SUPPLIER CODE OF CODUCT POLICY

SAFETYWARE SDN BHD and all its subsidiaries (“Safetyware Group”) is committed to responsible business practices and ethical behaviour. We operate on integrity-based approach to our supply chain and to our social responsibilities and looks to work with Suppliers who share our values.

Where appropriate we will work with our supply chain to make sure that they have the right policies and processes in place to demonstrate that they, in turn, will use the same principles with their own supply chain.

We shall also consider these principles when we are choosing Suppliers to work with.

This Supplier Code of Conduct (the “Code”) sets out the minimum standards of integrity which we expect our suppliers to adhere to. This Code is subject to modification, amendment or revocation by Safetyware Group at any time and without prior notice.

None of the policies or guidelines in this Code is intended to give rise to contractual rights, or to be construed as a guarantee for any specific period of time, or any specific type of work. This Code complements the relevant contract for services or other policies which we have shared with you (if any).

• Reference to ‘we’, ‘us’ or ‘our’ means Safetyware Group. This Code is applicable to all our suppliers including their employees, workers, contractors and agents. Reference to ‘you’ or ‘your’ refers to the suppliers including their employees, workers, contractors and agents.
• The suppliers are expected to meet the requirements of this Code and this is incorporated into our contractual arrangement.
• If you have any queries related to this Code or you are not sure how to apply the provisions stipulated in this Code, you are encouraged to contact your usual contact from Safetyware Group.

The principles of our approach are based on complying with legislation and regulations. However, this compliance is the minimum standard and we will always look to exceed these standards where possible.

Supplier should uphold the highest standards of integrity, transparency and governance and we require Supplier to adhere to agreements which are underpinned by such concepts. We consider a sustainable supply chain is key part of our commitment to the environment and social responsibility.

For the purposes of this Supplier Code of Conduct (CoC), a vendor is defined as an external party that has entered or proposed to enter into a business or contractual relationship with Safetyware Group, to provide business goods, services, functions or activities or to act on behalf of Safetyware Group. All vendors must comply with the CoC while conducting business with or on behalf of Safetyware Group and must ensure that their employees, agents, representatives, and sub-contractors comply with the CoC. Safetyware Group also reserves the right to take appropriate steps regarding its relationship with the vendor if there is a reason for concern and to take any action it deems fit against any vendor for non-compliance with the CoC, which may include –

• Non-renewal of contract;
• Reporting to the relevant authorities; or
• Disqualifying from participation in any procurement exercise.

The vendor must cooperate with Safetyware Group in any investigation Safetyware Group may conduct in relation to any allegation of inappropriate or unethical behaviour involving Safetyware Group’s employees or the vendor’s representatives pursuant to any business interaction or procurement exercise.

The suppliers are expected to comply with all relevant laws, codes, industrial standards, and regulations applicable to the suppliers. We reserve the right to verify and assess new and existing suppliers’ compliance with this Code.

It is our Code to conduct all of our business in an honest and ethical manner. We are committed to act professionally, fairly and with integrity in all our business dealings and relationships. Supplier shall always be ethical in every aspect of its business, including relationships, practices, sourcing, and operations.

5.1. NO EXPLOITATION OF LABOUR

We expect our suppliers to ensure that their operations are free from slavery and forced, bonded, involuntary, or unlawful migrant labour. The suppliers are expected to ensure that the employment agencies or the relevant third parties acting on behalf of the suppliers will not require workers to pay recruitment fees or other related fees for their employment. Also, all migrant workers shall have the access to their identification documents (e.g., passport) at all times and the workers are not prevented from free association.

5.2. NO CHILD LABOUR

We expect our suppliers to ensure their operations are free from child labour. As such:

• the minimum age for work should not be below the legal age for finishing compulsory schooling and, in any case, not less than the age of 18 or the minimum age applicable in the jurisdiction of where you are operated; and
• any work which is considered hazardous or likely to harm the health or safety of children should not be done by anyone under the age of 18 or the minimum age applicable in the jurisdiction of where you are operated.

5.3. EQUAL EMPLOYMENT OPPORTUNITY

We expect our suppliers to be dedicated to providing equal opportunities to their employees and workers and to creating an inclusive workforce by promoting equal remuneration for work of equal value and employment equality. The suppliers shall not allow race, colour, religion, national origin, sex, age, marital status, disability, political affiliation, or any other characteristic protected by law to influence their judgment when it comes to the recruitment, development, advancement, disciplinary actions, salary or benefits administration or retirement of any employee.

5.4. WORKING HOURS

We expect our suppliers to comply with all applicable working time laws and other applicable laws, code and regulations including any legally mandated maximum working hours requirements.

5.5. WAGES, WORK HOURS & BENEFITS

Wages and benefits need to be in accordance with relevant legislation. Supplier must provide wages and benefits that comply with applicable laws and agreements, including minimum wage, overtime, maximum hour rules, and meal and rest periods. All deductions from wages should be lawful and with the expressed permission of the employee.

Workweeks set by Suppliers are not to exceed the maximum set by local law. Suppliers must comply with applicable working hours requirement and encourage reasonable working hours including overtime, except in emergency or unusual situations Supplier shall provide their employees with at least one day off for every 7-day period on average. Overtime is voluntary and employees are paid in accordance with statutory order.

5.6. HUMANE TREATMENT

Safetyware Groupprohibits harsh or inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of employee; nor is there to be the threat of any such treatment. Supplier shall ensure that disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to employees. Supplier is encouraged to utilize the grievance procedure to report any in human treatment, concern and problem. All grievance reported shall be promptly and thoroughly investigated.

5.7. POLICY AGAINST WORKPLACE HARASSMENT AND BULLYING

All aspects of bullying and harassment are completely unacceptable. We expect our suppliers to be committed to removing any such attitudes or actions from the workplace. Harassment and bullying including, but is not limited to, any form of sexual, verbal, non-verbal and physical behaviour (whether express or implied) which is intimidating, humiliating, offensive, hostile or abusive; or has the purpose or effect of unreasonably interfering adversely with an individual’s work performance or equal employment opportunities.

This applies to all work‐related settings and activities, whether inside or outside the workplace, and includes business trips and business‐related social events.

Please refer to Human Rights Policy for more details.

5.8. ANTI-BRIBERY, ANTI-CORRUPTION, CONFLICT OF INTEREST POLICY & WHISTLE BLOWING POLICY

We expect our suppliers to be committed to conducting its business in an ethical and honest manner and is committed to implementing and enforcing policies that ensure bribery or corruption is prevented.

5.8.1. Fair Competition

5.8.2. Anti-Bribery and Anti-Corruption