2016_3rd Edition_CA_Employment Handbook for Executives 2016

SWM ENVIRONMENT HOLDINGS SDN. BHD.

FORWARD It is our pleasure to welcome you to the LGB family. This is the third edition of our Employment Handbook for Executives. The Management has taken cognizance of the continually changing labour market conditions and has made several enhancements on the employment benefits. We strive to provide a dynamic work environment in which both customer interests and employee interests are fulfilled. The policies, procedures and benefits available to eligible employees reflect a concern not only for the well-being but also for the personal growth and professional development of all members in LGB Group. It is important that you are familiar with and adhere to the Company’s policies and benefits program. As and when new items / benefits are developed, they will be included into this handbook. In the event a new legislation which is introduced by the authorities is superior to the terms contained herein, then such legislation shall apply and you will be notified accordingly. In a continually challenging environment, it is sometimes necessary to make changes to suit the situation. In this respect, the Management reserves the right to amend, revise in part or in whole, or withdraw any of the items in this Handbook. We hope your experience here will be challenging, enjoyable and rewarding. Should you have any enquiries pertaining to any terms and conditions, please contact the Human Resource Department and our staff will be pleased to assist. Regards The Management January 2016

TERMS AND CONDITIONS OF EMPLOYMENT

Definition The following definition shall apply in this Handbook: ITEM DEFINITION Employee A person as defined under the Employment Act 1955 and HRD under the employment of the Company including permanent, contract and temporary employment. Where an Employee is employed under a fixed term contract, the terms and conditions of his contract shall apply where they differ from the policies in this Handbook. “Employee” includes all staff employed by the Company whether male or female. Human Resource Department of the Company in which the relevant Employee is employed. Immediate Family Spouse, children, parents, brothers and sisters of the relevant Employee. Extended Family Parents-in-law, grandparents, grandchildren. Spouse Company An Employee’s first legal wife or husband. In the case of a Group Muslim Employee who has more than 1 spouse, he has to Basic Salary declare to the Company the name of his first legal spouse for this purpose. Rest Day Company within the LGB Group. LGB Group and all its subsidiaries in Malaysia. The basic monthly salary payable to an Employee. It does not include any allowance, incentive or other monetary entitlement. Refers to a whole day as may be arranged by the Company for the Employee to take his weekly rest. Where the Employee is allowed more than one rest day in a week, the last of such rest days shall be deemed the rest day. Hours of work The time during which an Employee is at the disposal of the Company and is not free to utilise the time for his own purpose or movement.

ITEM DEFINITION Leave Application The leave application procedure as maybe established by the Procedure Group from time to time to regulate the procedure for Employees to apply for a leave of absence from the Company. Local Any geographical location which is within 100 km radius (shortest possible distance by road) from the Employee’s normal place of work. Outstation Any geographical location which is beyond 100 km radius (shortest possible distance by road) from the Employee’s normal place of work. Overseas Any other country outside Malaysia. Any form of travel from the normal place of work to another location to conduct business on behalf of the Company or under the instruction of the Company. Business Travel Exclusion: Travel for the purpose of attending the Company’s social functions or Company excursion trips (whether domestic or overseas) is not considered as business travel. The time spent on travelling to and from the normal place of work or from and to the Employee’s residence shall not be considered as official travelling. However, for the purpose of outstation travel, the time spent on the journey shall be treated as part of working hours. The time spent in attending training, conferences or seminars etc. do not qualify for over-time claims / replacement leave etc. Full Tax Invoice A full tax invoice is similar to a commercial invoice or receipt named as “Tax Invoice” which containing the Company name and Company full address, SST rate and amount.

1. PURPOSE AND APPLICATION a) This handbook provides information and guidelines on Company policies, terms and conditions of employment and the general rules applicable to all executive Employees in the Company. b) The contents in this Handbook are not intended to be exhaustive. The Company reserves the right to introduce, modify or annul any terms, conditions and rules from time to time and all such amendments shall be binding on all Employees. c) Any statutory matters not covered by this Handbook shall be referred to the relevant prevailing statues. d) A copy of this Handbook shall be made available to all executive Employees for reference. 2. EMPLOYMENT a) All Employees shall be employed under a letter of employment issued by an authorized representative of the Company. b) An Employee shall furnish up-to-date personal details such as age, family details, educational qualifications, previous employment etc. in the Application for Employment form. If it is later discovered that any statement or documentary evidence provided by the Employee is false or misleading, the Employee concerned shall be liable for instant dismissal or other disciplinary actions as the Company deem appropriate. c) The Company shall not be responsible to bear the travelling expenses of candidates who are invited to attend interviews at the Company’s premise. 3. RECRUITMENT a) A newly recruited Employee may, at the discretion of the Company, be required to undergo a pre-employment medical examination at the Company’s panel of doctors, at the sole cost of the Company, and the validity of the offer of employment is subject to the Employee being certified “medically fit” by the medical practitioner or medical officer who conducts such examination. b) The Basic Salary and grading offered to an Employee upon his employment with a Company shall depend on the seniority of the position, the Employee’s relevant working experience, qualifications and his existing salary (if any). 1

4. PROBATIONARY PERIOD a) All newly hired Employees shall undergo a probationary period of six (6) months which may, if necessary, be extended for a further period at the discretion of the Company. b) The probationary period may also be reduced / shortened at the discretion of the Company. 5. CONFIRMATION a) It is the responsibility of each Head of Department (HOD) to guide, counsel and train new Employee in his department. b) For a new Employee, a performance appraisal shall be conducted to determine the suitability of the Employee to be offered permanent employment. If the Employee does not perform up to expectation during the probationary period, his immediate superior / HOD shall conduct a counselling session and review on the shortcomings together with the Employee. The immediate superior / HOD shall provide all possible assistance and guidance to the Employee to ensure that the Employee has the opportunity to improve himself. c) On the successful completion of the probationary period, the Employee will be given a letter to confirm his appointment. An Employee who is found unsuitable for further employment or whose probationary period is extended shall also be informed in writing by the Company. d) Upon confirmation by the Company, an Employee’s service with the Company shall be deemed to have commenced from the date he commenced service with the Company. e) For all intent and purposes, an Employee is deemed to remain on probation if he did not receive any letter of confirmation from the Company. 2

6. RESIGNATION / TERMINATION a) During the probationary period or any extension thereof, either party may terminate the employment, as follows: Grade 10 to 25 by serving one (1) month notice in writing or by payment of one (1) month salary in lieu of notice. Upon confirmation of employment, either party may terminate the employment as follows: Grade 14A to 25 by serving three (3) months notice in writing or Grade 10 to 13 by payment of three (3) months salary in lieu of notice. by serving two (2) months notice in writing or by payment of two (2) months salary in lieu of notice. Employees employed under fixed term contract shall comply with the notice period as stated in their fixed term employment contracts. The notice period for certain critical positions in Grade 10 to 13 may be increased at the discretion of the Company. As a guide, critical positions shall include but not limited to positions that have direct access and responsibility for i) cash, cash equivalent and financial resources. ii) sensitive data, records, information and technical know-how. b) In the event of an Employee giving notice to terminate his employment, the Company may, upon the application by the Employee and at its absolute discretion, waive the notice period totally or partially. The Employee shall not in such instances have any claims of indemnity in lieu of notice as stated in clause (a) above. c) Upon resignation, the Employee is allowed to utilise any balance of earned annual leave during the period of notice. Annual Leave is subject to approval as per the Leave Application Procedure. d) The Employee shall surrender immediately all the Company’s property such as articles, records, files, keys, computer discs and storage discs, company vehicle if any, that are currently in his possession, upon the termination of service. e) The Employee shall reimburse the Company the value of the replacement cost for any company item(s) that is lost or damaged while under his custody. f) The Employee shall settle all outstanding liabilities and obligations with the Company before any monies / payment due to him is to be released. 3

7. WORKING HOURS a) The normal working hours for the corporate office is as follows: Monday to Friday 8.45 a.m. to 5.45 p.m. Lunch break 12.45 p.m. to 1.45 p.m. Lunch break on Friday 12.45 p.m. to 2.30 p.m. Saturday shall be declared as Company off-day. b) The Company reserves the right to revise or to reschedule the working hours from time to time to suit its operational requirements and all Employees shall conform to such revised working hours upon notification by the Company. c) The working hours for Employees engaged in operations / production shall continue to operate on a six days / week. The work schedule / working hours shall be drawn up in accordance with the operational requirements. 8. REST DAY All Employees shall be granted one (1) rest day per week. If a gazetted public holiday falls on the rest day, the next working day shall be treated as holiday in substitution thereof. 9. SHIFT WORK Depending on the operational requirements of the Company, certain Employees may be required to perform shift work as and when deemed necessary. For this purpose, a duty roster shall be drawn up on a monthly or weekly basis, and the Employees concerned shall adhere to such duty roster. 10. RETIREMENT AGE a) The retirement age for all Employees is sixty (60) years. In the absence of a birth certificate, the date of birth as shown in the identity card or passport of an Employee shall be deemed to be the date of birth for the purpose of determining the retirement age. b) Notwithstanding the above clause, before reaching the retirement age, an Employee may opt for optional retirement after attaining the age of fifty-five (55) years. c) An Employee may retire before attaining the age of sixty (60) years on account of incapacity to work due to prolonged illness such as tuberculosis, cancer, polio, leukemia, leprosy, paralysis etc., or as a result of an accident which renders him incapable of rendering his service. 4

d) At the request of the Company, an Employee may continue to remain in employment beyond the normal retirement age. Employment under this category shall be on a year-to-year contract basis, and the terms and conditions of such employment shall be decided at the discretion of the Company. 11. HIRING OF FAMILY MEMBERS a) Hiring of an Immediate Family to work in the same department is not encouraged as conflict-of-interest may arise and it is important to avoid such inappropriate job relationship. b) In the event of a marriage between two Employees within the same department, one of them may be transferred to another department or to another company within the Group. 12. PROMOTION AND ACTING a) Promotion (i) The Company shall give preference to the internal promotion of suitably qualified and capable Employees from lower categories to higher categories in the event of a vacant position. However, the Company reserves the right to fill such vacancies from external sources as and when it is deemed necessary. (ii) An Employee selected for promotion to a higher category or to a different category may be required to undergo a probationary period of 3 months from the date of promotion. Such requirement shall be in writing. The Employee shall be given an appropriate salary adjustment on his promotion, and he shall enjoy the terms and benefits in accordance with the new grade / level. (iii) In the event the Employee does not complete his probationary period to the satisfaction of the Company, he shall revert to his previous position at the corresponding former salary, or he may be given another position compatible to his capability and experience. 5

b) Acting (i) In certain circumstances, the Company may appoint an Employee to a higher grade in an acting capacity. (ii) Where the Employee is required to serve fourteen (14) consecutive days or more in the acting capacity, he shall receive an Acting Allowance which shall be determined by the Company. (iii) During the period in which the Employee serves in an acting capacity, he shall continue to receive his salary / benefits in accordance with his existing grade. (iv) Upon the completion of the acting appointment, the Employee shall revert to his previous grade or is given another job compatible to his capability, and the Acting Allowance shall be withdrawn accordingly. 13. TRANSFER AND SECONDMENT a) Transfer (i) At the discretion of the Company, an Employee is subject to be transferred from one job to another or from one section / department / division / location to another or transfer from one company to another within the Group. Reasonable notice shall be given to the Employee concerned but, in some instances, a short notice may be necessary due to urgency of service. (ii) An Employee being transferred to another section / department / division / company shall retain his existing salary and grade, while his length of service and accrued annual leave shall be brought forward with his new posting. (iii) The Company to which the Employee is being transferred to shall bear the related costs of the transfer e.g. travelling expenses, disbursements etc. (iv) An Employee may also apply for a transfer within the Company or from one company to another with the Group for personal reason. However, such application is subject to approval by the Company after taking into consideration the needs and existing manpower requirements within the Company / Group. In the event such application is approved by the Company, the terms and conditions pertaining to such transfer may be revised / modified at the discretion of the Company on a case to case basis. 6

b) Secondment (i) An Employee may be seconded to another company / location at the discretion of the Company. All notices of secondment shall be made in writing. (ii) The period of secondment shall not exceed 6 months under normal circumstances. If an extension is necessary, such notification to the Employee concerned shall be in writing. (iii) An Employee on secondment shall continue to draw his salary and other benefits from his former Company. However, out-of-pocket expenses related to accommodation, entertainment, travelling etc. incurred during the period of secondment shall be reimbursed by the Company to which the Employee is assigned to. (iv) However, should an allowance be granted due to this secondment, the Company to which the Employee is seconded to shall be responsible for payment of such allowance, and this allowance shall be withdrawn upon the completion of the secondment. (v) At the end of the secondment period, the Employee shall resume his previous position in the former Company. However, the Company reserves the discretion to assign another position of similar ranking / grading to the Employee if at that point of time, the previous position is no longer available or if it has been filled by another Employee. 14. PUBLIC HOLIDAYS a) The Company shall recognise all public holidays gazetted by the Federal Government or the Government of the State in which the Employee is serving. b) In the event the Federal Government declares an ad hoc public holiday in accordance with the Public Holiday Act, the Company shall recognize and observe such ad hoc public holiday. However, to avoid disruption to operations, all Employees engaged in operations or production shall report for work on that day as usual, and the Company shall grant a substitute day in lieu thereof. The corporate office shall remain closed on such ad hoc holiday. c) Where a public holiday falls within a period during which the Employee is on sick leave or annual leave or on temporary disablement under the SOCSO Act, he shall be eligible for another paid holiday in substitution for such public holiday. d) Any Employee who absents himself from work on the working day immediately preceding or immediately succeeding a public holiday without the prior approval of the Company shall not be entitled to that public holiday unless he has a reasonable excuse for such absence. Please refer to Appendix 4 for the List on Public Holidays. 7

15. PAYMENT OF SALARIES a) Information pertaining to an Employee’s remuneration is strictly confidential and it should not be discussed among Employees. b) Salaries will be paid into the respective Employee’s bank account. In any case, the payment shall not be later than the 7th day of the wage period. All Employees shall indicate their consent to receive their salaries through their bank accounts by completing the “Salary Deposit Authorisation” form. c) Both the Employee and Company shall contribute to the Employees’ Provident Fund and SOCSO in accordance with the prevailing statutory rates. d) Where an Employee is hired during the month, the proportionate salary due to him for that month shall be calculated as follows: Gross Monthly Salary X Number of days worked Total Number of days in the month 16. OVERTIME a) Employees as defined under the Employment Act 1955 shall be eligible for overtime claims for work carried out after the normal hours of work in accordance with the provisions in the Employment Act 1955, as follows: (i) Weekdays Exceeding normal hours - 1.5 X basic hourly rate For those eligible Employees working on 5 days week, work on Saturday shall be treated as normal overtime work. i.e. 1.5 X the basic hourly rate. (ii) Rest Day - 1.0 X basic hourly rate Normal hours of work - 2.0 X basic hourly rate Exceeding normal hours (iii) Public Holiday - 2.0 X basic hourly rate Normal hours of work - 3.0 X basic hourly rate Exceeding normal hours (iv) The total overtime for an Employee shall not exceed 104 hours per month. The ordinary rate of pay and hourly rate are computed as follows: Monthly salary = ordinary rate of pay (rate per day) 26 days Monthly salary = rate per hour 26 days x 8 hours 8

17. SALARY REVIEW a) Salary review is conducted on January of each year, and the quantum of increment, if any, shall be decided at the full discretion of the Company. b) The quantum of salary increase will, among other things, depend on the Employee’s performance as evaluated in a performance appraisal over the past 12 months. 18. BONUS a) Bonus payment shall be decided at the full discretion of the Company. b) Confirmed Employees who have not completed 12 full months of service and are still in active service as at 31 December, shall be eligible for bonus on a pro-rated basis. c) An Employee is not entitled to any bonus payment: (i) in the event of dismissal or resignation to avoid disciplinary actions. (ii) when he has tendered his notice of resignation and / or is serving his notice at the time bonus is declared and paid out. (iii) if he is under suspension due to disciplinary reason or pending a domestic inquiry. 19. LEAVE OF ABSENCE 19.1 Leave Application Procedure a) All Employees are required to submit their leave application via E- Leave system prior to the intended leave period. Approval must be obtained from the superior / Head of Department before proceeding for leave. b) Employees are required to produce documentary proof to substantiate their application. The supporting document must be scanned and uploaded in the E-Leave system. This is applicable for all types of leave except annual leave. 9

19.2 Annual Leave a) The Company grants annual leave to all Employees to enable them to have a break from their working environment. b) Annual leave entitlement is calculated on a calendar year basis. For the first year of service or during the year where employment is terminated, annual leave shall be pro-rated to the number of completed days of service, rounded to the nearest one day. Example, any fraction of a day that is 0.49 or less, shall be treated as 0. Any fraction of a day that is 0.5 or more shall be treated as 1.0. c) Application for annual leave should be submitted in accordance with the Leave Application Procedure. An Employee shall not absent himself from duty for the purpose of annual leave unless he has obtained prior approval for his application. d) Employees may be allowed to carry forward up to 10 days of their current year’s leave entitlement to the following year up to 30 April only. Any earned annual leave not utilised by the 30 April deadline shall be forfeited accordingly except where the Employee has obtained the Company’s written permission to extend the deadline. e) If an Employee’s service is terminated due to misconduct or other disciplinary actions, then he shall not be entitled to any annual leave accrued up to the date of his termination. However, he shall be paid his earned salary up to the date of termination. f) The Company reserves the right to schedule certain days in each year for shutdown in conjunction with festivals and public holidays and Employees shall utilise their annual leave for this purpose. g) An Employee may apply for half-day leave, either for the morning or afternoon session. For those who are on 6 days week, annual leave taken on a working Saturday shall be treated as one day leave. h) An Employee under probation is discouraged from taking annual leave except for exceptional circumstances such as: (i) Attending to a sick family member (ii) Emergency cases (iii) Attending court cases / visiting Government offices, etc. i) Application for annual leave shall be made at least four (4) working days in advance in accordance with prevailing Leave Application Procedure. 10

19.3 Annual Leave Entitlement Grade Years of service Entitlement per year 10 to 13 (working days) 14A to 17 1 to less than 5 years 18 to 25 5 to less than 10 years 16 days 18 days 10 years and above 20 days 1 to less than 5 years 18 days 5 to less than 10 years 20 days 22 days 10 years and above 20 days 1 to less than 5 years 22 days 5 to less than 10 years 24 days 10 years and above 19.4 Sick Leave a) Sick leave is defined as the period which an Employee is unable to be present for work on account of sickness which shall be certified by a registered medical practitioner or Government medical officer. Medical certificates issued by registered dental surgeons shall be recognised as normal sick leave for this purpose. b) An Employee is eligible for paid sick leave which is certified by a registered medical practitioner or Government medical officer, as follows: Where hospitalisation is not necessary: Years of service Entitlement per calendar year Less than 2 years 14 days 2 to less than 5 years 18 days 5 years and above 22 days Where hospitalisation is necessary: up to an aggregate of sixty (60) days per calendar year (inclusive of normal sick leave and hospitalisation leave). When hospitalisation leave is granted for a continuous period exceeding one (1) week, such leave shall include off-days & rest days but exclude public holidays. 11

c) An Employee who has been granted medical certificate (sick leave) must notify his immediate superior or the HRD by telephone within 4 hours from the commencement of the sick leave. d) Any sick leave taken in excess of the annual entitlement shall be offset against prevailing annual leave entitlement or treated as unpaid leave, as the case may be. 19.5 Maternity Leave a) A female Employee is entitled to paid maternity leave as per the Employment Act 1955, of 60 consecutive days (including rest days, sick leave and public holidays) in respect of each confinement, if (i) she has been employed at any time during the four (4) months immediately preceding her confinement; (ii) she has been employed for an aggregate of not less than ninety (90) days in the nine (9) months immediately preceding her confinement. However, a female Employee shall not be entitled to paid maternity leave if at the time of her confinement; she has five or more surviving children. b) Leave taken on account of miscarriage, still-born or abortion during the first twenty-eight (28) weeks of pregnancy shall not be treated as maternity leave but as normal sick leave. c) The maternity leave may commence 30 days before confinement and any leave taken prior to this date is not considered as maternity leave. d) A female Employee should notify the Company at least one month in advance on her expected date of taking the maternity leave. 19.6 Paternity Leave a) A confirmed married male Employee is entitled to two (2) consecutive working days of paid Paternity Leave immediately following his wife’s giving birth. This benefit is not applicable if at the time of his wife giving birth, he already has five (5) or more surviving children. b) Application for paternity leave shall be supported by documentary evidence such as a photocopy of the birth certificate of the child. 12

19.7 Birthday Leave a) All Employees shall be entitled to one (1) full working day of birthday leave, which shall be utilised on the actual birthday or three (3) days prior or 3 days after the actual birthday. b) An Employee desiring to take birthday leave shall submit his leave application at least four (4) working days prior to the intended leave period. The Company reserves the right to cancel or reschedule the birthday leave if the exigencies of the Company’s business require the Employee’s service on that particular day. c) In the event the application for birthday leave is cancelled by the Company, the Employee is allowed to re-apply to utilise the said leave on another date which is not later than one (1) month from the date of his birthday. If the birthday leave is still not utilised during this extended period, it shall be forfeited accordingly. 19.8 Casual Leave a) The Company shall grant paid casual leave (subject to an aggregate maximum limit of eight (8) days per calendar year) in addition to the normal annual leave entitlement for the following occasion / incident(s): Employee’s first legal marriage 2 consecutive working days (for confirmed Employee only) 3 consecutive calendar days 3 consecutive working days Compassionate leave Natural disaster (e.g. flood, fire etc.) Compassionate leave is given on the death of the Employee’s spouse, children, brothers, sisters, parents, grandparents and parents-in-law only. Application for marriage leave shall be made at least 7 days in advance. 19.9 Pilgrimage (Haj) Leave a) All confirmed Muslim Employees who have served the Company for more than five (5) consecutive years are eligible for forty (40) consecutive days of paid leave for the purpose of performing the Haj in Mecca. This leave is accorded only once during the Employee’s tenure with the Company. 13

b) An eligible Employee who intends to apply for such leave must submit his application at least one (1) month in advance. The application must be supported by documentary evidence such as letter of confirmation by Tabung Haji or the relevant religious bodies or a confirmed return air ticket for the trip. 19.10 Unpaid Leave Employees are not encouraged to apply for unpaid leave. However, the Company will consider granting such leave when all available paid leave has been utilised and the Employee has to attend to personal matters such as extended maternity leave, serious illness of family members etc. Unpaid leave shall be approved in accordance with the Leave Application Procedure. 20. TERMINATION AND LAY-OFF a) The Company will give priority to deploy Employees who are made redundant due to completion of projects, change in operational requirement, business restructuring etc. by seconding or transferring the affected Employees to other departments or companies within the Group. However, when all avenues have been exhausted and the surplus of manpower still persists, the Company would have to consider a retrenchment exercise. b) In the event an Employee’s service is terminated or laid-off due to redundancy or on medical grounds, he shall be eligible to receive termination benefits in accordance with the provisions in the Employment (Termination and Lay-off Benefits) Regulations 1980, as follows: Termination Benefits Entitlement per year of service Years of service Nil Less than 1 year 10 days wages 1 to less than 2 years 15 days wages 2 to less than 5 years 20 days wages 5 years and above c) Termination of service on medical ground shall be substantiated by a medical report issued by the Company panel doctor or a Government medical officer or the SOCSO Board. Where necessary, a second medical opinion may be sought at the request of the Company. 14

BENEFITS 15

21. FLEXI MEDICAL BENEFITS a) All Employees are eligible to claim for outpatient medical treatment (this benefit is extended to their non-working legal spouse and non-working dependent children up to the age of 23 years old), medical examination / health screening plan, dental treatment (for tooth extraction, scaling & filling only) and corrective spectacles / corrective contact lens, subject to the following aggregate annual limits: Grade Aggregate Limit Per Calendar Year 18 to 25 RM 2,250 14A to 17 RM 1,600 10 to 13 RM 1,000 Note: Only confirmed Employees are entitled for the medical examination, health screening plan, dental treatment and corrective spectacles / corrective contact lens. b) All Employees shall seek for outpatient medical attention and treatment from the Company’s appointed panel doctors. However, Employees who are residing away from the vicinity of the Company’s panel doctors may seek treatment from other registered medical practitioners or Government Medical Officers, registered traditional practitioners / sinseh, and the Company shall reimburse the medical expenses, subject to the annual limits entitlement. c) All Employees should submit the details of their spouse and children to HRD at the beginning of each calendar year or whenever there is any change to their family status. This information is used to update the Employee’s medical entitlement. It is the responsibility of each Employee to promptly notify the HRD of any subsequent changes in his personal data and family data. d) During the first year of employment, the medical benefits entitlement shall be pro-rated in accordance with the total number of completed days of service. e) The medical benefits shall exclude the following: (i) Medical, surgical and optical appliances or aids (except corrective spectacles and corrective contact lens), artificial limbs etc. (ii) Dental appliances such as denture. (iii) Expenses and treatment incurred in respect of pregnancy, confinement, miscarriage, pre and post-natal check-up. 16

(iv) Expenses for the treatment of illness, injuries or disablement arising from attempted suicide or self-inflicted injuries, performance of any unlawful act, intoxication from excessive consumption of alcohol, participation in any hazardous activities, any indiscretion or carelessness of the Employee. (v) Expenses for the treatment of mental or psychotic cases, congenial cases, plastic surgery for beautification purpose etc. (vi) Transportation charges for the purpose of seeking medical attention / treatment. (vii) Preventive medicines such as vaccinations, vitamins & supplements. (viii) Expenses for drug rehabilitation programme (ix) Treatment for HIV and sexually transmitted diseases (x) Long term medication e.g. for illness such as hypertension, high cholesterol, diabetes etc. f) All claims must be supported by documentary evidence for the approval and are inclusive of SST amount. 22. PROLONGED ILLNESS a) A confirmed Employee who has been certified by the SOCSO Board or Company’s panel doctor or Government Medical Officer to be suffering from prolonged illness (such as tuberculosis, cancer, leukemia or other terminal diseases) or due to industrial accidents which renders him incapable of performing his duties, may be granted prolonged illness leave in addition to the normal sick leave / hospitalisation leave, subject to the following conditions. During the first 6 months - paid prolonged illness leave on full pay Next 3 months - half pay leave Next 3 months - unpaid leave b) This prolonged illness leave shall commence after an Employee has exhausted all his annual leave and medical leave entitlement. c) At the end of the twelve (12) months of prolonged illness leave and upon certification and recommendation by the SOCSO Board or Company’s panel doctor or Government Medical Officer, the Employee shall be medically boarded out. The benefits payable shall be in accordance with section 20(b) in this Handbook (Termination and Lay-Off Benefits). 17

23. HOSPITALISATION INSURANCE SCHEME a) The Company shall insure all Employees under its Group Hospitalisation Insurance scheme. The hospitalisation benefit for each Employee is subject to the limit of coverage under the respective plan which the Employee is insured. The Employee shall be responsible to pay for any medical expenses exceeding the limit provided in the insurance policy, or for any medical expenses which are not covered under the insurance policy. b) If an Employee elects to stay in a ward where the ward charges are higher than his entitlement, he shall be responsible to pay for the difference in ward charges and the additional 20% of the total medical expenses as imposed by the insurance company. c) Employees are encouraged to ascertain their eligibility of the hospitalisation benefits first before they proceed to be admitted to any particular private hospital. They should contact the insurance call centre to obtain the necessary clearance. 23.1 Procedure for Hospital Admission a) For non-emergency hospital admission, contact the insurance company’s call centre and provide the insurance policy number and the Employee’s hospital plan. b) Briefly explain the nature of illness and the medical treatment / surgery required. c) Indicate the date of admission and the preferred hospital (for non- emergency cases) d) Obtain the clearance / approval from the call centre and thereafter the call centre will arrange with the hospital concerned regarding the admission. e) On the appointed date, proceed to the hospital admission counter and provide the relevant details (e.g. medical card, doctor’s appointment, nature of treatment etc.). Please note that the admission process may take 1 to 2 hours. f) In the event the required treatment is not covered under the medical insurance, the Employee has to settle the medical expenses on his own accord. The Employee may be required to pay a deposit to the hospital prior to admission. g) For emergency cases, proceed directly to the hospital and provide the medical card to the admission counter. This process may take a few hours as the hospital may need to get confirmation from the insurance company. In some instances, the hospital may require some deposit payment. Employees are advised to make the payment first in order to expedite admission. 18

The Employee or his family members should inform the HRD regarding this emergency admission at first available opportunity. (Please refer to Appendix 2 for details of benefits). 24. GROUP INSURANCE SCHEME a) The Company shall insure all Employees under its Group Insurance scheme against death or permanent disabilities. The coverage is provided 24 hours a day and on worldwide basis. The sum insured shall be in accordance with the Company’s policy. The benefits payable for each Employee is subject to the limit of coverage under the plan which the Employee is insured. b) The insurance premium for this scheme is paid by the Company. Employees may be given the option to contribute on their own for any additional coverage for themselves or for their dependents, subject to acceptance & approval by the insurance company. c) In the event of an accident, the Employee concerned or his family members should notify the HRD at first available opportunity, stating full details of the incident, together with a copy of the Police Report where applicable. This is to enable the Company to file the insurance claim promptly with the Insurer. d) All claims made and received by the Company in relation to this scheme shall be for the benefit of the Employee. In case of death to the Employee, the Company shall pay such benefits to the Employee’s beneficiary(s) subject to the condition that the Company may utilise part of the claims to offset any amount of monies owing by the Employee to the Company. The release of payment due from the insurance policy is also subject to the provisions of Islamic Law if the Employee is a Muslim. e) All Employees are required to nominate their beneficiaries for this purpose and submit such nominations to HRD. (Please refer to Appendix 3 for the Nomination Form & details) 25. TRAINING AND DEVELOPMENT a) The Company recognizes that Employees are the most important assets, and the Company shall, on a regular basis, provide both internal and external training to Employees to enhance their skills and competencies. b) The year-end performance appraisals shall be used as the basis for the respective Heads of Department to identify the training needs and recommend appropriate training courses for their subordinates. 19

c) All recommendation for training (internal and external) shall be forwarded to HRD for review. Thereafter it will be compiled into a master training plan and forwarded to the Management for final approval. The training plan may be revised from time to time to suit operational & business requirements, and the nomination of Employees to be sent for training shall be decided at the discretion of the Company. d) Employees shall make their own travel arrangement when attending external training. However, when a group of Employees (exceeding 2 persons) are attending the same external training or seminar at a location beyond 50 km from their office, the group of Employees should make arrangement to meet at the office or at any other convenient meeting point and travel (and return) together by taxi or on car pool. The Company shall reimburse the travelling expenses as appropriate, including toll charges, mileage and parking charges or taxi fare. 26. LEAVE PASSAGE a) Employees (from Grade 14A and above) who have completed three (3) years continuous service in the Group / Company are eligible for a leave passage according to their current grading in the Company. This benefit is extended to the eligible Employees and their spouses and children only. Employees shall utilise their annual leave when they proceed for their leave passage. Leave Passage Entitlement Yearly Entitlement (inclusive of SST) Grade Maximum RM 7,500.00 22 to 25 Maximum RM 5,000.00 20 to 21 Maximum RM 3,000.00 18 to 19 Maximum RM 1,000.00 15 to 17 Maximum RM 500.00 14A & 14 b) Leave Passage entitlement shall be computed on calendar year basis, and not based on the anniversary date of employment of the Employee. On the first year of eligibility, the leave passage entitlement shall be pro-rated based on the completed number of days of service in the current calendar year. An Employee is allowed to carry forward his leave passage entitlement to the following year up to 31 December only. c) Any unused portion of the leave passage after the end of 2nd year will be forfeited. The Company will not consider any appeal to extend the deadline. 20

d) The Company shall reimburse the expenses related to leave passage only upon the completion of such leave passage by the Employee. The claimable expenses related to leave passage include: (i) airfare, land transport, meals & drinks, admission tickets, toll & parking (ii) hotel accommodation, package tours etc. e) An Employee may utilise the leave passage in any combination of (i) overseas trip, or (ii) local trips f) An Employee cannot claim for the leave passage if he did not personally partake in such trips. g) All original copies of receipts, vouchers, tickets, full tax invoices etc. must be submitted together with the expense claim form. Photostat copies or scanned copies are not acceptable. h) Employees should note that the Leave Passage is treated as “Benefit in Kind” under the Income Tax regulations and is subject to personal income tax in accordance with prevailing regulations. 27. CLUB MEMBERSHIP a) Employees (from Grade 20 and above) who have completed three (3) years continuous service in the Group / Company are eligible to subscribe to one (1) club membership of their choice according to their current grade, as follows: Grade Entitlement (inclusive of SST) 23 to 25 Company subsidies the entrance fees up to a 20 to 22 maximum of RM15,800.00 and the monthly subscription of up to RM150.00 Company subsidies the entrance fees up to a maximum of RM7,500.00 and the monthly subscription of up to RM100.00 b) Employees who have an existing club membership registered under their names only, may claim for reimbursement of the entrance fees, subject to the maximum rate above, upon showing proof of being a member of such club. c) All claims for reimbursement of the monthly subscription fees must be supported by original copies of receipts. 21

28. ANNUAL SUBSCRIPTION TO PROFESSIONAL BODY Confirmed Employees who are members of professional associations may claim for reimbursement of up to two (2) subscriptions upon producing the annual receipts. The subscriptions must be related directly to the discipline in which the Employee is employed to perform. The total reimbursement of subscription fees shall not exceed RM1,000.00 per calendar year. For confirmed Employees who have served less than twelve (12) months service during their first year of employment, the benefit shall be pro-rated to the actual number of completed days of service. 29. COMPANY’S CASH CONTRIBUTION a) In the event that a member of an Employee’s Immediate Family (or the Employee himself) passes away, the Company shall provide a cash token of RM 1,000.00. b) The Company shall provide a cash token of RM 300 on the occasion of a confirmed Employee’s first legal marriage. In the event the husband and wife are from the same company / Group, each of them is eligible for the cash token. The Employee shall provide documentary evidence (e.g. photocopy of marriage certificate) to support his claim for the cash token. 30. EXAMINATION / STUDY LEAVE The Company will consider granting examination or study leave to confirmed Employees only, for the purpose of sitting for an examination leading to a qualification that is relevant to the Employee’s job functions and is endorsed by the Company. The total examination or study leave shall not exceed seven (7) days per calendar year. All applications for examination or study leave must be submitted at least seven (7) days in advance and supported by relevant documentary evidence e.g. letter from the institution / college or examination time-table. Upon obtaining the relevant certificate or qualification, the Employee concerned shall submit a copy of the same to the HRD for record purpose. 22

CODE OF CONDUCT 23

31. CODE OF CONDUCT This Code of Conduct (the ‘Code’) contains policies and guidelines relating to the standards and ethics that all Employees are expected to adhere to in the course of their work. It is designed to maintain a harmonious standard in the work place among Employees of all levels. It also sets out the circumstances in which such Employees would be deemed to have breached the Code and action that can be taken against them if they do so. i) Professional Conduct All Employees shall observe and adhere to the highest standard of professional conduct. They should, in all respects and at all times, conduct themselves with integrity, propriety and decorum and must not under any circumstances, commit any act or omission that would bring damage to the Company, its property, reputation or general interests. Employees are expected to have respect and tolerance for cultures and religions other than those of their own whether locally or overseas and shall conduct themselves in accordance with accepted standards of behaviour. The Company does not tolerate any form of abusive or coercive behaviour whether verbal or otherwise, physical violence or sexual harassment among its Employees. ii) Attendance / Punctuality All Employees are required to observe the stipulated working hours of the Company. If an Employee is unable to commence work on time on any particular day, he must inform his immediate supervisor by telephone at the earliest available opportunity and in any event no later than four (4) hours after commencement of work on that day. Late attendance by an Employee will be recorded in the respective Employee’s attendance record maintained by the HRD. If any Employee is late for work on more than three (3) occasions in a month an appropriate caution letter will be issued to the Employee. If he persists in late attendance and without good reason, he shall be subject to disciplinary action. For the purpose of this section, ‘good reason’ shall be construed as a reason which is not, in the opinion of the HRD, frivolous, or inconsequential. An Employee who is unable to attend work because of illness shall submit his original medical certificate to the HRD on the day he returns to work. An Employee must not, without good reason, be continuously absent from work for more than two (2) consecutive days without having obtained prior approval for leave from his relevant superior. If the Employee is not able to 24

obtain such prior approval, his must inform his superior or the HRD of the reason for such absence at the earliest opportunity during such absence. iii) Appearance Dressing, grooming and personal cleanliness standards contribute to the morale of all Employees and can affect the business image of the Company. All Employees must be suitably attired and groomed at all times at the work place. Their clothes and personal grooming should reflect what is appropriate to their jobs, the work environment and personal safety. For Employees involved in operations with direct contact with the public, casual attire including jeans, short pants, sport shoes, slippers and sandals are not allowed in the work place during working hours. Employees who are provided with company uniforms are expected to wear their uniform during working hours. The following guidelines for office attire for all Employees shall be applicable from Monday to Thursday: Male Employees a) All male Employees are required to wear long sleeve shirts or short sleeve shirts, long pants and appropriate work shoes to the work place. The shirts must be tucked in at all times and no slippers, fit flops and sandals are allowed into the office building. b) All Employees wearing company uniforms are expected to present a professional image to clients, visitors, customers and the public and shall follow the guidelines provided at all times. c) Employees must maintain neatly groomed hairstyle at all times. Bright hair colour shade is not allowed. Female Employees a) The accent is on the professionalism and sensibility. Female Employees are required to dress up smart and neatly that commensurate with their position / job title at the workplace. Dress Down a) All Employees are allowed to dress down on the last working day of the week but in a smart casual manner. b) Employees may wear jeans and athletic shoes on such day, if desired. All jeans must be clean and properly fit. Strictly no frayed ends or torn jeans are allowed. 25

c) Although dress requirements are more relaxed on the last working day of the week, Employees should nonetheless consider the day’s activities when determining what to wear. d) Any Employee scheduled to attend a meeting with the public or any external party should dress appropriately for the occasion. iv) Code Of Ethics a) Commitment (i) All Employees shall, in the course of their employment with the Company and in carrying out their duties and responsibilities in respect thereof, diligently and to the best of their ability perform such duties and responsibilities as may from time to time be assigned or designated to them. (ii) All Employees are expected at all times to promote and advance the interests of the Company and shall not do anything to bring disrepute to the Company. (iii) All Employees shall obey, comply with and observe rules, regulations, procedures, practices, orders, directives and policies of the Company, whether expressed or implied in law or by custom and practice. b) Confidentiality (i) Employees are not permitted whether during or after termination of their employment with the Company, to discuss or divulge confidential information relating or pertaining to the Company directly or indirectly to any person or company unless: - (a) such information has previously been made public knowledge; or (b) upon express approval of the Company; or (c) in the course or carrying out the Company’s business (ii) Employees should not discuss whether among themselves or with others, within the workplace or outside the Company’s premises, confidential information regarding the Company, its business partners, its customers or clients, its Employees or any another confidential information except in the course or carrying out the Company’s business. 26

c) Insubordination and Inefficiency An Employee shall not commit any act of willful refusal, insubordination or disobedience of any lawful and reasonable instruction of his superior. This includes refusal to perform work assigned, being inefficient and deliberately slowing down of work causing the quality and/or the quantity of work to be adversely affected. d) Press Releases and Public Statements An Employee should inform his immediate supervisor if a member of the media approaches him for any information, statement or opinion concerning the Company. Unless authorised by the Company, an Employee shall not make any public statement on the policies or decisions of the Company whether orally or in writing or in any form whatsoever nor shall he circulate or cause to be circulated any such statement. e) Publications Unless authorised by the Company, Employees are not permitted to publish or distribute in any written or printed form, articles, books, periodicals, leaflets, brochures etc. containing information relating to the Company or the Group without prior written approval of the Company. f) Conflict Of Interest An Employee is not permitted to engage directly or indirectly in any other business or occupation whether as principal, agent, servant or broker while still in the employment of the Company. He is also not permitted to engage in any activity, which can be detrimental, directly or indirectly, to the interest of the Company. An Employee is not allowed to participate in or influence the purchase of goods and services from any company or person in which or through which that Employee has or will obtain a direct or indirect interest or benefit. g) Personal Solicitation The Company discourages any solicitation by Employees during working hours as such solicitations normally disrupt business activity and work routines. Employees are not permitted to sell, distribute or act as agent for the sale or distribution of any type of food or merchandise in the office premises. 27

h) Graft and Invitation to Graft An Employee shall not in any manner or form offer on behalf of the Company or receive an offer of graft or a bribe for his own benefit, or for the benefit of his relatives or his family. i) Intellectual Property “Intellectual Property” means any and all intellectual property in any form or stage of development, including but not limited to any idea, concept, design, prototype, product configuration, invention, improvement, modification, patentable subject matter, method, process, technique, procedure, system, plan, model, program, software or code, data, specification, drawing, diagram, flow chart, documentation, know- how, work of authorship, copyrightable subject matter, derivative work, trademark or trade name, and any other subject matter, material or information that qualifies and/or is considered by the Company to qualify for patent, copyright, trademark, trade dress, trade secret, or any other protection under any law providing or creating intellectual property rights. Intellectual Property also includes confidential information learned, obtained or developed in connection with employment, such as specifications, financial data, personnel information, market information, business arrangements and other non-public information of the Company or the Group. If during the tenure of employment with the Company, an Employee either alone or jointly with any other persons make or devise any intellectual property, he shall disclose truly and fully to the Company and deliver to the Company all documents, working papers, specifications, software programs or formula pertaining to the above, which may be in his control, possession or custody. The Employee shall cooperate with the Management and to assist in the preparation and execution of all documents relating to any effort by or on behalf of the Company to apply for, obtain, maintain, transfer, or enforce any intellectual property right relating to any patent, trademark or copyright, at the request and expense of the Company. j) Return of Company’s Assets Employees are responsible for all the Company’s property, materials, documents, keys or data (whether imprinted form or otherwise) issued to them or in their possession or control. Employees must return all the Company’s asset that is in their possession in the event of termination of employment for whatever reasons. In the event the said asset is not returned as required, the Company may take all action deemed appropriate to recover or protect its assets. 28

k) Electronic Communication The use of electronic or e-mail in any manner which may be disruptive, offensive to others or harmful to Employee morale, is strictly prohibited. Such transmissions may be grounds for strict disciplinary action including dismissal. Employees are not permitted to download any illegal or unauthorized software programs from the internet and / or install such illegal or unauthorized programs into their desktop computers / laptops in the office. l) Safety The establishment and maintenance of a safe work environment is the shared responsibility of Employees and the Company. Employees are expected to obey safety rules and to exercise caution in all their work activities. Unsafe conditions, regardless of how insignificant they may appear, must be promptly reported to the HRD or the Administration department. m) Poaching of Employee Employees who are leaving or have already left the service of the Company should abstain from enticing or persuading other Employees to leave the Company. 32. SEXUAL HARASSMENT a) It is the policy of the Company to promote a safe and healthy working environment that foster mutual respect where individual Employees irrespective of status or position are treated with dignity and free from sexual harassment. Employees are strictly prohibited from engaging in any form of harassment, humiliation and intimidation of a sexual nature. b) Definition Sexual harassment is defined as any unwanted conduct of a sexual nature having the effect of verbal, non-verbal, visual, psychological or physical harassment. (i) That may, on reasonable ground, be perceived by the recipient as placing a condition of a sexual nature on his employment. (ii) That may, on reasonable, be perceived as a threat to his well-being, but has not direct link to his employment. 29

c) Sexual harassment can occur between individuals of different sexes or of the same sex. Based on the above definition, sexual harassment may be divided into two categories, namely sexual coercion and sexual annoyance. (i) Sexual coercion is sexual harassment that results in some direct consequence to the victim’s employment. An example of sexual harassment of this coercive kind is where a superior, who has power over salary and promotion, attempts to coerce a subordinate to grant sexual favours. If the subordinate accedes to the superior’s sexual solicitation, job benefits will follow. Conversely, if the subordinate refuses, job benefits are denied. (ii) Sexual annoyance, the second type of sexual harassment is sexually related conduct that if offensive, hostile or intimidating to the recipient, but nonetheless has no direct link to any job benefits. However, the annoying conduct creates a bothersome working environment which the recipient has ton tolerate in order to continue working. Sexual harassment by an Employee against a co-Employee falls into this category. Similarly, harassment by a Company’s client against an Employee falls into this category. d) Sexual harassment in the workplace includes any employment-related sexual harassment occurring outside the workplace as a result of employment responsibilities or employment relationships. Situations under which such employment-related sexual harassment may take place include, but are not limited to the following: (i) at work-related social functions; (ii) in the course of work assignments outside the workplace; (iii) during work-related conferences or training sessions; (iv) during work-related travel (v) over the phone; and (vi) through electronic media It is essential to emphasize that sexual harassment refers to sexual conduct, which is unwanted and unwelcome to the recipient. It is also a sexual conduct which is imposed on and unsolicited or unreciprocated by the recipient. e) Forms of Sexual Harassment Sexual harassment encompasses various conducts of a sexual nature which can manifest themselves in five possible forms, namely: (i) verbal harassment: e.g. offensive or suggestive remarks, comments, jokes, kidding, teasing, sounds, inquiries or discussions about sexual activities or other verbal abuse; 30

(ii) non-verbal / gesture harassment e.g. leering or ogling with suggestive overtones, licking lips, holding or eating food provocatively, hand signal or sign language denoting sexual activity, persistent flirting; (iii) visual harassment e.g. showing pornographic materials, writing sexually suggestive letters or other written material, sexual exposure; (iv) psychological harassment e.g. repeated unwanted social invitations, proposal for dates or physical intimacy; (v) physical harassment e.g. inappropriate touching, patting, pinching, stroking, grabbing, hugging, kissing, fondling, brushing up against the body, coerced sexual intercourse or sexual assault. f) Disciplinary Action Since sexual harassment is a form of misconduct, all Employees including supervisors and manager will be subject to disciplinary action up to and including dismissal for engaging in sexual harassment. Employees who make false and malicious complaints of sexual harassment as opposed to complaints that are made in good faith will also be subject to disciplinary action. An independent and thorough investigation in a manner that is as confidential as possible under the circumstance will be carried out on all complaints received alleging sexual harassment. g) Complaint Procedure Due to the sensitive and personal nature of sexual harassment complaints, the Company will pay special attention to deal specifically with such complaints. Employees who believe they have been aggrieved under this policy are strongly encouraged to raise written complaints of sexual harassment as promptly as possible to the HRD. Delay in making a complaint of sexual harassment may make it more difficult for the Company to conduct an investigation. As a standard practice, all cases of sexual harassment will be reported to the Police for further action. 33. DISCIPLINE a) The Company must ensure that a reasonable standard of work and conduct is maintained in the management of its business. The Company is equally concerned to ensure fair treatment for Employees when disciplinary action has to be taken in the event the Employees failed to meet the necessary 31

performance standards or have committed misconduct; and such cases will be dealt with in accordance with the rules of natural justice. b) Misconduct A “Misconduct” is defined as any act or omission which is inconsistent with the fulfillment of the expressed or implied conditions of the contract of service. The following are some examples of misconduct and is not exhaustive: - Major Misconduct (shall include but not limited to) (1) Willful insubordination’s or disobedience whether alone or in concert with others, to any lawful and reasonable order of a superior. (2) Theft, fraud or dishonesty including attempted fraud or attempted dishonesty in connection with Company’s business, monies and property. (3) Willful damage to or loss of Company goods, assets or property. (4) Taking or giving bribes or any illegal gratification. (5) Gambling or card playing, whether for monetary gain or otherwise. (6) Riotous or disorderly behaviour or fighting in the Company’s premises. (7) Violence, abusing, assaulting or threatening to abuse or assault or to injure another Employee or superior within Company’s premises. (8) Habitual absence; absence for more than two (2) consecutive days without reasonable excuse (AWOL) or without informing or attempting to inform the Company at the earliest opportunity. (9) Leaving work place during working hours without permission. (10) Habitual late attendance. (11) Engaging in strikes or inciting others to strike in contravention of provisions of any written laws or regulations of Malaysia. (12) Habitual or culpable negligence of his duties. (13) Willful slowing down of work or inciting others to do so. (14) Disclosing commercial secrets or design of the Company. (15) Collection of monies or distributing of pictures, literature, leaflets or posting notices within the Company premises without the prior approval in writing of the Company. 32

(16) Repeated failure to meet established work standard and slackness in performance. (17) Failure to obey safety rules or tempering with other safety devices. (18) Inefficiency or lack of skill which an Employee expressly or implicitly warrants himself to know or possess. (19) Habitual breach of any Company rules and regulations pertaining to conduct and discipline. (20) Participating in illegal activities with the intention of causing the company to make loses, incur expenses or reduce it’s earnings. (21) Bringing and/or consuming alcoholic liquor within the Company’s premises while on duty without prior permission of the Company. (22) Possessing illegal drugs or narcotics or illegal or dangerous weapons within the Company’s premises. (23) Stealing other Employees’ property within the Company’s premises. (24) Committing an immoral act within the Company’s premises. (25) Failure to give reasonable or satisfactory explanation for the presence of Company’s property or products found in the Employee’s vehicle or in the Employee’s possession. (26) Clocking another Employee’s attendance on his behalf or tempering with the time clock or altering the clock card to produce a fraudulent result. (27) Failure to report an infections or contagious disease affecting himself to the Company or Company Panel Doctors. (28) Obtaining or attempting leave or absence by false pretense. (29) Failure or refusal to submit to a search when required to do so by the Company’s authorized personnel within the Company’s premises. (30) Participating in any subversive activities which affect the general behaviour of other Employees in the Company. (31) Engaging in private work or trade within the Company’s premises. (32) Making false representation when submitting claims to the Company. (33) Conduct within the Company, which is likely to endanger the life or safety of any person. 33

(34) Refusal to accept any communication served either in accordance with the code of conduct or in the interest of discipline. (35) Interfering with the record of attendance or recording attendance of any other Employee or falsification, defacement or destruction of any record of the Company. (36) Trespassing or forcible occupation of the Company’s premises. (37) Picketing in the Company’s premises except where allowed under any written law. (38) Willful failure to report at once to the Company any defect which an Employee may notice in any equipment connected with work. (39) Willful failure to report any defect or occurrence which an Employee may notice, or which might endanger himself or any other Employee or public users or which might result in damage to the Company’s or any person’s property within Company’s premises. (40) Threaten, intimidate or instigate other Employee to take any form of illegal industrial action. (41) Deliberate damage and interference with or contamination of materials or equipment. (42) Forging or defacing medical certificates or other official documents to defraud the Company. (43) Sleeping while on duty. (44) Sexual harassment and / or other form of harassment. Minor Misconduct (shall include but not limited to) (1) Absent without permission and without valid reason or excuse. (2) Coming late to work. (3) Any action contrary to Company’s procedures. (4) Leaving work, workplace, etc. or leaving before the proper ending time without prior permission. (5) Committing nuisance in the office or at Company’s premises. (6) Tempering or damaging or disposing the Company’s uniforms. (7) Not taking proper care of the Company’s properties, assets or goods entrusted to him 34

(8) Posting, altering or removing any matter or bulletin boards or Company’s property without the permission of the Company. (9) Bringing friends/visitors into company premise without permission, unless on official tour of the restricted areas. Entertaining private visitors without permission. (10) Failure to observe the safety and health rules and regulations. (11) Interfering with another person’s work during working hours. Not informing the Company when leaving workplace. (12) Not wearing uniform provided by the Company while at work. (13) Improper use of toilets or other facilities. (14) Unauthorized use of the Company’s vehicles, equipment or fire or safety devices and appliances. c) Procedure on Disciplinary Action All disciplinary actions taken by the Company shall comply with the Company’s established procedures and current legislation. Where there is any conflict between the two, the current legislation shall prevail. (i) For minor misconduct, the Head of Department shall, after counselling the Employee concerned, issue a caution letter to the Employee with a copy given to HRD for record purpose. (ii) For misconduct which warrants a warning, the Head of Department shall notify the HRD by providing all relevant details pertaining to the case to enable the HRD to take appropriate action. (iii) For repeated misconducts, a second or final warning letter, as the case may be, will be issued to the Employee after investigation has been conducted. If the Employee commits further misconducts after receipt of the final warning, stern disciplinary action including dismissal may be taken against him after due inquiry. The above disciplinary actions are only applicable to normal misconducts and offences. In the case where the misconduct or offence is of a fundamental nature, instant dismissal will be effected when the Employee is found guilty after due inquiry. Depending on the gravity of the alleged offence(s) the Company may temporarily suspend the Employee concerned from work during the process of investigation or pending the outcome of the domestic inquiry. For cases which involve criminal breach of trust or which result in financial loss to the Company, criminal and civil actions will be instituted against the Employee(s) concerned. 35

d) Inquiry A panel appointed by the Company shall conduct all domestic inquiries. The inquiry panel shall not include a member(s) whose presence may affect the impartiality of the panel in its conduct of the proceedings and its recommendations. The proceedings of an inquiry shall be duly recorded by the panel for submission to the HRD or to the appropriate higher authority for decision. e) Disciplinary Actions Depending on the gravity of the offence committed and after due inquiry, the Employee who is found guilty may subject to any one of the following punishments: (1) Dismissal without notice (2) Downgrading (3) Suspension without pay up to a maximum of two (2) weeks. (4) Stoppage/withholding of increment (5) Withholding of bonus (6) Withholding of promotion (7) Reduction of salary (8) Written Warning (9) Any other form of disciplinary action as deemed appropriate. f) Right of Appeal An Employee who has been imposed a disciplinary action shall have the right to appeal in writing within three (3) working days of the announcement of the decision, to any one of the following as appropriate: Head of Company / Executive Director / Managing Director / Chief Operating Officer / Chief Executive Officer The decision of the Company is final and shall be submitted to the Employee in writing. g) Grievance Procedure (i) A grievance is defined as any discontent or dissatisfaction, whether expressed or not, arising out of anything connected with the Company that an Employee thinks, believes or perceives as unfair, unjust or inequitable. (ii) It is the desire of the Company that any grievances arising between an Employee and another or between an Employee and his superior, be settled as amicably, equitably and quickly as possible. 36

(iii) Employees should, whenever possible try to resolve disputes and minor problems amicably and informally among themselves or together with their immediate supervisors. (iv) If such informal means do not bring a resolution, an Employee may bring to the HRD attention any grievance or complaint within seven (7) days form the date of occurrence of the event. The filing of a formal grievance in writing should be done only if such complaints cannot be resolved through these informal discussions. A member of the HRD shall be assigned by the Company to attend to such grievances or complaints. (v) The HRD may at its discretion and depending on the seriousness of the grievances and complaints, bring the matter to the attention of the Head of Company / Executive Director / Managing Director / Chief Operating Officer for consideration. A decision will be made within the next 5 working days which is deemed as final and binding. 34. PERSONAL DATA PROTECTION ACT a) In compliance with the provisions of the Personal Data Protection Act 2010 (PDPA) the Company is committed to safeguard all personal information that is kept by the Human Resource Department. b) All Employees who have direct and indirect access to personal information of other Employees are required to take all preventive and remedial measures to prevent leakage, loss or damage of personal data that is in your possession. c) Record Management (i) Ensure that all personal data and employment records are updated and accurate at all times, e.g. name, address, identity card number, email address, salary, medical, bank account number, designation, benefits, leave, statutory contributions and personal income tax records. (ii) All personal data whether in electronic form, digital form, in digital image or in hardcopy must be kept and stored in secured locations and /or in cabinets under lock and key. The personal data must be filed in a manner that is orderly and easy to retrieve by the authorised HR users. All personal data that is stored in computer system, human Resource system etc. must be password protected to prevent unauthorised access. All passwords must not be disclosed to any third party/other Employees, and these passwords should preferably be changed every six (6) months. 37

(iii) Should the processing of personal data be outsourced to a third party, the Management shall conclude a confidentiality agreement with that third party requiring the protection of our personal data. (iv) When it is necessary or upon the instruction by the Management to transfer personal data from one location to another location using electronic mail or digital storage appliances, all such data must be encrypted and /or password protected. Personal data should not be copied or transferred in whatever form for personal use. (v) Do not disclose or divulge the personal data to any Employee or third party, except when you under a lawful duty of care to do so, or when under the lawful instruction of authorised Management representatives. (vi) When it becomes necessary to discard personal data for whatever reason (e.g. old records exceeding seven (7) years, unsuccessful job applicants’ details etc.), such data must be destroyed in a proper manner. Examples include using paper shredders, deletion from computer system or storage media, outsourced documents destruction etc. (vii) The collection, retention and processing of personal data shall comply with all laws, government guidelines and other regulations governing the protection of personal data. (viii) The Management shall continually review and improve its Personal Data Protection Management System in line with changes in its business operations as well as changes in the legal, social, and IT environment. As and when there are changes to such system, all relevant Employees shall be notified accordingly. (ix) All employees have the right of access and request for amendment to their personal data held the Company. An employee may direct such request to the HR Department. In accordance with the Personal Data Protection Act 2010 (Act), the Company reserves the right to charge an employee a reasonable fee for the processing of any data access request. 35. WHISTLE BLOWING POLICY a) All Employees are encouraged to raise genuine concerns about possible improprieties in matters of financial reporting, compliance and other malpractices at the earliest opportunity, and in an appropriate way. 38

b) This policy is designed to: (i) Support the company’s value; (ii) Ensure Employees can raise concerns without fear of reprisals; and (iii) Provide a transparent and confidential process for dealing with concerns. c) This policy not only covers possible improprieties in matters of financial reporting, but also: (i) Fraud; (ii) Corruption, bribery or blackmail; (iii) Criminal offences; (iv) Failure to comply with a legal or regulatory obligation; (v) Miscarriage of justice; (vi) Endangerment of an individual’s health and safety; and (vii) Concealment of any or a combination of the above. d) Principles The principles underpinning the policy are as follows: (i) All concerns raised will be treated fairly and properly; (ii) The company will not tolerate harassment or victimization of anyone raising a genuine concern; (iii) Any individual making a disclosure will retain anonymity unless the individual agrees otherwise; (iv) The company will ensure that any individual raising a concern is aware of who is handling the matter; and (v) The company will ensure no one will be at risk of suffering some form of reprisal as a result of raising a concern even if the individual is mistaken. The company, however, does not extend this assurance to someone who maliciously raises a matter he / she knows is untrue. e) Whistle-Blower Channel (i) If any Employee believes reasonably and in good faith that malpractice exists in the work place, the Employee should report this immediately to the line manager. However, if for any reason the Employee is reluctant to do so, then the Employee should report the concern to the higher management team or any designated person in the company. (ii) Your legitimate concerns contained in a written report should be sealed in an envelope and marked as “Strictly Private & Confidential & to be Opened by Addressee only”. (iii) The following information is necessary when submitting your legitimate concerns: - 39

(a) Your name, designation and company / division / department / unit and telephone contact number; (b) Specific description of the incident / case; (c) The name of the individual(s) and entity involved in the legitimate concerns; (d) Documentary evidence, if any, to support your legitimate concerns; (e) Particulars and contact numbers of witnesses, if any. (iv) Anonymous reports/ allegations/ complaints are not encouraged, but they may be considered at the discretion of the person(s) to whom the reports/ allegations/ complaints are addressed to, depending on the severity of the reports/ allegations/ complaints. (v) Other than the above channels, you can also forward your legitimate concerns via email to [email protected]. The Management may direct any of the Appointed Representative to deal with the matter and report the outcome to the Management. f) Your Safeguard (i) The person(s) to whom the report is addressed to is required to treat all such report and YOUR IDENTITY in a confidential manner. (ii) If you have raised a legitimate concern in good faith, you WILL NOT BE subject to any disciplinary action. (iii) However, the Group reserves the right to consider disciplinary action against any Employee who had submitted a report / allegation / complaint when: (a) he / she is later proved to have acted maliciously, vexatiously or frivolously; or (b) the report / allegation /complaint is manifestly untrue; or (c) he / she is acting for personal gain or personal interest. g) What Happens To Your Report? (i) Legitimate Concerns Reported to Your Superiors a) If you have reported a legitimate concern to your immediate superior or to the head of the division/department/unit, it will be acknowledged and immediately thereafter forwarded to the head of the company who will conduct a preliminary investigation to determine whether it merits further investigation. b) You will be informed on the conclusion arrived therefrom as soon as a decision is made. 40

(ii) Legitimate Concerns Reported to the Appointed Management (a) If you have reported your legitimate concerns to the Appointed Management, the Appointed Management will duly acknowledge receipt and conduct a preliminary investigation to determine whether it merits further investigation. (b) You will be informed on the conclusion arrived therefrom as soon as a decision is made. (c) Where necessary, the Appointed Management will appoint and authorise an Inquiry Committee to pursue this matter in an expedient manner. (iii) To assist the Inquiry Committee in gathering information, you may be required to provide further clarification and information from time to time. (iv) To assist the Inquiry Committee in gathering information, you may be required to provide further clarification and information from time to time. (v) Where necessary, the Company will initiate appropriate action against any party proven to be in the wrong in accordance with prevailing company policy. If there is sufficient evidence of illegal /criminal activity, the Company may lodge a police report accordingly. 41

GENERAL 42

36. EMPLOYEE RELOCATION An Employee may be required to be relocated from one location to another, depending on the requirements of the Company. Expenses related to this relocation shall be reimbursed / paid by the Company as follows: a) Temporary Relocation Definition Temporary relocation is defined as relocation to a place exceeding 100 KM from the home base for a continuous period of exceeding 1 month but less than 6 months. (i) If the Employee needs to source for suitable accommodation at the new location, he is allowed to stay at a hotel for up to two (2) weeks during the interim period. If additional time is required, then it will be reviewed on a case to case basis. (ii) An outstation / overseas meal allowance according to the grade will be paid to the Employee during his stay at the hotel. (iii) The cost of public transportation (eg. taxi, train, economy class air fare) for the Employee and his immediate family (where applicable) will be reimbursed. (iv) If the Employee uses his private vehicle to travel, he is eligible to make a mileage claim in accordance with the Company’s policy. (v) Items iii) and iv) above shall be applicable when the Employee and his immediate family members (where applicable) return to his original designated work place. (vi) There are occasions where an Employee is required to be posted to another location immediately upon completing the initial relocation. In these situations, the Company shall work out a separate reimbursement scheme for the Employee, based on a case to case basis. b) Permanent Relocation (for period exceeding 6 months) (i) If the Employee needs to source for suitable accommodation at the new location, he is allowed to stay at a hotel for up to two (2) weeks during the interim period. If additional time is required, then it will be reviewed on a case to case basis. (ii) An outstation / overseas allowance according to the grade will be paid to the Employee during his stay at the hotel. (iii) The cost of public transportation (e.g. taxi, train, economy class air fare) for the Employee and his immediate family will be reimbursed. (iv) If the Employee uses his private vehicle to travel, he is eligible to make a mileage claim in accordance with Company policy. 43

(v) The Company shall reimburse an Employee for the relocation of his personal belongings / household items to his new posting. The Employees should carry with him all valuable items during the relocation process. The transfer of personal items shall either be by land, air or sea freight, whichever is the most economical. The disbursement shall be against actual receipts / full tax invoices and is inclusive of insurance coverage & SST for each relocation (whether temporary or permanent). Status Within Malaysia Other countries RM 500 RM 1,500 Employee travelling alone RM 1,000 RM 3,000 Married Employee travelling with immediate family c) Relocation Allowance During each relocation, a relocation allowance shall be paid to Employees who are relocated (whether temporary or permanent), as follows: Status Within Malaysia Other countries RM 400 RM 600 Employee travelling alone RM 600 RM 1,000 Married Employee travelling with immediate family 37. COMPANY TRAVEL 37.1 Travelling within Malaysia Mode of transport Type of payment Taxi, bus, train Reimbursement based on actual receipts. Flight Within Malaysia Grade Business Class 22 to 25 10 to 21 Economy Class Note: Please provide full tax invoice to support your claims. 44

37.2 Mileage Claim a) For using private motor car: For cars below 1.3L 70 cent / Km For cars 1.3 L & above 80 cent / Km b) For using private motorcycle - 40 cent / Km. Employees who are currently placed under special travelling schemes (example, fixed transport allowance) due to the nature of their job scope shall continue to participate in such schemes and they shall not be eligible to make mileage claims as stated above. For any exceptional travelling, they may claim for petrol reimbursement based on receipts only. The claim shall be submitted on a monthly basis instead of ‘per trip’ basis. Toll, parking and related expenses shall be reimbursed on actual basis and these must to be supported with bills / receipts whenever applicable Employees who have to travel in a group on company business shall, whenever possible, car-pool to minimize travelling expenses. The person who uses his personal vehicle for this purpose shall be eligible to claim for mileage and related expenses. 37.3 Travelling using Company Vehicle Employees who use company vehicle to travel on company business shall be eligible to claim for reimbursement for petrol, toll and parking based on actual expenses. They are not eligible to claim for mileage. 37.4 Outstation Meal Allowance (within Malaysia) An Employee is eligible to claim for outstation meal allowance when he travels outstation on company business: Grade Meal Within Malaysia Grade 22 to 25 Based on actual Grade 10 to 21 Breakfast RM15 Lunch RM20 Dinner RM20 45