Policy
Discover our commitment to compliance through our detailed policies.
Purpose
This Conflict-of-Interest Policy (“Policy”) is intended to guide the Associates to conduct business responsibly, with integrity, honesty, morality, and adherence to high-quality professionalism and ethical standards.
This Policy is intended to ensure that all Associates practice professional independence and avoid any relationships or obligations that might conflict with the interest of ZTMB. Such relationships or obligations may impair their ability to make objective and professional judgement when performing their duties and give rise to conflicts of interest.
This Policy aims to prevent any conflict or potential conflict between ZTMB’s interests and our personal interests. It establishes the standards and requirements for undertaking business transactions with complete loyalty and without personal conflicts.
Governance
Any modifications to this Policy shall be monitored and documented for further reference, and any changes must be implemented only with the Compliance Officer and/or Head of Human Resources’ prior approval.
The Compliance Officer and/or Head of Human Resources shall review and update this Policy on a regular basis to reflect applicable law(s) and/or the most recent notices issued by the regulatory authorities from time to time.
The Compliance Officer and/or Head of Human Resources shall monitor and assess the efficacy and execution of the compliance principles outlined in this Policy on a regular basis, taking into account its appropriateness, adequacy and effectiveness.
Applicability
This Policy applies to all of ZTMB’s employees, Board Members, contractors, consultants, trainees, agents, as well as its subsidiaries, affiliates, group companies, and individual or entities contractually bound across the world.
Policy Framework
CONFLICT OF INTEREST
A conflict of interest arises when the employee is placed in a position where their personal interest interferes with the interests of ZTMB. Such personal interests may exist when the employee uses its position or role in the Company to advance personal gain, including benefits for family and friends, where such interests may conflict or potentially conflict with the interests of ZTMB.
Scenarios
The following are some examples of circumstances, situations or relationships that may result in an actual, potential or perceived conflict of interest:
Participating in any form of paid or unpaid, verbal or contractual relationship, directly or indirectly, with any individual or entity with whom ZTMB has a present or continuing relationship in a personal capacity.
Conducting business as the representative of ZTMB with a company in which the Associate has a financial or commercial stake or with which they are otherwise associated. This interest may be held directly in a personal capacity or indirectly through a closely connected individual.
Acting as a consultant or advisor in any capacity to any government, regulatory body, industry association, which has the potential to impair ZTMB’s operations.
Accepting personal gifts, illicit payments, compensation, contributions, or equivalent perks from competitors, clients, suppliers or potential suppliers. Accepting or providing such gifts or hospitality that may sway the objective and professional judgement when performing their duties for ZTMB. All such transactions must adhere to the guidelines outlined in the Anti-Bribery and AntiCorruption Policy.
Engaging in business transactions with parties linked to the Associate or their family members which are, or appear to be, detrimental to ZTMB’s interests.
Relatives Working in The Company
A ‘Relative’ or a ‘Closely related person’ is defined by the organisation as someone who is closely related by blood or marriage or has other significant relationship (such as a spouse, son, daughter, mother, father, brother, sister, grandparent or grandchildren, stepparent, or step-children, step-sister, step-brother, in-laws, aunty, uncle, nephew, niece, first cousin, domestic partner), or any other relationship that the organisation deems to be a conflict of interest. The term “Relative” is defined as follows in the family tree:
Relatives should not work in a position where one relative can affect the employment of another relative through decisions, recommendations or judgements regarding to daily working, job allocation, appraisal, remuneration, hiring, retention, transfer, leave requests, and so on.
All present and prospective Associates must provide the following information in accordance with the declaration as attached in Annexure A:
All relatives employed within the organisation or its subsidiaries;
If they are shareholders or owners of companies that engage directly or indirectly with ZTMB or its subsidiaries; and/or
When their relative is an investor, owner or employee of a company that collaborates with ZTMB as a business partner or vendor.
If a relative is found to be working in the same function or department, the organisation will ensure that either of the Associate is reassigned to a different role or department based on the their qualifications and background.
Every Associate is responsible for disclosing any change in their relationship with respect to another associate who falls within the category of a relative, such as becoming related to another Associate (for example due to marriage, or any business association with ZTMB or its subsidiaries).
ZTMB shall not, under any circumstances, employ relatives in a supervisorsubordinate relationship or relatives in the same area of influence. Applicants who are relatives will not be assigned to a position that is in a reporting relationship or within the same function as a known relative. Any relative proposed for employment by ZTMB or any of its subsidiaries must be disclosed prior to the employment decision.
Hiring of relatives as interns on a temporary basis or for project work assignments will be based on merit and the organisation’s recruiting processes.
Relationships with Competitors
Associates shall not own or purchase shares in any competitive Company without prior written consent unless the shares are acquired through listed stock.
Any relative who works for a competitor, as well as any such relationships that may establish while working, must be declared using the method provided (as per Annexure A).
Employment Outside the Company
Associates are not permitted to accept any employment or labour – remunerative or otherwise, outside ZTMB that may impede, restrict or impair their capacity to carry their assigned tasks and obligations at ZTMB.
Academic speaking engagements for restricted hours, whether remunerative or non-remunerative, may be approved if they do not interfere with the Associates’ job at ZTMB; nevertheless, prior notification and approval of such engagement is required from ZTMB Management Board.
All services or positions, whether remunerative or non-remunerative, including affiliation with charitable, not-for-profit, non-commercial organisations or any type of involvement, consulting or support in product creation, must be reported to ZTMB’s Management Board.
Reporting and Complaint Process
ZTMB is aware that some conflicting interests, such as a closely related individuals employed with a customer or vendor, may be unavoidable or impractical to avoid.
This Policy is intended to uphold and promote the aforementioned framework. ZTMB serves as a mechanism for all parties involved to report genuine concerns pertaining to unethical behaviour, actual or suspected fraud or violation of this Policy without fear of retaliation.
Any potential or actual conflict of interest must be reported to the Compliance Officer or Head of Human Resources as soon as possible via the channel provided (as per Annexure A). Associates must declare any possible or present conflict of interest during their employment with ZTMB or at the time of joining.
In the meantime, all related work in ZTMB must be avoided with the contentious party. An adequate response shall be delivered within thirty (30) days of the declaration’s submission.
Policy Violation
Any violation of this Policy, including failure to disclose potential violations of compliance principles or relevant applicable legislation may result in disciplinary actions, including termination, suspension of employment or penalties.
Policy Exceptions
Any deviation from the principles outlined in this Policy must be approved in advance by the Compliance Officer, Head of Human Resources or the Management Board of ZTMB.
Disclaimer Policy
The contents of the website are provided merely for informative and general educational purposes only and should not be construed as the provision of legal, financial, taxation or investment advice of any form or kind by ZTMB, and shall not at any time be relied upon as such.
While ZTMB strives to provide the contents on this website as timely and accurate as possible, we make no representations, promises or guarantees of any kind, express or implied, as to the accuracy, completeness or reliability of the contents, products, services or related information generated on our website.
ZTMB reserves the rights to make changes on the contents of the website from time-to-time ZTMB shall not in any event be liable for any direct or indirect loss or damage suffered by any individual or entity arising from reliance of, or in connection with such information or any part thereof.
ZTMB urge you to conduct your own research and consult with your independent professional advisor prior to taking any action or investment related decisions based on information appearing on this site or any site to which it may be linked.
This website may contain links to other independent third-party websites (“Linked Sites”). The inclusion of any hyperlinks to Linked Sites does not imply an indication of endorsement by ZTMB of the Linked Sites or any part of its contents. Such Linked Sites do not form part of our websites and are provided solely for your convenience reference only.
The information and contents that contained at the Linked Site, including any amendments or updates thereto, are not under the control of or the responsibility of ZTMB, and shall not be deemed to be provided by ZTMB. ZTMB make no warranty as to the accuracy or reliability as to the information contained on the Linked site, and ZTMB expressly disclaims all liability and responsibility for any direct or indirect loss or damage incurred or suffered by any party arising out of, in connection with or as a result of such Link Sites. Therefore, ZTMB encourage you to make your own independent judgment regarding the interaction with these Linked Sites, and to do so entirely at your own risk.
All rights are reserved. No part of the website and no content may be copied, reproduced, republished, uploaded, posted, encoded or distributed in any way without ZTMB’s express prior written consent. In order to enable ZTMB to perform our services, offer our products to you, and or to fulfil partly or all of the services requested by you, ZTMB is bound by domestic and international laws and regulations to process personal information and data about you, including but not limited to your name, residential address, contact information, occupation, nature of business and source of funds. ZTMB will only process all such information in accordance with applicable Anti Money Laundering and Personal Data Protection laws in the relevant jurisdiction. This Disclaimer policy shall be read in conjunction with our Terms of Use (TOU) and Privacy Policy.
Terms of Use (TOU)
Welcome to https://www.zicotrust.com.my/, the official website of ZICO TRUST (M) BERHAD (also referred to as “ZTMB”, “We”, “Our”, or “us” below). By registering or otherwise using any of our websites, products, services, or any content that we made accessible through the websites or services, you accept these Terms of Use.
These Terms of Use, Privacy Policy and Disclaimer Policy, all of which are hereby expressly incorporated by reference along with any ordering documents, shall form a legally binding agreement between you and ZTMB. We reserve the right to modify these Terms of Use at our sole discretion as we deem fit. You are only permitted to use the services and products if you have reached the age of majority or legal age in your jurisdiction (generally 18 years of age or older) and have the capacity to enter into legally binding contracts under applicable law. You are not permitted to access or otherwise use this website, services and products if you do not agree to this Terms of Use.
Copyright
The name “ZTMB”, its logo, design marks, and artwork are the property of ZTMB and its owners, and are protected from infringement by copyright and other intellectual property laws in Malaysia and internationally. Any use of the content found or published here, including reproduction, representation and other uses are explicitly forbidden. Since ZTMB respects copyrights, we prohibit users of the services or products from publishing, uploading, or otherwise transmitting any content that infringes on the intellectual property rights of others. No content or materials contained on this website may be used in any manner for another website or publication.
Proprietary Rights and Permitted Use
You hereby acknowledge and agree that ZTMB (and its owners) shall exclusively own all rights, title, and interest in and to the website and its content, including but without limitation, any patents, patent rights, business methods, copyrights, trademarks, trade secrets, inventions, know how and all other intellectual property rights pertaining thereto.
You agree not to make, copy, display, modify, rent, loan, lease, sell, distribute or create derivative works of this website, in whole or in part, unless expressly authorised by ZTMB herein. You also agree not to access or attempt to access this website by any means other than through the interface that is provided by ZTMB.
Termination or Discontinuance
ZTMB may, at any time and for any reason, modify, suspend, cease, discontinue or terminate the operation of or access to, all or any part of the services with or without notice. You acknowledge that any modification, suspension or termination of the website shall not subject ZTMB or its owner to any liability to you or to any third party.
Links to Third-Party Websites
Links to websites run by third parties may be made available by ZTMB on our website solely for the convenience of users, you will leave our website if you click on these links. If you decide to access any of the linked websites, you do so at your own risk and are responsible for taking all necessary precautions to protect yourself from viruses and other harmful components. ZTMB does not guarantee, represent, support or in any way sponsor any linked websites, the information appearing on them or any of the products or services mentioned therein. The links do not suggest that ZTMB has the legal right to use any trademarks, trade names, logos or copyright symbol displayed in or accessible through the links, nor do they imply that any linked website has the legal right to use any trademarks, trade names, logos, copyright symbols of ZTMB.
You acknowledge that your use of any third-party websites or resources, including, without limitation, any content, information, data, advertising, products or other materials on or accessible through such websites or resources, is at your own risk and is governed by the Terms of Use that are specific to such websites and resources.
Consent to Communication
You fully consent that ZTMB, or our authorised employees, officers and/or agents may use the contact number or email address you provided us with to contact you. By using the website or sending emails to info@zicotrust.com.my constitutes electronic communication with ZTMB, and you agree to receive any message relating to your use of the website electronically. We may communicate with you by sending emails or notices that we publish on the website.
You agree and acknowledge that electronic delivery of all agreements, notices, disclosures and other communications to you satisfies any legal requirement that such communications be in writing. All notices from ZTMB intended for receipt by a user in connection with the website shall be regarded as delivered and effective when sent to the email address provided by the user on or through our website.
Discretion and Risk
ZTMB and its owners shall not be liable for any damages of any kind arising from the use of the website, including, but without limitation, direct, indirect, incidental, punitive or consequential damages. Any information, statements or opinions viewed, downloaded or otherwise obtained through the use of the website are done at your own discretion and risk.
Prevailing Language
The entire content of this website is written in English and shall be deemed the original document. In the event of any discrepancy between this version and any translation thereof, the English language version shall control in all respects and prevail.
Errors
The entire content of this website is believed to provide a complete and accurate depiction of all facts and assertions. Nonetheless, interested parties should conduct their own research to ensure that they are satisfied with all aspects. It is normal to make mistakes and omissions, whether due carelessness or a technological issue.
Indemnification
To the extent authorised by law, you agree to defend, indemnify and hold ZTMB, its employees, officers, directors, affiliates and agents from and against all claims, losses, expenses, damages and costs, including reasonable attorneys’ fees, resulting directly or indirectly from or arising out of:
Your violation of the terms;
Your failure to verify the copyright licence, attribution, and other information associated with content obtained through the use of ZTMB;
The material you make accessible on any of the services and products; and/or
Your usage of any of the services and products.
Privacy Policy
In accordance with our Privacy Policy, ZTMB is dedicated to managing the information and data we collected through our services responsibly. To learn how we gather and handle your personal information, please review the Privacy Policy.
Governing Jurisdiction
You agree that any disputes relating to the website, this agreement or the Privacy Policy, it shall be governed by and construed in accordance with the laws of Malaysia.
General
ZICO Trust (M) Berhad (“ZTMB”) and its subsidiaries are committed to safeguarding your privacy in strict compliance with the provisions of the Personal Data Protection Act 2010 ("PDPA"). This Privacy Policy describes, inter alia:
The categories of personal data collected by ZTMB, whether directly or indirectly, and the mechanisms employed in obtaining such data;
The purposes for which such personal data is processed, stored, or utilised by ZTMB;
The categories of third-party recipients, including both domestic and international entities, to whom such personal data may be disclosed, pursuant to the statutory and contractual obligations of ZTMB; and
Your statutory rights under the PDPA, including the right to request access, rectification, removal or limitation of your personal data, as well as the right to withdraw consent, where applicable.
For the purposes of this Privacy Policy, “Personal Data” refers to any information that directly or indirectly identifies you and has been or will be provided by you or collected by ZTMB, including but not limited to your name, National Registration Identity Card number, residential or correspondence address, telephone number, email address, photographic or biometric data, personal preferences, particulars of third parties or beneficiaries, financial and banking information, and other identifying data. The term “Personal Data” also includes sensitive data as defined under Section 4 of the PDPA, including but not limited to data related to physical or mental health, political affiliations, religious beliefs, and data concerning any criminal record.
Failure to provide your Personal Data to ZTMB as stipulated in any of its deeds, agreements, forms, applications, or otherwise required by ZTMB, whether through manual or electronic means, may result in ZTMB being unable to fulfil its contractual obligations, including but not limited to, the inability to process applications, execute trust deeds, maintain accurate client records, or provide ongoing trust-related services. Such non-compliance will inhibit ZTMB from offering, continuing, or fulfilling any trust-related services to you.
By providing ZTMB with any Personal Data related to third parties, including but not limited to beneficiaries, you confirm that the necessary consents from such third parties have been obtained in full compliance with the PDPA for the purposes outlined in this Privacy Policy.
Collection of Personal Data
ZTMB may collect your Personal Data from you, its Authorised Agent(s), other party(ies), or publicly available source(s), including but not limited to:
When you enter into contractual relations with ZTMB or sign up to its product(s) and service(s);
When you submit any formal documentation, including forms, agreements, or declarations, whether electronically or manually;
When you engage with ZTMB for any inquiries, grievances, or feedback, whether through in-person visits, electronic correspondence, or other digital platforms;
When you initiate or during the course of any business relationship transaction with ZTMB;
When you visit any premises or events organised by ZTMB;
In the course of any employment-related interactions, including job applications;
When you visit or navigate the ZTMB website;
When you participate in any of the ZTMB corporate events or training sessions;
When ZTMB acquires your Personal Data from publicly available sources, business affiliates, or third-party references, including through agents, financial institutions, or credit reporting agencies.
Use of Personal Data
Your Personal Data may be used, recorded, stored, archived, disclosed or otherwise processed by and/or on behalf of ZTMB, including but not limited to the following purposes as stated below:
To conduct and fulfil the duties and obligations related to the provision of trust services, including but not limited to carrying out any and all trustee-related activities, for operational or internal management purposes, as may be applicable;
To conduct anti-money laundering and counter-terrorist financing assessments, Know Your Customer (KYC) procedures, and other compliance purposes in adherence to regulatory standards and protocols;
To assess, process, or facilitate any deeds, agreements or applications submitted in relation to ZTMB’s services;
To improve and develop ZTMB’s products and services to better meet your requirements;
To respond to your enquiries, complaints, or feedback;
To manage or facilitate the operation of ZTMB’s services in a manner compliant with statutory or contractual requirements;
To perform any data matching exercises for the purpose of updating your Personal Data from time to time;
To facilitate and process any requests for modifications, variations, terminations, or renewals of ZTMB's products or services;
For any legal proceedings or potential litigation, if applicable;
If required by law or in good faith, to comply with any law enforcement, court orders or legal process, and/or to protect and defend the rights or property of ZTMB; and
Any activity related or incidental to any abovementioned purposes.
Disclosure of Personal Data
In the course of the providing, managing and/or operating ZTMB products and services to you, ZTMB may provide or disclose your personal Data, to the extent necessary, to the following parties for the purposes set out in Clause 3, subject at all times to any applicable laws or practice, guidelines, obligations and/or directives from any regulatory authorities:
any officers, employees, or directors of ZTMB or its subsidiaries insofar as necessary to fulfil their duties and obligations;
any companies and/or organisations that act as agents, service providers and/or professional advisers engaged by ZTMB (if applicable);
any person authorised to act as an agent of ZTMB or its subsidiaries in relation to the distribution of products and services offered by ZTMB or its subsidiaries (if applicable);
third party credit reference and/or reporting agencies registered under the Credit Reporting Agencies Act 2010, any authority including Bank Negara Malaysia, any other governmental or regulatory authority or body, and any insolvency department;
any agent or third-party service provider, within or outside ZTMB responsible for executing transactions or processing instructions on your behalf; and
any other authorised third party ZTMB believes in good faith to be tendering payment on your behalf.
ZTMB reserves the right to transfer your Personal Data to jurisdictions outside Malaysia, including countries where data protection laws and privacy regulations may differ. ZTMB will take all necessary measures to ensure that the transfer of such Personal Data complies with applicable legal and regulatory requirements to ensure that your Personal Data remains secure and is processed in a manner consistent with the standards of data protection and privacy upheld by ZTMB.
Protection of Personal Data
ZTMB ensures that your Personal Data is highly secured and greatly valued as much as ZTMB’s assets. ZTMB regularly reviews and implements up-to-date technical and organisational security measures when processing your Personal Data.
ZTMB ensures that all its employees and authorised personnel are well-trained to process your Personal Data securely and are bound by strict confidentiality agreements. ZTMB has a zero-tolerance policy for breaches of Personal Data, and any such breach may result in the employee or authorised personnel being subject to disciplinary actions, including termination and legal action.
ZTMB’s website may contain links to third-party websites, which are subject to their own respective privacy policies and ZTMB is not responsible for their data collection policies, procedures or content, and ZTMB is not liable for any damages resulting from any breaches related to unauthorised and/or fraudulent use of your Personal Data.
Access Rights to Personal Data
You may access certain Personal Data held by ZTMB under the applicable data protection laws of Malaysia. Should you desire to access your Personal Data or believe that such Personal Data kept by ZTMB is inaccurate, incomplete, misleading, or out of date, or you have any inquiries regarding the limitation of processing certain information, you may, at your discretion, request in writing via email at info@zicotrust.com.my along with the relevant supporting documentation.
ZTMB reserves the right to charge administrative costs which are directly related to and necessary for the processing of any request for Personal Data.
Retention of Personal Data
ZTMB shall retain your Personal Data to the extent where its legal or business purposes for acquisition or use remain applicable, until the information has fulfilled its intended purpose, or unless otherwise compelled by law, mandated by government authority, or required for legal proceedings.
Consent
By submitting your Personal Data, you agree to the use of such data as described in this Privacy Policy, including any amendments. ZTMB may review and update this Privacy Policy from time to time to reflect changes in the law, business practices, procedures, and structure of ZTMB. By continuing to use the service, you indicate your acceptance of any such modifications.
ZTMB will take reasonable and best efforts to safeguard your personal data within its possession and control by implementing reasonable security measures to mitigate the risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or similar threats. Despite these measures, ZTMB does not guarantee the absolute security of any personal data that may have collected from or about you. ZTMB holds no liability for any damages resulting from any personal data breaches, on unauthorised and/or fraudulent use of your personal data.
Contact Information
Should you have any query(ies), concern(s), or complaint(s) in relation to this Privacy Policy or how ZTMB handles your Personal Data, kindly contact ZTMB at :
ZICO Trust (M) Berhad
Mailing address :
102 & 202, Block C,
Pusat Dagangan Phileo Damansara 1,
Jalan 16/11, Seksyen 16,
46350 Petaling Jaya,
Selangor, Malaysia.
Contact no.: +603 7932 3314
Email address: info@zicotrust.com.my
