company policies

Every employee has the responsibility to promptly report any violation or suspected violation of the Code of Conduct, policies and procedures, or applicable law or regulation, in order to protect the Company, its stakeholders, its employees, its suppliers and its customers. Anybody who is an accomplice,accessory, collaborator or deliberately permits the execution of any irregular or fraudulent act shall be equally liable. All employees, rank and files, officers and expatriates are covered by this policy.

The policy aims to protect the whistle blower from retribution or retaliation, and provides a disincentive to passively allowing the commission of wrongful conduct. The whistle blowing policy provides for procedures for interested parties to communicate, even anonymously, concerns regarding accounting, internal accounting, auditing or financial reporting matters directly to the Audit Committee.

All employees must avoid and/or declare any situations or relationships which might conflict with the legitimate business interests of the Company. Such a conflict will exist where an employee compromises his or her ability to act with total objectivity with regard to the Company’s business interests. Conflicts of interest occur when your personal interests or activities (a) influence, or appear to influence, your judgment when acting on behalf of the Company; (b) result in your competing, or appearing to compete, with the Company or your diverting, or appearing to divert, business from the Company; (c) diminish, or appear to diminish, the efficiency, effectiveness or objectivity with which you perform your duties; (d) result in your receiving improper personal benefits due to your position within the Company; or (e) actually or appears to harm or impair the Company’s reputation, including the goodwill arising from the Berjaya name. Moreover, prohibited conflicts can occur because of the interests or activities of close family members and/or other individuals who live in your household.

While it is not feasible to describe all of the situations in which conflicts of interest may arise, the following guidelines apply:

Corporate Opportunities Company employees are prohibited from using opportunities discovered in the course of their employment for their own personal gain or benefit. For example, if, in his or her capacity as a Company employee or representative, an employee, officer or a Director of the Company is approached about or otherwise becomes aware of a potential investment that may be appropriate for the Company, such individual should not take that opportunity for himself or herself, but should bring it to the attention of his or her manager or other appropriate Company personnel.

Conflicts Arising from Ownership or Investments No employee or family member of an employee may, without disclosure to, and the written consent of, the Head of Operating Company/Supervising Director, have either a direct or an indirect ownership or other interest in any supplier of goods or services to the Company, any customer of the Company, or any competitor of the Company. All such relationships are subject to the disclosure and consent process on a case by case basis.

Community, Charitable and Other Outside Activities The Company generally encourages employees to participate in community, charitable and other outside activities. However, you are expected to avoid any outside personal interest or activity (whether or not for profit) that will interfere with your duties to the Company. As a guideline, your activities should not encroach on time or attention that you should be devoting to Company business; adversely affect the quality of your work; compete with the Company’s business or imply Company sponsorship or support (for example, through the use of Company stationery) without express Company approval; and/or adversely affect the reputation of the Company, including the Berjaya name, which is a valuable asset
of the Company

Work or Employment outside the Company
The employee shall not, without the prior expressed written consent of the Company which consent shall not be unreasonably withheld ,either directly or
indirectly during the continuance of his or her employment with the Company, be engaged in any capacity in any trade, business or occupation whatsoever other
than being in the employ of the Company. In this Clause, the expression “occupation” shall include membership of parliament or state assemblies or
any other public or private work which in the opinion of the Company may hinder or otherwise interfere with the performance by the employee of his or her duties
whilst in the employment of the Company.

The Company is committed to maintaining a safe and healthy workplace for all employees, and to protecting the environment in which we operate. Accordingly,
the Company will use its best endeavour:

To meet all requirements of applicable environmental, health and safety laws and regulations. To promote employee safety and minimize the environmental impact of the development, production and distribution of our products.

To encourage and apply pollution prevention, resource conservation, waste minimization, reuse and recycling practices.

To promote responsible environmental and safety practices, enhancing awareness among our employees.

To implement and update prevention and training programs and any other measures needed to reduce the risks of illness and accidents.

All employees are required to comply with the safety and health regulations and instructions and fire prevention and fire fighting regulations issued by the
Company from time to time. Any employee who fails to comply with the regulations and instructions will render himself liable for disciplinary action.

Any injury suffered in an accident at work must be reported to the Head of Operating Company/Group Function immediately for necessary action.

Berjaya Philippines, Inc. (“The Company”) recognizes that Related Party Transactions should be subject to review and approval to ensure that such
transactions are entered into with due care and thorough deliberation, and within the limitations provided by relevant laws and regulations.

The Company shall ensure that all transactions are fair to the Company and are at arm’s length, with sufficient documentation, full disclosure to the Board and
subjected to vigorous scrutiny by the directors, and must be approved by a majority vote of the Board of Directors.

The Officers/Directors of the Company, as a general rule, discourages transactions with Officers and Directors and their spouses/children/siblings/ parents. Where
such a transaction arises, the Company takes deliberate care in ensuring that the same fosters no conflict of interest, and is not prejudicial to the Company.

Material transactions of such nature are duly disclosed to the Board for the latter’s scrutiny and approval. Disclosure obligations required by law and relevant
regulation are also duly complied with by the Company, in case of related party transactions requiring shareholders’ approval, the guideline that the decision should be made by disinterested shareholders shall be observed.

The Company is committed to maintaining a safe and healthy workplace for all employees, and to protecting the environment in which we operate. Accordingly,
the Company will use its best endeavour:

To meet all requirements of applicable environmental, health and safety laws and regulations. To promote employee safety and minimize the environmental impact of the development, production and distribution of our products.

To encourage and apply pollution prevention, resource conservation, waste minimization, reuse and recycling practices.

To promote responsible environmental and safety practices, enhancing awareness among our employees.

To implement and update prevention and training programs and any other measures needed to reduce the risks of illness and accidents.

All employees are required to comply with the safety and health regulations and instructions and fire prevention and fire fighting regulations issued by the
Company from time to time. Any employee who fails to comply with the regulations and instructions will render himself liable for disciplinary action.

Any injury suffered in an accident at work must be reported to the Head of Operating Company/Group Function immediately for necessary action.

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