Code of Conduct And Policies



The KBZ Group Code of Conduct has been in place for almost half a decade and applies to staff at all levels within our group. This includes Directors both within the group and all its subsidiaries. All group Directors have signed up to the Code of Conduct. All our staff across the KBZ subsidiaries has now been trained through workshops and has signed up to the Code. This has been carried out through a cascade system whereby trained Managers train and explain the Code to staff after which they are requested to sign an agreement to carry out their work in accordance with the Code. The Managers/trainers answer questions from staff and refer to HR Department as necessary. The importance of the Code is made clear in its relevance to staff, management and other stakeholders.
All new members of staff are required to sign up to the Code before commencing their jobs. They are given training in regards to their responsibilities and rights as part of their induction to the group and its subsidiaries.
An e-Learning software tool has been developed in relation to the Code of Conduct. The Code of Conduct will be updated and re-circulated to all staff annually or more often if required as directed by the Group Board of Directors.
The code also applies to all suppliers, vendors, consultants and others providing services to KBZ. In selecting partners to work with, KBZ performs a registration and pre-qualification process before a contractor is approved. Subsequent to that, contractors or suppliers are required to sign a Letter of Declaration (LoD) acknowledging their commitment to work to our Code of Conduct. We work closely with our suppliers and contractors, monitoring activities and giving guidance to ensure compliance with our Code.
The KBZ Code of Conduct and related Stand-alone policies encompass multiple core strands. We believe that these constitute the structure, along with our monitoring and reporting processes, by which we can ensure organisational transparency and responsible business practice. The Stand-alone policies provide greater detail on specific issues:
  1. Anti-corruption & Bribery Policy  – We have a zero tolerance policy towards corruption, bribery or facilitation payments
  2. Health, Safety & Environment Policy – We are committed to creating a safe, healthy and conducive environment for all our employees
  3. Environment Policy - 'Greener ways of doing business' is core to our company ethos. We are constantly looking for opportunities to reduce our carbon footprint and ensure the environment remains healthy for future generations
  4. Legal Compliance Policy – KBZ acts in compliance with all prevailing laws relevant to our areas of jurisdiction
  5. Whistle-blowing Policy – We support and actively encourage any member of staff to let us know whenever there might be an act or suspected act contrary to our Code of Conduct. The company expects all employees to exercise judgment and perform their duties with
    integrity, accountability and openness. Contact to
  6. Grievance Policy – We take staff and stakeholder concerns seriously. We have systems in place for all our staff and stakeholders to report complaints without fear of reprimand and anonymously if required. Contact to
  7. Employment Policy – KBZ is committed to providing staff with just and fair remuneration enabling us to recruit and retain the highest calibre of staff.
  8. Human Rights Policy – Respect for the Human Rights of our staff and other stakeholders is of paramount importance. We do not tolerate child labour, bonded labour or forced labour and strive to comply with the highest international standards.
  9. Procurement Policy – We have an official policy in place for procurement procedures to ensure we carry out purchases in an ethical and cost effective manner.
  10. Land Acquisition Policy – Our policy regarding any land acquisition transactions is set to ensure that all stakeholder’s concerns are taken into consideration and all parties concerned are satisfied with the outcome.
  11. Social Media Policy – Our social media policy is designed to help protect our staff, our Group and all our stakeholders from reputational risks or risks to personal safety
  12. CSR Policy –  We carry out all our projects with the greatest sincerity to try to utilize our position and strengths to contribute positively in a manner that benefits all stakeholders.
  13. Equality & Diversity Policy –  KBZ Group is dedicated to create environments where equality and diversity are self-evident across all our workplaces. The principle of inclusiveness without discrimination is fundamental to our Group philosophy.
  14. Dividend Policy –  As a Group, KBZ does not have one specific Dividend Policy. The Group and the majority of its subsidiary companies are family owned and do not pay out dividends. Those companies that do have external shareholders each have their own dividend policies. These areagreed in collaboration with the other partners on the basis of the nature of the business.
  15. Risk Management Policy – Key to the sustainable development of each of our companies is risk assessment and management. This process involves the identification, evaluation and prioritisation of risks alongside the maximisation of  opportunities.
  16. Sustainability Policy – KBZ works strenuously to ensure sustainable growth across the Group. Working in multiple sectors, this means each of our companies faceunique challenges and opportunities. 


KBZ Group of Companies is committed to performing as an exemplary corporate citizen. In order to do so, we have a structure in place to implement best practice.

Our core values as an organization determine the way in which we behave. On that basis we have set out a Code of Conduct to which we expect all our staff, suppliers, contractors or other engaged parties to adhere. More detailed group policies derive from the principles outlined in the Code. Finally these guidelines are adapted by each of our subsidiaries to ensure all relevant factors are incorporated.


KBZ Group of Companies is a signatory of the UN Global Compact. We consciously strive to adhere to all of the ten key principles based around human rights, labor, environment and anti-corruption:

Human Rights
Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and
Principle 2: make sure that they are not complicit in human rights abuses.  

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labor;
Principle 5: the effective abolition of child labor; and
Principle 6: the elimination of discrimination in respect of employment and occupation. 

Principle 7: Businesses should support a precautionary approach to environmental challenges;
Principle 8: undertake initiatives to promote greater environmental responsibility; and
Principle 9: the development and diffusion of environmentally friendly technologies.   

Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.  



KBZ Group of Companies has introduced a structure whereby the MD or an appointed alternative has been selected in each of our subsidiaries to champion the implementation, reviewing and reporting on all aspects of our Code of Conduct and other policies. She or He is responsible for allocating tasks as appropriate to responsible individuals or committees. We produce an annual report on our performance on the basis of feedback from our teams.



We have carried out training across our Group initially through Board Members and MDs across the subsidiaries to cascade knowledge throughout our organization. Our first major training session took place at the KBZ Bank AGM on 10th February 2015. This proved to be a great success facilitated by external consultants with the support of the Myanmar Centre for Responsible Business (MCRB). Subsequently all KBZ Bank staff had soon signed up to the Code of Conduct.

On the back of this success, MDs of our other subsidiaries (or representatives thereof) attended a similar training on 12th June 2015. They are responsible for training their teams and ensuring full compliance of staff within their spheres of authority.

We take this process seriously and want to ensure all members of staff truly understand the Code and other policies before putting pen to paper. We want all our staff to fully understand what we expect from them, what theirrights are and the direction in which we are heading.



At least one individual in each of our subsidiaries and/or their sub-sets is responsible for identifying and engaging with our stakeholders. These will vary according to the nature of the operation, but will include, but not be limited to:


  • Staff
  • Customers
  • Local Communities
  • The Myanmar Government
  • International Institutions (UN, Foreign Governments, etc.)
  • The Environment
  • Suppliers & Contractors
  • Shareholders
  • Regulators/ Law Makers
  • Partners
  • NGOs
  • Peer Companies

KBZ Group prefers not to prioritisebetween stakeholders. Each is important to our mutual wellbeing. Most of our companies work in differing sectors with varying stakeholder interests. We prefer to consider all as equal in importance and deserving of our attention and collaborative efforts to work together.


Annual reports are published on our Group website putting information about all issues covered in our Code and Policies into the public domain. We welcome feedback from all stakeholders. Our annual report regarding Transparency, Anti-Corruption and Bribery and Human Rights is attached below. 


At KBZ we constantly try to improve our performance. We are implementing ever-better auditing and monitoring processes to help us to meet or exceed the highest international standards. We engage both internal and external auditors to assess our performance in an ongoing process to monitor our activities and analyse where we can improve in all our areas of our operations.

For a full copy of our Code of Conduct, please download the attached:
Code of Conduct Myanmar Version
Code of Conduct English Version





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