Business Ethics


TMH embraces the following principles:

We have a zero-tolerance approach regarding to:

  • Corruption
  • Discrimination
  • Child and forced labor


TMH is currently reviewing and updating its Code of Conduct. Led by our Board, this project involved an independent third-party. With their support, we conducted a gap analysis with Notification 14/2018 issued by the Anti-Corruption Commission to ensure the compliance of our approach. 

An action plan was developed: 

  • A Code of Conduct was developed covering various areas to ensure the integrity of our operations. 
  • New processes, procedures and tools were developed to ensure compliance.

A training programme will be then rolled out, with a focus on specific departments (compliance, HR and internal audit) first to structure and encourage a speak-up culture.


When a case is reported, our HR department will start the investigation. If the case is serious, it will be handled by the Internal Audit team to ensure confidentiality of the inspection and to protect as well the whistle-blower. Internal auditors will then inform the BOD of their findings, and recommend a various range of actions to manage the issue swiftly.


Two potential frauds were reported. However, after a thorough investigation by our internal audit team, it appears that these cases were both merely cases of late payment by our business partners. More information is available in our latest Annual Report.