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ၾိင်ႈတိုဝ်းၵမ် လွင်ႈၶပ်းသၢင်ႈၵၢၼ်ငၢၼ်း

ၾိင်ႈတိုဝ်းၵမ် လွင်ႈၶပ်းသၢင်ႈၵၢၼ်ငၢၼ်း

Respect diversity, culture and basic human rights

Every human being has an intrinsic right to be treated with respect, care and dignity. Great Hor Kham’s core belief is that business practices and business relationships are not sustainable unless we base relationships on basic human rights with and between employees and appreciate diversity, cultural and other differences.

Our Value

Great Hor Kham respects individual rights.

Our code of conduct

All employees respect the personal dignity, privacy and rights of each individual we interact with during the course of work and shall not in any way cause or contribute to the violation or circumvention of human rights.

If you become aware of any situation in breach with Great Hor Kham’s value and standards, you shall notify your leader.

Our Value

Great Hor Kham values professional workplace that nurtures inclusive and collaborative working environment, and shall respect all applicable labor law of Myanmar and other applicable laws. Great Hor Kham is opposed to any discriminatory practices and shall do its utmost to promote equality and fairness in all employment practices.

Our code of conduct

Our working environment standards shall be exemplified by all leaders and employees and extended to every member of our diverse community.

Our employee shall act with highest integrity and treat our colleagues and others with respect at all times.

No direct or indirect discrimination shall take place based on race, color, gender, sexual orientation, age, disability, language, religion, employee representation, political or other opinions, national or social origin, property, birth or other status.

We do not tolerate degrading treatments towards any employee, such as mental or sexual harassment or discriminatory gestures, language or physical contact that is sexual, coercive, threatening, abusive or exploitative.

Health, safety and employee security

Great Hor Kham is committed to safe and healthy working environment for our employees.

Our Value

Great Hor Kham shall strive to be an industry leader in the field of health, safety and employee security and comply with relevant local and internationally recognized standards.

A healthy and sustainable work-life balance shall be ensured for all employees.

Hazards shall be identified, risk assessed, mitigated and monitored to prevent accidents and occupational diseases.

Necessary employee security protection shall always be given the outmost attention. Employee security measures shall be based on risk analysis and mitigating actions.

Our Code of Conduct

We shall do our utmost to identify occupational risks, establish controls and monitor performance. Our performance will be reported in a transparent and accurate manner.

It is the responsibility of all of us to adhere to the prescribed safety rules and to act by example as well as to raise and react to any concerns which may represent a potential threat to health and safety.


As responsible Myanmar Citizen company, we care about our environment and how our action and operation could impact the environment.

Our Value

Great Hor Kham is committed to minimize the impact on the environment of its operations.

Great Hor Kham shall adhere to relevant local and internationally recognized standards, minimize its environmental impact and continuously improve its environmental performance by implementing sustainable sourcing.

We shall prioritize and support development and deployment of environmentally friendly designs and technologies whenever possible.

Our Code of Conduct

You shall contribute to minimizing the use of finite resources, including energy, water and raw materials.

You shall contribute to minimizing harmful emissions to environment, including waste, carbon emissions and other air emissions and waste discharges to water.


Our vision is to provide quality services, improving life quality in society and of our customers.

Our mission is to benefit from satisfying our customers through international standard quality services

Our Value

Great Hor Kham shall create growth by delivering highest quality services in a most cost effective way.

Our Code of Conduct

You shall delight customers with quality service delivered in professional manner. You shall deliver insight, respect and understanding. The key to achieving our vision and mission is a mindset where everyone works together with common values: Be reliable, Be accountable, Be Inspiring and Be Respectful.

You shall always try to fulfil the needs of the customer in the best possible manner, whilst complying with laws, regulations and the Great Hor Kham way.


We rely on our suppliers to deliver us tools, technologies, services and resources so that we can successfully provide quality products and services to our customers.

Our Value

Suppliers shall be treated fairly and equitably.
Great Hor Kham's selection processes shall garner supplies’ trust.
All Great Hor Kham’s Suppliers shall adhere to Great Hor Kham’s principles for supplier conduct.

Our Code of Conduct

You shall follow all established guidelines and procedures when choosing suppliers.

You shall help our suppliers understand Great Hor Kham’s principles for supplier conduct.


Fair and level competition sharpen our edge and is essential for efficient value creations for Great Hor Kham.

Our Value

Great Hor Kham supports fair and open competition in the markets.

Great Hor Kham's competitive edge in the market shall be based on good products and services at the right price.

Our Code of Conduct

You shall conduct all business dealings with Great Hor Kham’s competitors in an honest and professional manner.

You shall not participate or be part of any breach of competition regulations.

Corruption and bribery

Corruption corrodes public trust. It is illegal and can result in fines and jail sentences for those involved. Corruption includes bribery, facilitation payments, benefits and otherwise offering an improper advantage to influence a third-party.

Our Value

Great Hor Kham has zero tolerance for corruption and is firmly opposed to all forms of corruption.

Our Code of Conduct

You shall never offer, give, ask for, accept or receive any form of bribe. A bribe occurs when someone attempts to influence a third party’s decision by offering an improper advantage either directly or through intermediary.

Information, communication and media

Disclosing relevant and material information accurately and timely and reliably to all stakeholders is truly essential to instill trust in the company.

Our Value

Information from Great Hor Kham shall be reliable and correct, and meet high professional and ethical standards. Communication with the media, the public and the financial markets shall take place in accordance with established procedures in compliance with the regulations and practices applicable to public companies.

Our Code of Conduct

Public information about Great Hor Kham shall only be communicated by the authorized person responsible for public communications approved by Great Hor Kham management.

Employees who participate in public debates are obliged to make sure that they clearly distinguish between their role as a private citizen and of that as an employee of Great Hor Kham.


Our value

Shareholders are the most crucial and fundamental people among our relationships. The ultimate goal of our existence is Value / wealth creation for our shareholders. We shall always focus on long term shareholders’ value that is compatible with sustainable, environmentally sound social development, ethical and responsible manner.

Our Code of Conduct

We shall never compromise continuity through an interest in short-term enrichment. We all are responsible for protecting and building shareholders value while our directors are mainly responsible to strategically plan and guide to ensure the long-term shareholders value.

We shall build shareholders value with focus on efficiency, sustainability, social responsibility, integrity, ethics and professionalism based on our knowledge, experience, and competency.

We shall also protect our shareholders value by protecting our information, our intellectual property and physically assets appropriately, upholding financial integrity and reporting and compliance.

We are committed to provide full, fair, complete, accurate, timely and understandable disclosure of information, including financial information and thus giving the voting rights on an informed and responsible basic.

Only certain officers and Directors designated from time to time should be authorized to communicate with investors and securities market professionals (including brokers, analysts and other market professionals) on any subject relating to GHK. No other employees or Directors are authorized to engage in any such communications. Requests for information should be referred to the Investor Relations Department or CEO office.


Our value

To maintain our reputation and our business sustainable, it is crucial to comply with laws of all jurisdictions we are doing business and effectively work with government investigations. We shall always strive for compliance at all cost.

Our Code of Conduct

We shall always conduct our business in accordance with the existing laws, rules and regulations. We must know or take advise as necessary to know the regulations surrounding us and set up effective system to fully comply with those.

We shall actively cooperate with Government agencies having jurisdiction over our business such as investigators, regulators, and auditors as they do reviews or inspections.

We shall fulfill all our tax duties as responsible citizens.

The members of BOD and head of departments shall be in good character and have no history of punishment by court and have not been facing any lawsuits. They shall not be included in the black list of any public and government organizations.

We shall neither hire a lobbyist or similar person nor act directly by using GHK’s assets to influence government executive or legislative decision making to be awarded or to modify any contract.

GHK respect each individual’s right on their freedom of choice on political matters – involving in political activity and contributing their own time and resources. However, such activities must not take place on GHK’s working hour or at GHK’s property nor involve GHK’s name. GHK will not reimburse for any political contributions or activity you made. GHK will not also contribute money or other resources to candidates, officeholders or political parties.

We should also be especially careful when dealing with government client since they are significant penalties for organizations that fail to follow the law while working for government clients.

Our Assets

All physical and intangible assets are to be safeguarded and utilized with proper control and due care to promote value creation for the company.

Our value

Great Hor Kham shall have internal controls that ensure that the Great Hor Kham’s goals, strategies and business processes are effectively executed.

All commitments shall be made in accordance with the applicable regulations concerning authority.

Our Code of Conduct

You shall follow established procedures and guidelines. If applicable procedures and guidelines do not exist, you shall act in the best interest of Great Hor Kham. If you are in doubt how to act you shall consult your leader.

You may only enter into a commitment if you hold authority to do so. The limits of your authority must not be exceeded. Internal controls are the responsibility of management, but the individual employees shall contribute to ensuring that effective and reliable business processes are in place.

Conflict of interest

Conflict of interest is when we have a personal or outside interest that conflicts with the best interest of our company. A personal interest could be a financial interest in another company or in a transaction, a personal relationship, including but not limited to immediate family, or any interest or relationship that could improperly affect our judgement and decision making.

Even if we believe that our judgement will not in any way be affected by an outside interest, if others might reasonably think the interest is substantial, the appearance of a conflict may exist.

Our value

Service to Great Hor Kham shall never be subordinated to personal gain nor advantage. Any decision on behalf of Great Hor Kham shall be based on objective and fair assessment of Great Hor Kham’s interest without being impacted by any other considerations.

Existence of actual or perceived conflict of interest shall be disclosed to the leader or other supervisory bodies as appropriate.

Disclosed conflicts shall be processed in accordance with Great Hor Kham’s governing documents.

Our Code of Conduct

You shall never take an active role or try to influence a decision if you have an actual or possible conflict of interest, or other circumstances exist which could give grounds to question your judgement unless prior written approval has been granted by your leader. Such approval can only be given if it is deemed to be in the best interest of the company. If a conflict of interest arises, you shall at your own initiative, evaluate circumstances that may imply a conflict of interest or your impartiality and promptly notify your leader of such circumstances.

Private interests and activities

Engagements in external positions and appointments may impact the working relationship with Great Hor Kham or be in conflict with Great Hor Kham's business interests.

Our value

Managers and employees shall not hold external duties or positions with a scope and work load which may affect their work ability and capacity unless such duties or positions are approved by their leader.

Our Code of Conduct

Prior to accepting any external duties or positions you shall consider the impact on your ability and work capacity. If you believe the impact will be negative for Great Hor Kham you shall abstain from accepting such appointments.

External duties and positions which may affect your work ability and capacity need advance approval from your leader in writing.


Information may have value for Great Hor Kham or may need to be kept confidential because it involves employees or third parties. Unauthorized access to such information may impair the value and have a negative impact on Great Hor Kham’s reputation.

Our value

In Great Hor Kham, we safeguard information that is of a sensitive nature or which is classified as confidential due to other reasons. Information from external parties shall be treated with minimum the same level of confidentiality as our own information.

The duty of confidentiality also applies after the conclusion of employment or contractual relationship with Great Hor Kham for as long as the information is confidential.

Our Code of Conduct

It is your duty to ensure that information you create or receive is correctly classified and only disclosed in accordance with Great Hor Kham’s rules and guidelines.

Caution shall be exercised when discussing internal affairs to avoid being overheard by unauthorized persons.

If confidential information is to be shared with external parties, it is your duty to ensure that a written confidentiality agreement is in place.

Personal Data and Privacy

Customers, employees and other related parties need to feel confident that personal data is processed in such a way that data is only used for legitimate business purposes.

Our value

Great Hor Kham’s processing of personal data shall be subject to the care and awareness which is required according to laws and regulations. Processing of personal data shall be limited to what is needed for operational purposes, efficient customer care, relevant commercial activities and proper administration of human resources.

Our Code of Conduct

You shall only collect, process, and store personal data for legitimate business purposes and keep such data no longer than necessary for the purposes for which any data was collected.

You shall in particular process customer's personal information in accordance with the relevant laws and regulations on protection of personal data.

Intellectual Property

Intellectual property such as trademarks, copyrighted works, inventions, trade secrets and know-how, are often valuable and may be important to Great Hor Kham's success in the market.

Our value

Great Hor Kham’s intellectual property shall be safeguarded from unauthorized access, sharing and illegitimate use.

Great Hor Kham shall respect the intellectual property of others.

Our Code of Conduct

You shall protect and process intellectual property in the best interest of Great Hor Kham. Specifically, you shall not make unprotected intellectual property available to external parties without prior authorization from your leader and a signed confidentiality agreement from such parties.

You shall not infringe the intellectual property of others. In particular, you shall comply with all confidentiality obligations regarding trade secrets disclosed by third parties.

Properties and Assets

Great Hor Kham’s assets represent significant values and are of importance to its success in the markets Great Hor Kham operates.

Our value

Great Hor Kham's property and assets, e.g. buildings and equipment, shall be managed and safeguarded in a manner which protects their values.

Great Hor Kham’s property and assets shall be used only for business purposes unless agreed in employment terms or in compliance with Great Hor Kham's procedures and guidelines.

Our Code of Conduct

You shall use Great Hor Kham’s properties and assets with due care and in such a manner that the values are safeguarded.

You shall observe Great Hor Kham’s requirements, direction and guidance on safeguarding from external threats, including terrorism, cybercrime and fraud.

Accounting and Financial Reporting

As a publicly listed company, Great Hor Kham is subject to strict requirements concerning financial reporting with respect to compliance with IFRS and good accounting practices. Reliable, transparent, consistent and timely reporting of financial performance enhances investors’ and other stakeholders’ confidence in Great Hor Kham and provide equal opportunity to act on such information.

Our value

Great Hor Kham's accounting processes shall ensure that all transactions are correctly registered in accordance with local law and good accounting practices.

The annual financial statements and interim financial statements shall be in accordance with the law, IFRS and good accounting practices.

Our Code of Conduct

You shall follow the Great Hor Kham’s accounting procedures concerning the registration of transactions and proper documentation to ensure that business transactions are recorded and documented in accordance with applicable accounting procedures.

If you participate in Great Hor Kham’s reporting processes, you shall understand applicable valuation and presentation requirements and comply with Great Hor Kham’s disclosure controls and/or requirements as per IFRS and other relevant standards.

Handling Breaches: Reporting

Great Hor Kham is determined to nurture a culture where employees feel confident to share ethical dilemmas and speak up about possible breaches. It is important to Great Hor Kham that you speak up!

An important part of the Code of Conduct is to manage breaches of this Code, including relevant laws, regulations and Governing Documents. Such breaches are defined as Compliance Incidents. All Compliance Incidents shall be handled by the relevant Ethics and Compliance Officer in accordance with the requirements defined in the Governing Documents.

You shall report any act that is likely to constitute a breach of the Code of Conduct to the Ethics and Compliance Hotline.

Consult your local Ethics and Compliance Officer/Advisor, the Ethics and Compliance Hotline or your leader if you need advice concerning the reporting of breaches.

The Ethics & Compliance Hotline is a confidential web and phone-based intake system provided by Great Hor Kham to employees of all companies in the Great Hor Kham and other stakeholders. The intake system is operated by Navex Global, an unaffiliated service provider located within the EU. All reports are handled by the appropriate Great Hor Kham Ethics & Compliance function.

All reports will be handled confidentially. You may choose to remain anonymous, and no information from your computer (like IP address) or your telephone number is recorded.

Great Hor Kham does not allow reprisals of any kind against those who, in good faith, report a possible breach of the Code of Conduct.

The Ethics & Compliance Hotline, including overview of the available local toll-free numbers, is available here.

Contact information to the local Ethics and Compliance Officers/Advisors can be found on the intranet portal.

Contact information to the Group Ethics and Compliance Officer:
Great Hor Kham ASA
Group Ethics and Compliance Officer


Those who breach the Code of Conduct must be prepared to face the consequences that reflect the type and scope of the breach. Serious breaches may lead to termination of the employment.

Misconduct that may result in disciplinary action includes (but is not limited to):

  • Breach or request others to breach this Code
  • Failure to promptly raise a known or suspected breach
  • Failure to cooperate in Great Hor Kham investigations of possible breaches
  • Retaliation against any employee for reporting integrity concerns in good faith

The Board of Directors shall take all action it considers appropriate to investigate any breaches. If a breach has occurred, Great Hor Kham will take such disciplinary or preventive actions, as it deems appropriate.