Conflict of Interest Policy

TAPiO Management Advisory Sdn. Bhd. is committed to objective professional and business decisions and to the interests it has agreed to serve. This Policy sets out how actual, potential and perceived conflicts of interest are identified, disclosed and managed.

A conflict does not necessarily mean misconduct has occurred. The risk arises when a relevant interest is hidden, unmanaged or allowed to influence a decision improperly.

This Policy applies to TAPiO directors, officers, employees and interns and, where relevant to services provided for TAPiO, consultants, contractors and other representatives.

Actual conflict

A present conflict between a person’s duties or TAPiO’s obligations and another interest.

Potential conflict

A situation that could develop into an actual conflict depending on future events.

Perceived conflict

A situation in which a reasonable external observer could question whether judgement or independence may be affected, even if no improper influence has occurred.

Conflicts may arise from:

• holding a financial or ownership interest in a client, supplier, competitor, potential investor, recommended partner or other counterparty;
• a close family or personal relationship with a person involved in a hiring, procurement, tender, government, investment or client decision;
• serving two clients whose interests are directly adverse in the same or closely related matter;
• outside employment, directorships, advisory roles, political or public appointments that intersect with TAPiO responsibilities;
• receiving gifts, hospitality, commissions, referral fees or personal benefits connected with a professional recommendation;
• using confidential information or a business opportunity learned through TAPiO for personal benefit;
• participating in a decision involving a business owned or controlled by the person or a close associate; or
• a personal investment or relationship that could reasonably affect professional independence.

Persons covered by this Policy must disclose a material actual, potential or perceived conflict promptly after becoming aware of it and, where practicable, before taking part in the affected decision or activity.

When in doubt, disclose. A disclosure does not itself imply wrongdoing. The duty to disclose applies even where the person believes they can remain objective.

Conflicts are assessed objectively and managed in proportion to the risk. Safeguards may include withdrawal from a decision, changes in responsibility, restrictions on information, informed client consent where appropriate and legally permissible, or declining or ending an engagement.

The person with the conflict is not the sole decision-maker on how it is managed.

Potential conflicts are considered before and during an engagement, taking account of relevant relationships, duties, confidential information and commercial interests. Working with several parties in the same sector does not automatically create a conflict.

New or changed circumstances are reviewed as they arise, with safeguards proportionate to the risk.

The disclosure requirement covers outside employment, board positions, advisory appointments, investments and substantial business activities that may overlap with a person’s TAPiO responsibilities. TAPiO may require safeguards where the outside role competes with TAPiO, uses TAPiO resources, creates reputational risk or affects the person’s ability to perform their duties.

Gifts, hospitality, travel, commissions, referral benefits and similar advantages must comply with the Anti-Bribery & Corruption Policy. A benefit that creates or appears to create personal influence over a professional recommendation must be disclosed and, where necessary, declined.

Confidential client, partner, government, employee or TAPiO information must not be used for personal gain or for the benefit of another party without authorisation. Business opportunities identified through a TAPiO role must not be diverted for personal benefit where doing so would conflict with TAPiO’s or a client’s legitimate interests.

TAPiO’s professional relationships with government bodies, embassies, institutions and decision-makers must be managed transparently. The disclosure requirement includes a personal, political, family, financial or other material relationship with a public official involved in an engagement where it could reasonably create an actual or perceived conflict.

Material conflict disclosures, decisions and agreed safeguards are documented in writing and handled confidentially.

Failure to disclose or appropriately manage a material conflict may result in reassignment, disciplinary action, termination of an engagement or other proportionate measures. Deliberate concealment of a conflict may be treated as serious misconduct.

Questions about potential conflicts can be raised with TAPiO management. Suspected concealment, corruption or retaliation can be reported through the arrangements in our Speak-Up and Whistleblowing Policy.