Last updated: June 2026
This Code of Ethics and Business Conduct (the "Code") sets out the standards of honesty, integrity, and professional behaviour that Pertama Partners ("Pertama," "we," "our," or "us") expects of everyone who works for or with us. Our reputation is built on the trust our clients, partners, and communities place in us, and this Code helps us protect that trust in everything we do.
This Code applies across the Pertama Partners group, comprising Pertama Partners AI Solutions Pte. Ltd. (Singapore, UEN 202619329D) and Pertama Partners AI Solutions Sdn. Bhd. (Malaysia, registration no. 202601017482, formerly 1679579-A) (together, "Pertama"). It applies to all directors, officers, employees, interns, and contractors across our Singapore and Malaysian operations. We also expect our partners and suppliers to act in a manner consistent with the principles set out here. The Code works together with our other policies, including our Anti-Corruption & Anti-Bribery Program and our Privacy Policy.
We hold ourselves to five core principles in all of our work:
We comply with all laws and regulations that apply to our business in every jurisdiction where we operate, including Singapore and Malaysia. Where this Code sets a higher standard than the law requires, we follow this Code. If you are ever unsure whether a course of action is lawful or consistent with this Code, ask before you act.
Pertama maintains a zero-tolerance approach to bribery and corruption in all forms. You must never offer, give, request, or accept any bribe, kickback, secret commission, or improper advantage, whether dealing with public officials or private parties. Full details, including our rules on gifts and hospitality, facilitation payments, and third-party due diligence, are set out in our Anti-Corruption & Anti-Bribery Program, which forms part of this Code.
You must avoid situations where your personal, family, or financial interests conflict, or appear to conflict, with the interests of Pertama or our clients. Examples include outside work that competes with us, personal relationships that affect business decisions, or accepting benefits that could influence your judgement. Disclose any actual, potential, or perceived conflict promptly so it can be managed openly.
We handle confidential and personal information with great care. You must protect the confidential information of Pertama, our clients, and our partners, and use it only for legitimate business purposes. We comply with applicable data protection law, including the Personal Data Protection Act 2012 of Singapore and the Personal Data Protection Act 2010 of Malaysia, and with the commitments in our Privacy Policy. Do not access, share, or store personal or confidential data except as authorised and necessary for your work.
We act in our clients' best interests, give honest and competent advice, and only take on work we are qualified to perform. We are truthful in our marketing, proposals, and reporting, and we do not overstate our capabilities or results. We deliver what we promise and communicate openly if circumstances change.
We compete fairly and on the merits of our work. You must not engage in dishonest, deceptive, or anti-competitive practices, and you must not take unfair advantage of anyone through manipulation, concealment, abuse of confidential information, or misrepresentation.
Modest, reasonable, and infrequent business gifts and hospitality may be acceptable, but only where they could not be seen as an attempt to improperly influence a decision. Any gift or hospitality above RM 250 (approximately SGD 75) per occasion must be declared to the Compliance Contact and recorded. Cash and cash equivalents are never acceptable. Follow the detailed rules in our Anti-Corruption & Anti-Bribery Program, and seek guidance when in doubt.
We use Pertama's and our clients' assets responsibly and only for legitimate business purposes. This includes physical property, funds, equipment, systems, and intellectual property. Protect these assets from loss, theft, damage, and misuse, and respect the intellectual property rights of others.
In the course of our work we may learn information that is not public. You must not misuse such information, disclose it improperly, or use it for personal gain or the gain of others. Treat all non-public client, partner, and company information as confidential.
We are committed to a workplace free from harassment, bullying, discrimination, and violence. We treat everyone fairly regardless of race, religion, gender, age, nationality, disability, or any other protected characteristic, and we make employment decisions on merit. We value diversity and inclusion, and we provide a safe and healthy working environment.
When communicating publicly or on social media in a way connected to Pertama, be honest, respectful, and professional. Do not disclose confidential information, do not speak on behalf of Pertama unless authorised, and make clear when you are expressing a personal view.
If you become aware of any actual or suspected breach of this Code, of the law, or of our policies, you have a responsibility to speak up. You can raise a concern in confidence to:
Pertama Partners
Compliance Contact
Email: michael@pertamapartners.com
Concerns raised in good faith will be treated confidentially and investigated appropriately. Pertama prohibits any form of retaliation against anyone who reports a genuine concern or who refuses to take part in conduct that breaches this Code, and the identity of the person raising the concern will be protected so far as reasonably possible and as permitted by law. Concerns may be raised, and will be received and addressed, in the appropriate local language, including English, Bahasa Malaysia, and Mandarin.
Every person to whom this Code applies is expected to read it, understand it, and act in accordance with it. All personnel receive training on this Code and on our anti-corruption standards as part of onboarding and at least annually thereafter, and are asked to acknowledge in writing that they have read and understood the Code. Compliance with this Code is a condition of working with Pertama. Breach of the Code may result in disciplinary action, up to and including termination of employment or engagement, and may also have legal consequences.
This Code is adopted by the Pertama Partners group:
We review this Code periodically and update it as needed. The most current version is published on this page with the revision date shown above. If you have any questions about this Code or how it applies to a situation, please contact us at michael@pertamapartners.com.
