
funds, services, gifts or entertainment, directly or indirectly to any:
(a)
(b)

government official;
director, officer, employee or agent/representative of an actual or
prospective counterparty, supplier or customer of Compass;

Compass Group Malaysia Sdn Bhd

Suite 25.03, Level 25, Johor Bahru City Square Office Tower,
106-108, Jalan Wong Ah Fook,
80000 Johor Bahru, Johor

(c)

director, officer, employee or agent of Compass or its co-ventures or

any of its or their affiliates;

(d)

political party, official of a political party, or candidate for public office;

(e)

agent or intermediary for payment to any of the foregoing; or

(f)

other person or entity;

for the purpose of obtaining, rewarding or influencing the award of this

Contract or for any improper advantage or improper purpose or where it
would be improper for the person to accept such an advantage in connection
with the performance of this Contract and the transactions contemplated
hereunder or in connection with any other business transactions involving
Compass, if and to the extent that to do so is or would be in violation of or
inconsistent with the principles or requirements of any anti-bribery or antimoney laundering laws applicable to Compass or to Supplier, or to their
respective parent companies, including, but not limited to, the UK Bribery Act
2010, the UK Anti-Terrorism, Crime and Security Act 2001, the U.S. Foreign
Corrupt Practices Act and successor legislation, legislation implementing the
OECD Convention on Combating Bribery of Foreign Public Officials in
International Business Transactions or the United Nations Convention Against
Corruption, and/or the anti-corruption or anti-money laundering laws of the
country of operations.
(C) Compliance with Ethics: Supplier will not in any way, offer directly or indirectly,
any illegal payments, remuneration, gifts or comparable benefits to any employee
which are intended or perceived to obtain business or uncompetitive favors for the
conduct of its business excepting nominal gifts which are customarily given and are
of commemorative nature for special events.

Compass Group Malaysia Sdn Bhd

Suite 25.03, Level 25, Johor Bahru City Square Office Tower,
106-108, Jalan Wong Ah Fook,
80000 Johor Bahru, Johor