SCHEME OF SERVICES

&
CODE OF BUSINESS CONDUCT

CONFIDENTIAL
For the information of employees only
LIST OF CONTENTS

SCHEME OF SERVICES PAGE NO

PART A INTRODUCTION
Preamble 1
Our Intention 2
Our Vision 2
Our Mission 2
Our Value 2
Our Customer Value Proposition 2

PART B EMPLOYMENT

Article 1 Job /Position Classification 3

Article 2 Appointment 3
Article 3 Orientation Programmes 3
Article 4 Probation and Confirmation 4
Article 5 Performance Review 4
Article 6 Transfer 4
Article 7 Promotion 4
Article 8 Dedication 4
Article 9 Termination of Employment 5
Article 10 Retirement 5
Article 11 Employment of Relatives 5

PART C RULES AND REGULATIONS

Article 12 Working Hours 6
Article 13 Dress Code 6
Article 14 Absence from Work 6
Article 15 Grievances 6
Article 16 Discipline 7
Article 17 Disciplinary Procedure 7
Article 18 Employees on Suspension 8
Article 19 Misconduct 8

PART D COMPENSATION and BENEFITS

Article 20 Payment of Salary 11

Article 21 Pay Deductions 11
Article 22 Annual Increment & Bonus 11
Article 23 Overtime 11
Article 24 Annual Leave 11
Article 25 Pilgrimage Leave 12
Article 26 Gazetted Public Holidays 12
Article 27 Sick / Hospitalisation Leave 13
Article 28 Prolonged Illness 13
Article 29 Maternity Leave 13
Article 30 Special Leave 14
Article 29 Examination / Study Leave 14
Article 30 Medical Benefits 14
Article 31 Maternity Benefit 16
Article 32 Allowance & Claims 16
Article 33 Outstation Allowance/Claims 16
Article 34 Local / Overseas Travel 17
Article 37 Entertainment Claims 17
Article 38 Mileage Claims 18

CODE OF BUSINESS CONDUCT

Policy 19
Employee Obligations 19
Integrity of Business Practices 20
Personal Behaviour 20
Breach of Conduct 21

AMENDMENTS 21
PART A: INTRODUCTION

Preamble

Dear New Family Member,

I am pleased to welcome you into <Company>.

This Handbook is designed to introduce and guide you through the Companys Scheme of
Service and Code of Business Conduct. Whilst it serves as a communication medium from
the Company to all Employees, it will also serve as a reference to you. The Handbook will be
updated from time to time and the revisions shall be forwarded to you accordingly.

The success of our Company depends on your professionalism combined with great team
effort in order to provide the highest level of service needed in our industry.

Chief Executive Officer

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Our Intention
<Company Intention>

Our Vision.
<Company Vision>

Our Mission
<Company Mission>

Our Value
<Company Value>

2
PART B: EMPLOYMENT

1. Job/Position Classification

Job
Job Grade Position
Classification
Chief Executive Officer
SM1
Senior General Manager / Chief
SM 2
Managemen Operating Officer
SM 3
t Assistant General Manager
SM 4
Senior Manager
Managemen M1 Manager
t M2 Assistant Manager
E1 Senior Executive
Executives
E2 Executive
Clerical
Non- NE1
Despatch / Receptionist /
Executives NE2
Driver

2. Appointment

2.1 A new employee will be issued an appointment letter by the Management

before reporting for duty in their respective Departments.

2.2 The Company has the right to verify information provided in the Job
Application Form and any misrepresentation of facts shall warrant immediate
disciplinary action that includes termination of employment.

2.3 The Company reserves the right to request a new Employee to have a Medical
Examination conducted by an approved medical practitioner recommended
by the Company prior to employment. The offer of employment will be
subject to your medical examination report.

3. Orientation Programmes

Orientation Programmes have been designed to assist all new Employees to ensure
assimilation into the Company:-

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 3.1 General Orientation

The general orientation will be conducted by the HR Department for all new
Employees to ensure that they understand the Company's policies, benefits
and the structure of the Company

3.2 Departmental Orientation

The departmental orientation will be conducted by the respective Head of

Department to ensure that the new Employee fits into the department with
ease.

4. Probation and Confirmation

4.1 All Employees will initially undergo a probationary period as follows:

Job Classification Probationary Period

Senior Management
Management
Executive
Non-Executive

4.2 The probationary period will be extended for another period of not more
than the initial probationary period if the Employee's performance does not
meet the Company's expectation. During the probation period, an employee
will be required to undergo performance evaluation to determine the
employees performance level prior to being confirmed.

4.3 An Employee will be informed in writing by the Company, as to whether the

Employee has been confirmed in the employment or otherwise.

5. Performance Review

Aside from the Performance Review during the probationary period, all Employees
will undergo a Performance Review on annual basis. This review will take into
account all aspects relating to your job performance.

6. Transfer

An Employee is subject to transfer by the Company to another department,

subsidiary or associate company. The new posting could be in other states where the
Company has an office.

7. Promotion

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 It is the Company's policy to promote suitably qualified Employees from the lower
grades to higher grades as and when a vacancy arises. If no suitable candidates are
available, the Company reserves the right to recruit externally.

8. Dedication

Employees shall devote their entire time and attention to the service of the Company
and must not be engaged in any other business or occupation without the written
consent and approval of the Company.

9. Termination of Employment

9.1 Either party, otherwise stated, may terminate the contract of service by giving
to the other party the following notice in writing or payment in lieu thereof:-

Notice
Period Job Classification
Period
Sr. Management/
During Management
Probation Executive
Non-Executive
Sr. Management /
Upon Management
Confirmation Executive
Non-Executive

Note: No reason needs to be given for either party to terminate the

agreement.

9.2 An Employee upon resignation or termination of employment must return all

Company's property. Employees are required to reimburse the value of items
that are not returned. Final payment of any monies due to you will be made
after the return of all Companys properties.

10 Retirement

The normal retirement age of an Employee is sixty (60) years. However at the
discretion of the Management, an Employee can be offered an annual contract upon
reaching the retirement age.

11. Employment of Relatives

Employment of relatives is subject to the approval of the Company's Management.

PART C: RULES AND REGULATIONS

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12. Working Hours

12.1 The normal working hours shall be as follows:-

Mondays to Fridays : <Time> hours

Lunch : <Time> hours

Friday Lunch : <Time> hours

Note: Friday lunch hours are only applicable to all Muslim male Employees
who are performing Friday prayers.

12.2 Employees may have to work longer hours as may be required to complete
tasks falling within his ambit of work.

12.3 The Company may vary the standard office or lunch hours at its absolute
discretion.

13. Dress Code

13.1 All employees are required to use uniform as provided by the Company for
official site visits.

14. Absence from Work

14.1 Absence from work without leave or medical certificate will result in a written
warning and no pay for the day. Repeated offence of this nature may result in
disciplinary actions being taken.

14.2 Absence from work for more than 48 hours without any written prior
approval from the Departmental Head will be construed as abandonment
from work and self-termination of your employment contract.

15. Grievances

15.1 During your employment with this Company, there may be occasions when
you have grievances. If the grievances are left unresolved, these can seriously
affect the relations between you and your superior or colleagues and may
also affect your performance.

15.2 The Company believes that all grievances, however grave, can be solved
amicably. The following grievances procedures have been drawn up:-

Step 1: Consult your Head of Department immediately

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 Step 2: If not resolved to the satisfaction of both parties within one (1) week,
of
the matter shall be referred to the General Manager or CEO.

16. Discipline

All Employees are expected to maintain high degree of discipline at all times.
Employees are required to carry out their duties as directed by their Immediate
Superior.

16.1 Verbal Warning

The Head of Department may give an Employee a verbal warning for minor
breaches of discipline or failure to achieve satisfactory standards. A written
record of this will be made on the Employee's confidential file to prevent
future dispute on whether a verbal warning has been given or otherwise.

16.2 Written Warning

A written warning will be administered for offences which are serious or

when verbal warning has been insufficient.

If an Employee has two (2) written warnings, and a third incident or situation
occurs which is a violation of policies or rules, then he / she is required to
attend an inquiry which may lead to the disciplinary action stated below:-

1) Downgrade the Employee

2) Dismiss the Employee without notice
3) Impose any lesser punishment as the Company deems fit

17. Disciplinary Procedure

17.2 Head of Department will review the complaints received and to determine as
to gravity of the complaint whether it is a minor or major misconduct. HR
Department will be informed immediately if its a major misconduct.

17.3 Minor Misconduct

Head of Department shall issue a verbal warning and it is to be documented

and submitted to HR Department. If the Employee repeats the same
misconduct, he shall be issued a written warning. In the event that the
Employee repeats the misconduct after having received a second written
warning, such misconduct will be considered as a major misconduct.

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 17.4 Major Misconduct

HR Department shall conduct a preliminary investigation and will issue a

Show Cause Letter to the Employee. If deemed necessary, the Employee will
be suspended from work. HR Department shall give notice for Domestic
Inquiry if the reply is deemed unacceptable.

18. Employees on Suspension

Employees on suspension for the purpose of investigation shall be on half pay for a
period of not more than two weeks prior to a domestic inquiry. Should the Employee
be found innocent he/she shall be allowed to work again and the salary shall be
retroactive from the first day of his/her suspension date. However if he/she is found
guilty, he/she shall be paid until the day prior to the suspension plus 1/2 pay for the
period of suspension and subsequently disciplinary action shall be undertaken by the
Company.

19. Misconduct

19.1 Major Misconduct

Wilful insubordination or disobedience whether alone or in combination

with others, to any lawful and reasonable order of a superior or customer /
client of the Company
Thefts, frauds or dishonest practices, including attempted thefts, attempted
fraud or attempted dishonesty in connection with the Companys business or
property or that of the Companys client / customer
Gambling or card playing of any form, whether for money or not, within the
Companys premises at any time
Riotous or disorderly behaviour, or threatening to assault or to do any injury
to other Employees or Superiors, within the Companys premises at any time,
or to Companys clients / customers
Violence, abusing or assaulting other Employees, or superiors, within the
Companys premises at any time, or to Companys clients / customers
Habitual absence without leave; absence without leave for more than two
(2) consecutive working days. See section 15(2) of the Employment Act
1965.
Leaving workplace repeatedly during working hours without permission or
overstaying sanctioned leave without sufficient grounds or proper or
satisfying explanation or without informing or attempting to inform his
Company of the reason(s) for such absence, within the stipulated period.
Habitual late attendance

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 Taking or giving bribes or any illegal gratification
Striking at work or inciting others to strike in contravention of any law or rule
having the force of law
Habitual or substantial negligence of his duties
Smoking in non-smoking areas / places
Sleeping while on duty; claims of sickness not to be accepted as an excuse,
unless the sickness is of a serious and unexpected nature
Disclosing commercial or manufacturing secrets or calculations or designs or
any other information
Refusal to wear or use safety equipment provided by the Company
Any material misstatement made on the Application for Employment form
Habitual breach of any Company order or any law applicable to the
establishment of rules made there under
Disclosing confidential information without proper authorisation
Conviction an imprisonment for any criminal offence
Slackness in performance
Bringing alcoholic beverages within the Companys premises without prior
permission
Being found guilty of drug abuse or drug pushing
Drinking alcoholic beverages within the Companys premises without prior
permission
Stealing other Employees property within the Companys premises
Committing an immoral act within the Companys premises
Failure to report an infectious or contagious disease to the Company
Obtaining or attempting to obtain leave or absence through false reason(s)
Failure or refusal to submit to a search when required to do so by a Company
authorised searcher
Committing of any act subversive to the discipline of the Company or general
behaviour
Found drunk or under the influence of liquor whilst under duty
Interfering with the record of attendance or recording attendance of any
other absent Employee or falsification, defacement or destruction of any
record of the Company
Picketing in Companys premises except where permissible under law,
agreement or reward
Wilful failure to report at once to superior of any defect which an Employee
may notice in any equipment connected with his work
Spreading false or unpleasant information of the Company among
Employees and outsiders
Forging or defacing medical certificates or other official documents or
defrauding the Company
Participation in illegal strikes or abetting, inciting and instigating such
activities
Participating in any act or entering into any relationship that could adversely
affect the public image of the Company or that of other Company Employees
Vandalism and improper use of Companys facilities

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 19.2 Minor Misconduct

Absent without permission and without valid cause

Coming late for work
Any action contrary to Company or office procedures
Ceasing work before the proper finishing time without permission
Leaving the workplace, section or department without permission
Spitting within the Companys premises
Not taking proper care of tools, equipment, etc. entrusted to him / her
Not properly dressed and groomed for work
Not taking proper care of uniforms provided
Not keeping his / her machines and / or workplace clean and tidy
Careless use of public facilities / utilities
Excessive use of the telephone except for business calls
Not wearing uniforms provided by the Company while at work

PART D: COMPENSATION AND BENEFITS

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20. Payment of Salary

20.1 Employee's salaries will be paid on a monthly basis and all payments will be
made through a Bank designated by the Company.

21. Pay Deductions

21.1 The Company will make such pay deductions under the following
circumstances:-

21.1.1 Deductions authorised by written law such as EPF, SOCSO and Income
Tax.

21.1.2 Deduction for indemnity due, such as breaching a service contract or

not returning companys properties

21.1.3 Muslim employees have the option to have their zakat and/or Tabung
Haji savings deducted from their salary and you are required to
officially submit your requests to HR Department.

22. Annual Increment and Bonus

22.1 Annual increments and bonuses shall be variable award based on your
performance, prevailing market rate and also the Companys financial
standing. The eligibility for entitlement shall be Confirmed Employee with a
minimum of six-month service with the Company.

21.2 The annual bonus will be computed if any based on the Companys financial
year i.e. June 30 of every year.

23. Overtime

23.1 Employees who are governed by the provision of the Employment Act shall
be paid overtime if they are required to work in excess of the normal working
hours.

24. Annual Leave

24.1 All Employees are entitled to annual leave as follows:-

Years of Service All Job Grades

Up to 2 years service <No. of days> days
Between 2 to 5 years <No. of days> days

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 Over 5 years service <No. of days> days

24.2 The Company shall grant annual leave on the current year basis. Such leave
shall be calculated on a pro-rata basis from the date of joining till 31 st
December of the year.

24.3 If the Annual Leave is not applied prior to the actual taking of the leave, the
leave shall be considered as an Emergency Leave and be deducted from the
Annual Leave entitlement. However, the maximum allowed Emergency Leave
shall be 5 days in a year, otherwise it will be treated as absence with no pay.
In cases, of emergency leaves, Employees are requested to immediately
inform the Immediate Superior and seek prior approval. Failing which, it will
treated as absence without approval.

24.5 All Employees on probation will be entitled to apply for Annual Leave
according to pro-rata earned basis.

24.6 Annual Leave must be applied on the prescribed 5 days prior to the intended
leave period. Any leave application with less than 5 days notice shall be
considered as Emergency Leave. All annual leave must be approved before
the Employees commence the leave.

25. Pilgrimage Leave

25.1 All employees may opt to carry forward their annual leave up to maximum of
60 days and convert to Pilgrimage Leave for religious purpose as such:

Muslims - Haj/Umrah
Christians Jerusalem/Lourdes
Hindus Kasi / Rameswarm
Any other religious event

25.2 Employees opting for clause 25.1 must firstly apply and submit the
registration with travel plan and other supporting documents to Management
for approval

25.3 Any unutilized converted pilgrimage leave cannot be convert into cash
benefit.

26. Gazetted Public Holidays

26.1 Employees shall be granted all the gazetted public holidays for the state which
the Employee is stationed.

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27. Sick / Hospitalisation Leave

27.1 All Employees is entitled to paid Sick Leave as follows:

Years of Service All Job Grades

2 years and below 14 days
Between 2 to 5 years 18 days

Over 5 years service 20 days

27.2 All Employees with paid sick leave shall produce the medical certification
from an Approved Medical Practitioner or by a Government Medical Officer.

27.3 If hospitalisation is necessary, an Employee shall be entitled to sixty (60)

working days per calendar year which is exclusive of the sick leave
entitlement.

27.4 Your Departmental Head must be informed of sick leave, as failure to do so

within forty-eight (48) hours will be treated as absence without leave. All
medical certificates must be handed to your Departmental Head for
endorsement upon returning to work.

28. Prolonged Illness

28.1 Employees who are diagnosed with prolonged illness are entitled to full pay
for the first three months and half pay for the subsequent three months.

28.2 Subsequent to the six months, the Employee shall then receive a no pay leave
for a further three months. Thereafter, if the Employee is still certified not fit
to work, the Company would then reserve the right to terminate the
employment.

29. Maternity Leave

29.1 All female Employees shall be entitled to sixty (60) consecutive days paid
maternity leave for up to five surviving children

29.2 Leave on account of miscarriage, abortive measures/premature birth

occurring during the first twenty-two (22) weeks pregnancy shall be
considered as normal sick leave. Maternity leave shall be granted after the
twenty-two (22) upon certification by a doctor.

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 29.3 Female Employees shall give 30 days notification, as possible, for their
intention to proceed on maternity leave in order to enable the Company to
make provisions for their absence from work.

30. Special Leave

30.1 All Employees are granted special leave with pay as stated below:-

Congratulatory Leave
First legal Marriage of an Employee - 3 days
Birth of an Employee's legal child - 2 days

Compassionate Leave
Death of immediate parents, spouse, - 3 days
brother or sister and child of an Employee

30.2 Employee shall be required to obtain the approval before or when taking such
leave. The Employee shall forward documentary evidence in support of his
application for such leave.

31. Examination / Study Leave

31.1 Employees who are with the Company for at least one (1) complete year will
be eligible for consideration.

31.2 The course must be related to his/her job and in line with the Company's
continuing Professional Development Program. It should be in the form of
Diploma, Degree or Professional Course.

31.3 The entitlement is 1 day for every exam day with a maximum of 10 days per
annum and documents pertaining to examination must be forwarded for
approval.

31.4 Employee pursuing degrees, MBA or similar professional qualification who

needs more than 10 days entitlement specified in item 30.3 may opt to apply
to convert their unutilized annual leave into additional examination/ study
leave. The application must be submitted with full counsel program details.

32. Medical Benefits

32.1 Employees are eligible to claim for treatment sought from registered medical
practitioner.

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 Job Classification Maximum Per Annum
Senior Management RM <Amount>
Management RM <Amount>
Executive RM <Amount>
Non-Executive RM <Amount>

32.2 This medical benefit will also be extended to the Employees spouses and their
children under the age of 18. The limit of coverage is within the quantum
specified in item 33.1.

32.4 The Company shall not be liable for:-

a) Spectacles, lenses, optical fees;

b) Expenses incurred as a result of pregnancy, confinement, self-inflicted
injuries, illness or diseases arising from misconduct or exposure to any
unjustifiable hazard;
c) Expenses incurred as a result of attempted suicide, or injury arising from
the performance of an unlawful act, provoked assault or breach of the
peace, or under the influence of illegal drugs / alcohol;
d) Expenses incurred for the treatment of venereal diseases or drugs
addiction.

32.5 The coverage for this medical benefit is meant for clinical and outpatient
treatment only.

32.6 Medical Coverage and Insurance

Employees are entitled to the Companys insurance plans as follows:

Group
Hospitalisati Group
Job Grade on and Personal Group Term Life
Surgical Accident
(Room)*
SM1
SM2
SM3 & SM4
M1 & M2
E1 & E2
NE1 & NE2

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 33.8 A detailed benefit schedule will be forwarded for your records. The detail
coverage may change in accordance to the terms and conditions specified by
the Insurance Company. The hospitalisation and surgical coverage will also be
extended to the Employees spouses and children under the age of 18 years
old.

34. Maternity Benefit

34.1 All Employees are eligible to claim for maternity benefit of RM1, 500.00 per
child upon submission of a copy of the birth certificate of the child.

34.2 The entitlement is limited to a maximum of 5 children

36. Allowance & Claims

36.1 The entitlement for allowance shall be as follow:

Job Grade Allowance

SM1
SM2
SM3
Sm4
M1
M2
E1 and E2
NE1 and NE2

37. Outstation Allowance / Claims

39.1 Employees who are required to travel outstation for business purposes and
required to stay overnight are entitled to the following:-

Meal Allowance Lodging

Job
Classification Without
Overnight With Receipt
Receipt
Senior
Management
Executive and
Non-Executive

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38. Local / Overseas Travel

40.1 The Company shall make the travel and lodging arrangements for Employees
who are required to travel local and overseas for official business reason.
Entitlement as listed below:

Local Overseas
Job
Grade Accommodation Travel Accommodation Travel

SM1 and
SM2
SM3 and
SM4
M1 and
M2
E1 and
E2
NE1 and
NE2

40.2 All employees who are required to travel overseas must submit the Travel
requisition form for approval before making travel arrangements.

39. Entertainment Claims

39.1 The entitlement for entertainment expenses for the sole purpose of carrying
out your duties shall be as follows:

Job Grade Limit Per Month

SM1 RM <Amount>
SM2 RM <Amount>
SM3 and SM4 RM <Amount>
M1 RM <Amount>
M2 RM <Amount>
E1 and E2 RM <Amount>

39.2 On the event if the entertainment expenses exceed the limit stated above, the
Employee concerned should get the consent of his/her superior prior to the
event when the expense will be incurred.

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 39.3 On the event if there be any entertainment claim that needs to be incurred
for those not covered under the schedule stated, the Employee concerned
should get the consent of his/her superior prior to the event and submit
claims to Finance department.

40. Mileage Claims

42.1 Employee who are authorised / permitted to use own vehicle on official duty
shall be eligible to claim mileage reimbursement as follows;

Transport Type Per km

Motorcar <Amount> cents
Motorcycle <Amount> cents

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CODE OF BUSINESS CONDUCT

Policy

Company is committed to the highest standards of ethical business conduct. This Code of
Conduct is binding on all Employees, whose actions must always be such as to avoid any
impropriety. In addition, the Company and its Employees are subject to the Laws of
Malaysia in every respect.

Company will deal only with those organisations having ethical standards compatible with its
own declared policy. Company will report promptly to the appropriate authorities whenever
it knows or is informed by a reliable source, that a client, supplier, subcontractor or other
participant (including Employees) in a project of Company is acting illegally or unethically.
Employees found to be in breach of these ethical guidelines also will be subject to Company
disciplinary action.

Employees who have any doubts on the appropriate course of action involving matters of
business ethics should consult a Director of the Company.

To ensure that all Employees are aware of their ethical obligations, a copy of this Code is
provided to all new staff which is to be read and, when fully understood, acknowledged by
the Employee by signing the attached sheet.

Employee Obligations

Staff members are expected to give their best efforts at all times so as to provide our clients
with quality service and products. This obligation extends to the protection of the physical
and intellectual assets of Company and its client(s). Accordingly, Employees:

Shall keep confidential all proprietary information of Company and its client(s), which
includes commercial and human resource data, design and intellectual property of all
forms;

Shall not speak to the media or publish anything about Company or client business
unless authorised;

Have a duty to inform the Directors about breaches of the law and safety matters as
soon as they become aware of them; and where the concerns raised are not answered
by the company, are free to communicate these concerns to an appropriate government
agency. Whenever an agency of government conducts an investigation, Employees
should cooperate fully;

Must use the resources of Company and its client(s) only for relevant business purposes.
This applies both to physical (e.g. materials) and non-physical resources (e.g. software,
intellectual property, etc.);

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 Shall keep accurate and sufficient records organised in a manner so as to inform fairly
and honestly those who receive (or have use for) the information, in the conduct of
Company business or that of its client(s)

Integrity of Business Practices

Employees of Company have the obligation to inform their senior management as soon as
they become aware of practices or circumstances which may involve them in unethical
conduct or conflict of interest. This obligation applies when dealing with internal or external
parties. In doing business with any organisation the following standards apply:

Employees must deal fairly and equitably with their colleagues and external contacts.

Employees must not misrepresent themselves or Company to anyone. If a

misunderstanding occurs, immediate clarification should be made once this becomes
evident.

Employees must not engage in any collusive practices which may lead to a client of
Company receiving less than a fair and competitive service.

Unauthorised copying or use of software and other data or documentation can result in
criminal liabilities. The improper use of such proprietary information is strictly
forbidden.

Gifts and entertainment shall not be offered or accepted where there is any obligation
incurred or such offer or acceptance can be construed as a bribe. The provisions of the
Prevention of Bribery Ordinance shall apply in all respects. In this regard the acceptance
of souvenirs, advertising and promotional items of nominal value only is permitted.
Items of more substantial value should be declined or recorded and disposed of in
accordance with stated company procedures.

Entertainment in the form of customary business amenities such as meals with

associated drinks may be accepted or offered provided it is not unduly lavish or frequent.

Company will meet all reasonable expenses associated with your travel, food and
accommodation on company recognised business. Such arrangements should not be
accepted from suppliers unless at the suppliers facilities or otherwise unavailable
through normal commercial sources.

Personal Behaviour

The personal behaviour of Employees shall reflect the ethical standards of Company and
respect the rights of the Company and its client(s). An Employee who conducts a
transaction outside the Company at the expense of the Company or its Clients shall be
deemed to have created a Conflict of Interest between him/her and the Company.

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The criteria to determine the Conflict of Interest shall be your job, the form and amount of
external investment and the external companys structure and involvement with Company
and how this influences your actions as a Company Employee. In particular:
Your external personal activities must not give rise to real or perceived conflicts of
interest. Should any such occasion arise you must declare any interest openly and
abstain from the decision making process.

Employees must not perform services in competition with the Company either alone or
in conjunction with another company or person without the prior consent of the
Company.

You must not use inside information, confidential material or non-public information for
your own financial benefit either directly or indirectly. In addition to being a violation of
law, it will be grounds for instant dismissal.

You may not perform external work or solicit non-Company business on company
premises or within the company time nor may you use company or client resources for
external work.

You must not use your association with Company or its client(s) to sponsor, endorse or
advance the interests of another organisation except where you have the prior written
consent of a Director.

Employees must not accept or offer money, any other benefit, and advantage in the
performance of their duties other than as part of a recognised commission or payment
scheme which is available to all suppliers or providers.

Staff shall refrain from borrowing and lending money to clients, suppliers or contractors
of Company.

Breach of Conduct

The Company recognised that a breach of ethical business behaviour may result in its
removal from the list of suppliers of goods and services. Accordingly, the Company will
regard any breach of these ethical guidelines by Employees in the most serious light and
implement immediate disciplinary action or dismissal.

AMENDMENTS

The Policies, Rules and Regulations contained in this Handbook may be amended from time
to time and they will be conveyed to you via company memorandum.

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Employees are also subjected to all the statutory legislations at time being in force where
otherwise any terms and conditions of service are not mentioned in this Handbook.

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