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Governance & Business Ethics

Built on Integrity. Governed with Purpose.
At PXP, good governance and ethical conduct shape how we operate. We act responsibly, decide transparently and remain accountable to our clients, partners and stakeholders.

Doing the Right Thing is Part of How We Deliver Excellence

Integrity is one of the core Company Values of Project Xcellence Partners Sdn. Bhd. (PXP). It underpins how we conduct our business, serve our clients, engage our consultants and partners, and make professional decisions. At PXP, excellence is not measured only by what we deliver, but also by how we deliver it. We are committed to conducting our business responsibly, ethically and professionally, in compliance with applicable laws, regulations, contractual obligations and client requirements.

These commitments apply, as relevant, to PXP’s directors, employees, consultants, representatives and other parties acting on behalf of the Company.

1) Ethics, Integrity & Professional Conduct

PXP is committed to conducting its business honestly, fairly and professionally. We expect everyone representing or working with PXP to:

  • act with integrity and in good faith;
  • ⁠exercise sound professional judgement;
  • provide information honestly and accurately;
  • avoid misleading, deceptive or improper conduct;
  • comply with applicable laws, contractual obligations and client requirements; and
  • protect the reputation, interests and legitimate expectations of PXP and its clients.

Actual, potential or perceived conflicts of interest should be disclosed promptly so that they can be appropriately assessed and managed.

We believe that trust is built through competence, transparency, accountability and consistent ethical behaviour.

2) Anti-Bribery & Anti-Corruption

PXP adopts a zero-tolerance approach towards bribery, corruption, fraud and improper business practices.

No employee, consultant, representative or other person acting on behalf of PXP shall directly or indirectly:

  • offer, promise, give or authorise an improper payment, benefit or advantage;
  • request, solicit or accept an improper payment, benefit or advantage;
  • use gifts, hospitality, commissions or other arrangements to improperly influence a decision; or
  • engage in conduct intended to improperly influence a business, professional or official decision.

PXP is committed to complying with applicable Malaysian anti-bribery and anti-corruption laws and with relevant integrity requirements imposed by our clients.

Business opportunities should be pursued and secured through professional capability, competence, value and ethical conduct.

3) Human Rights & Ethical Labour

PXP is committed to respecting human dignity and recognised principles of human rights, and to complying with applicable laws and regulations relating to employment and labour practices.

PXP does not tolerate:

  • forced or compulsory labour;
  • child labour;
  • human trafficking or modern slavery;
  • discrimination, harassment or abuse;
  • exploitation or coercive employment practices; or
  • unsafe or degrading working conditions.

We are committed to fair, respectful and safe working practices.

PXP also expects employees, consultants, contractors, suppliers and other business partners acting on our behalf to uphold comparable standards of responsible and ethical conduct.

Any credible human rights or ethical labour concern brought to PXP’s attention will be reviewed and, where appropriate, corrective action will be taken.

4) Speak-Up, Concerns & Non-Retaliation

PXP encourages employees, consultants, clients, suppliers and other stakeholders to raise genuine concerns regarding suspected:

  • bribery or corruption;
  • fraud or dishonesty;
  • conflicts of interest;
  • harassment or discrimination;
  • ⁠human rights or labour concerns;
  • misuse of confidential or personal information;
  • serious professional misconduct; or
  • other unlawful or unethical conduct connected with PXP’s activities.

Concerns may be raised through PXP’s official communication channels or directly to the Company’s management.

Reports will be treated seriously and handled as confidentially as reasonably practicable, taking into account the nature of the matter and any applicable legal or regulatory requirements.

PXP does not tolerate retaliation against any person who raises a genuine concern in good faith.

5) Data Privacy, Confidentiality & Information Protection

PXP respects the privacy of individuals and is committed to protecting personal, confidential and proprietary information entrusted to us.

Personal information will be collected, used, disclosed, retained and managed only for legitimate business, contractual, administrative, regulatory or compliance purposes and in accordance with applicable data protection requirements.

Employees, consultants and representatives of PXP are expected to safeguard confidential information belonging to:

  • PXP;
  • our clients;
  • our consultants and employees;
  • business partners; and
  • other stakeholders.

Reasonable measures should be taken to prevent unauthorised access, disclosure, loss, alteration or misuse of information.

PXP also expects appropriate care when using cloud services, digital platforms and artificial intelligence technologies. Confidential, personal or proprietary information must not be uploaded or disclosed to unauthorised third-party systems or platforms.

PXP is committed to complying with applicable Malaysian personal data protection requirements, including the Personal Data Protection Act 2010 and applicable amendments and regulations.

6) Anti-Money Laundering & Financial Crime

PXP is committed to conducting business only for legitimate purposes and does not knowingly participate in, facilitate or support:

  • money laundering;
  • terrorist financing;
  • fraud;
  • concealment of proceeds of crime; or
  • other unlawful financial activities.

Where appropriate to the nature and risk of a transaction, PXP may undertake reasonable due diligence on clients, consultants, suppliers, business partners or transactions.

This may include seeking information concerning identity, ownership, commercial purpose, source of funds or other relevant matters.

PXP will comply with applicable legal and regulatory requirements concerning financial crime and will cooperate with lawful requests from competent authorities where required.

7) Sanctions & Export Control Compliance

PXP is committed to complying with applicable sanctions, trade restrictions and export control requirements relevant to its business activities.

PXP will not knowingly undertake transactions, provide services or participate in arrangements where doing so would contravene applicable legal sanctions, trade restrictions or prohibitions.

Where warranted by the nature of an engagement, PXP may undertake appropriate checks concerning:

  • counterparties;
  • beneficial ownership;
  • ⁠jurisdictions;
  • end users;
  • ⁠intended use of services or information; and
  • other relevant compliance considerations.

8) Conflicts of Interest

Professional independence and objectivity are important to PXP. Employees, consultants and representatives are expected to disclose any actual, potential or perceived conflict of interest that could affect, or reasonably appear to affect, their professional judgement or PXP’s obligations to a client. Where a conflict is identified, PXP will determine appropriate measures to manage it. Where the conflict cannot reasonably be managed, PXP may decline, withdraw from or terminate the relevant engagement.

9) Responsible Business Relationships

PXP expects organisations and individuals acting on our behalf to conduct themselves in a manner consistent with the principles stated on this page.

Depending on the nature of an engagement, consultants, suppliers, contractors and other business partners may also be required to comply with additional requirements relating to:

  • ethics and integrity;
  • ⁠anti-bribery and corruption;
  • ⁠confidentiality;
  • ⁠information security;
  • ⁠health, safety and environment;
  • sustainability;
  • professional conduct; or
  • client-specific compliance requirements.

Serious misconduct, unethical behaviour or material non-compliance may result in PXP reconsidering, suspending or terminating the relevant business relationship.

Our Commitment

Responsible business is an ongoing commitment.

As PXP grows, we will continue to review and strengthen our governance practices in response to evolving regulatory expectations, professional standards, business risks and the needs of our clients and stakeholders.

Our aim is straightforward: 'Deliver excellence. Act with integrity. Earn trust.'

Project Xcellence Partners Sdn. Bhd.
Registration No. 202501022032 (1623445-V)
Effective: October 2026
Last Reviewed: October 2026