Contractor & temporary worker Handbook

APAC
1. Need to know – Spencer Ogden Temporary and Contractor Essentials pg. 3
1.1 Who should I contact if I have a query about an up and coming assignment? Pg. 3
1.2 Does Spencer Ogden have standards and protocols that I need to follow? Pg. 3
1.3 Do I need to provide Spencer Ogden with any documents? Pg. 3
1.4 What is the process for making a leave request while on assignment? Pg. 3
2. Need to know – money matters pg. 4
2.1 How will my pay rates be decided? Pg. 4
2.2 What do I need to know about completing manual timesheets? Pg. 4
2.3 When do I have to submit my timesheet? Pg. 4
2.4 How and when will I receive payments if I’m a temporary worker? Pg. 5
2.5 How and when will I receive payments if I’m a contractor? Pg. 5
2.6 Can I obtain an advance on my salary / payment? Pg. 5
2.7 Why has there been a delay in my salary / payment? Pg. 5
2.8 How can I claim expenses? Pg. 5
2.9 When will I receive my bonus payment if I am entitled to one? Pg. 5
3. Contractor & temporary worker Health, Safety & environment Policy Pg. 6
3.1 Objectives Pg. 6
3.2 Applicability Pg. 6
3.3 Responsibilities Pg. 6
3.4 Health, Safety & Environment Pg. 6
3.5 Reporting of injuries Pg. 7
3.6 List of specific health and safety duties when working on site Pg. 7
3.7 Guidance Note Pg. 8
3.8 Precedence Pg. 8
3.9 Declaration Pg. 8
4. anti-bribery & corruption Policy Pg. 9
4.1 What is bribery? Pg. 9
4.2 What is not acceptable? Pg. 9
4.3 Facilitation payments & kickbacks Pg. 9
4.4 Gifts and hospitality Pg. 10
4.5 Your responsibilities Pg. 10
4.6 How to raise a concern Pg. 10
4.7 Declaration Pg. 10
5. sanctions Policy PG. 11
5.1 Consequence of failing to comply with sanctions Pg. 11
5.2 Sanctions policy & declaration Pg. 11
5.3 Sanctioned countries Pg. 11
5.4 Approved countries Pg. 12

6. Data Protection Statement PG. 13

7. Contractor & temporary worker Handbook declaration PG. 13

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Welcome
Welcome to Spencer Ogden, one of the world’s leading energy recruiters. Spencer Ogden is committed to providing you with a
rewarding, safe and satisfying work experience. This Contractor & Temporary Worker Handbook has been designed to provide
you with useful information that you will need to know when you are on assignment with Spencer Ogden, as well as setting out
some key standards and policies that Spencer Ogden expects you to adhere to. Should you have any queries about the information
in this handbook please do not hesitate to contact your Recruitment Consultant.

1. Need to know – Contractor & Temporary worker Essentials

1.1 who should I contact if I have a query about an upcoming assignment?
Your Recruitment Consultant will brief you on each assignment prior to commencement. If you have any queries, feel free
to raise these with your Recruitment Consultant.

1.2 Does Spencer Ogden have standards and protocols that I need to follow?
Yes, Spencer Ogden is focused on excellence and committed to fostering high levels of professionalism, so before you
start an assignment it is important you familiarize yourself with our standards and protocols.
- Spencer Ogden expects you to respect the rights of others and to treat them fairly. Harassment of any kind is not
acceptable and could result in the termination of an assignment. Similarly, should you find yourself in an
uncomfortable situation, do not hesitate to contact your Recruitment Consultant.
- When you enter different work environments, you may be exposed to confidential or sensitive information whether
work-related or personal. Please ensure you keep all information confidential, even once your assignment has
finished, as failing to do so will put you in breach of your contract with Spencer Ogden and its Clients.
- When accessing a client’s computer network which includes e-mail, intranet, the internet and various software
programs, remember they must be used for business purposes only and that confidentiality of passwords and
information is paramount. Use of any systems for personal use or for accessing offensive and/or obscene content
is unacceptable and may result in the termination of your assignment and other possible serious consequences.
- Except in the case of an emergency, please make personal phone calls only during breaks. Leave hand phones off or
on silent during work hours.
- Please ensure you read and follow the specific policies enclosed in this handbook and also be aware that you may be
required to sign the client’s separate Confidentiality Agreement, HSE Policy documents and other such documents
that may be required by the client on a case by case basis.
Permanent opportunities often develop from contract or temporary assignments, so if you encounter any difficulties
whilst on assignment (or have a complaint) please address it with your Recruitment Consultant immediately rather than
approaching the client.

1.3 Do I need to provide Spencer Ogden with any documents?

Yes, as a leading energy recruitment company, Spencer Ogden must ensure that the workers it supplies to its clients are
who they say they are, are entitled to work in the country they will be working in and have the necessary skills and
qualifications to carry out the work. Your Recruitment Consultant will advise you of the specific documents that Spencer
Ogden will require from you to evidence the above. Additionally, if you are an independent contractor working through
your own company, you must supply Spencer Ogden with your incorporation certificate, GST registration (or equivalent),
insurance documents and evidence of your right to work where the Services are to be delivered before Spencer Ogden
issues your contract and before you start work.

1.4 What is the process for making a leave request while on assignment?
Annual leave should be agreed between yourself and the client, with your Recruitment Consultant fully informed before
leave is taken. This will ensure cover is available whilst you are away. If you intend to take medical or sick leave, then
we ask you to notify the client and / or your Recruitment Consultant us as early as possible before you are due to start
work. If that is not possible, you must notify the client and / or your Recruitment Consultant as early as possible after
that time. A leave request form must also be completed and signed by the client, along with a medical certificate.

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2. Need to know – Money Matters
2.1 How will my pay rates be decided?
Your pay rate will be given by your consultant prior to the beginning of each assignment.

2.2 What do I need to know about completing manual timesheets?

Your timesheet must be properly completed with a full record of the time you have worked and be signed by your direct
manager and / or any other client-specified personnel. If your timesheet is not signed, it will not be processed. Please
submit your timesheet to - apacpaybill@spencer-ogden.com. If you have expenses due to you, please submit your
endorsed Expense Claim form along with any related receipts. Like your timesheet, your expenses will not be processed
without the signature of your manager or any other client-specified personnel.

2.3 When do I have to submit my timesheet?

You will need to submit your timesheet to Spencer Ogden by 12pm on the last Friday of each month. Your timesheet must
be submitted within 30 days of each work period. You will receive your pay within 7 working days of this submission.
Please be wary of public holidays. As all of our contractors have the same cut-off time for timesheets, please ensure you
get your documents in long before cut-off to avoid missing the deadline.
timesheet Submission
- Please ensure that the time sheet is signed and you are to provide with supporting document if necessary (eg.
receipts, claims).
- When submitting the time sheet, please cc your consultant in your email.
- For contractors working through a Management Company, kindly submit the time sheet to the respective
management company contracted with you.
- For direct contractors, kindly submit the time sheet to the following address:
- Submission of Time Sheet – apacpaybill@spencer-ogden.com
*Any incomplete timesheet will result in a delay in your salary payment. Refer to 2.3.
Submission before cut off time
- For contractors working through a Management Company, you are to submit your time sheet to the Management
Company by the end of the month, at least one working day before the payroll cutoff date. Your time sheet will
be processed on the following day after the payroll cutoff date. (Please refer to the payroll schedule for the cutoff
dates)
- For direct contractors, you are to submit your time sheet to Spencer Ogden by the given payroll cutoff date, before
12 noon. Your time sheet will then be processed on the following day after the payroll cutoff date. (Please refer
to the payroll schedule for the cutoff dates.
- Once the time sheet is processed, Spencer Ogden will release the payment to the Management Company/ Direct
Contractors on D+2 working days. (eg. If your time sheet is processed on a Tuesday, payment will be release on
the following Thursday)
- For contractors working through a Management Company, do expect an extra day for the Management Company
to re-route the funds to you.
Note: The date on actual monies received are subject to the beneficiary bank’s clearance.
Submission after cut off time
- Time sheet received after the above mentioned cutoff timing will NOT be processed on the following day after
the payroll cutoff date. Instead, it will be re-scheduled to the following payroll schedule.
- Once the time sheet is processed, Spencer Ogden will release the payment to the Management Company/ Direct
Contractors on D+2 working days. (eg. If your time sheet is processed on a Tuesday, payment will be released on
the following Thursday)
- For contractors working through a Management Company, do expect an extra day for the Management Company
to re-route the funds to you.
Note: The date on actual monies received are subjected to the beneficiary bank’s clearance.

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2.4 How and when will I receive payments if I am a temporary worker?
Payment will be made via electronic funds transfer into your bank account. Payment will be processed on the Tuesday
following the week of work. Depending on your bank, all funds will be received within 7 working days. Payment in 7
working days will not be guaranteed if your timesheet is received after the cut-off deadline (12pm on the Friday of the
week worked). Note that no post-payment / advance payment I is allowed, salaries will be processed based on time
worked, acknowledged by the authorized manager-in-charge. Finance will not process timesheets without a signature
from the client. Any information deemed improper on the timesheets by Finance during processing may result in a delay
in payment.

2.4 How and when will I receive payments if I am a contractor?

Payment will be made by electronic funds transfer into your bank account. Unless advised otherwise, your monthly
timesheet must be in by 12pm on the last Friday of the month worked and you will receive the funds within 7 working
days. Payment will be processed on the Tuesday following the week of work. Depending on your bank, all funds should
appear by the following Friday. Payment on Friday will not be guaranteed if your timesheet is received after the cut-off
deadline (12pm on the Friday of the week worked).

2.5 Can I obtain an advance on my salary / payment?

No, Spencer Ogden does not provide salary / payment advances.

2.6 why has There been a delay in my salary / payment?

The most frequent reasons for a delay in payment are because a time sheet has been submitted after the cut off time,
the time sheet is incomplete, the time sheet has not been signed or the right documents or bank details have not been
provided. Typically, the most common reasons why any document will have been rejected will be because the
contractor or temporary worker did not ensure that documents requiring signatures have been signed or signed correctly
or signed by the correct authorized personnel, or where receipts or other necessary supporting documents have not been
provided or where there is incomplete information on documents. For contractors working through a Management
Company, you may want to contact the management company directly if you think you might have indicated the wrong
account number. The contact details are indicated in your on-boarding email. For direct contractors, if you have any
queries pertaining to payroll please email: apacpaybill@spencer-ogden.com

2.7 How can I claim expenses?

All expenses must be approved by the client prior to incurring the expense, and prior to payment being made. The expense
claim document provided is to be completed with the relevant receipts attached upon submission. Expense claim
reimbursements are made at the same time as your monthly or weekly pay. Should expenses be received after 12pm
Friday, then they will be paid the following month. Claims made without a valid receipt will be held until one is provided.

2.8 When will I receive my bonus payment if I am entitled to one?

Should a bonus payment be part of your contractual agreement, then this will only be paid following signed authorization
from the client. This is usually done at the end of your contract period if not already agreed.

2.9 Is there an email or number I can call if I have a query about money matters?
Yes, if you have any queries, contact your Recruitment Consultant directly or alternatively email: apacpaybill@spencer-
ogden.com. The apacpaybill@spencer-ogden.com address can be used for queries regarding your EP (if applicable),
taxation, expense claims, annual leave or medical leave entitlements and your pay. Advise us if there are any changes to
your address, telephone number or bank account details to ensure you receive your pay and pay slips.

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3. Contractor & temporary worker Health, Safety & environment Policy
This Health, Safety & Environment Policy of Spencer Ogden Pte Ltd and Spencer Ogden Consulting Sdn Bhd (hereinafter
referred to as “Spencer Ogden”) aims to comply with the Work Place Safety & Health Policy Standards set by the Ministry
of Manpower and endeavours to ensure a safe, injury and illness free workplace for our workers. A copy of this Health,
Safety & Environment Policy is available for all of our contractors, temporary workers and employees working on client
sites.

3.1 Objectives
The objectives of this Health, Safety & Environment Policy are:
- to demonstrate the commitment of Spencer Ogden’s management towards its workers’ health, safety and the
environment (including its contractors, temporary workers and employees);
- to ensure no damage to the environment
- to remove or minimise risk to the health, safety and welfare of all workers, contractors and any third parties
involved in our business operations;
- to ensure all work activities are completed safely with; and
- to reduce individual’s behaviour that could result in injury, inefficiency and/or damage to property

3.2 applicability
This Health, Safety & Environment Policy applies to all of Spencer Ogden’s contractors, temporary workers and employees
working on client sites. The authorization and responsibility for enforcement has been given primarily to the undersigned
personnel. It is Spencer Ogden’s policy that accident prevention be a prime concern of all contractors, temporary workers
and employees working on client premises.

3.3 responsibilities
As Spencer Ogden’s contractor, temporary worker or employee working on client premises, you acknowledge and warrant
that YOU:
- will adhere to the client’s in-house safety guidelines throughout your Assignment and maintain a safe working
environment for yourself and others at the clients’ premises;
- have been informed and trained adequately prior to on-boarding and you shall follow safe work practices, adhering
to the Work Health and Safety Act of where the Services are to be delivered and/or other applicable QEHS policies
in the country of work at all times;
- shall ensure you attend any applicable safety presentations given by any client representative;
- shall make appropriate recommendations to the client’s safety officer (or authorized personnel) as and when you
see areas for improvement or notice work hazards to minimize harm to yourself and/or others;
- shall carry out your duty as per appropriate safety policy established by the client and/or any specific instructions
for maintaining effective accident prevention within your area of responsibility;
- have been provided with sufficient information, instruction, training and supervision needed to make sure that all
reasonable efforts are used to protect yourself to be safe from injury and risks to your health;
- are committed to consulting and co-operating with the client’s safety officer/ authorized personnel in all matters
relating to health and safety in the workplace;
- will wear industry-approved standard of personal protective equipment and clothing where required;
- shall not misuse or interfere with anything provided for health and safety;
- shall report all known or observed hazards to the client’s safety officer/ authorized personnel;
- must observe the client's fire safety procedures at all times;
- are obligated to stop the work if you find that you or your work duties re placing yourself or others at risk. You
should also inform Spencer Ogden and the client’s safety officer/ authorized personnel immediately if you judge
that there is a risk where you or other workers are working; and
- are committed to continually improve your performance through effective safety management.

3.4 Health, Safety & Environment

You are responsible for:
- complying with all relevant environmental and WHS laws, policies and regulations;
- using care in handling hazardous materials or operating processes or equipment that use hazardous materials to
prevent unplanned releases into the workplace or the environment; and
- reporting to the client’s safety officer or authorized personnel on all spills of hazardous materials; any concern that
client’s products are unsafe; and any potential violation of environmental, health or safety laws, regulations or
company practices or requests to violate HSE procedures.

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3.5 reporting of injuries
You must ensure that all accidents are reported to the client’s safety officer (or authorized personnel) and Spencer Ogden
on the same day of the occurrence. You should fill out a “Notice of Injury Form" immediately after an injury occurs, even
if medical treatment is not required. (Notice must be made at or near the time of the injury and on the same day of the
injury.) You must report the injury to the client’s safety officer or authorised personnel. A casual mentioning of the injury
will not be sufficient. You must let Spencer Ogden and the client’s safety officer or authorised personnel know:
- how you were injured;
- what you were doing at the time;
- who you were working with at the time;
- when and where it happened; and
- other pertinent information that will aid in the investigation of the incident.
Failure to report an injury immediately (meaning at or near the time of the injury and on the same day of the injury) is a
violation of this Health, Safety & Environment Policy.

3.6 LIST OF SPECIFIC HEALTH AND SAFETY DUTIES WHEN WORKING ONSITE:
As Spencer Ogden’s contractor, temporary worker or employee working on client premises, you must observe the
following:
- Ensure that all equipment, stationeries and substances are placed in a safe condition.
- Hard hats will be worn on the project site at all times. The bill of the hard hat will be worn in front at all times.
Alterations or modifications of the hat or liner are prohibited. Crane operators, when in an enclosed cab, have
the option of not wearing a hard hat due to the possible obstruction of view.
- Safety glasses will be worn as the minimum-required eye protection at all times before performing any manual
task. Additional eye and face protection such as mono-goggles and face shields are required for such operations
as grinding, jack hammering, utilizing compressed air or handling chemicals, acids and caustics. Burning goggles
for cutting, burning or brazing and welding hoods for welding, etc., are required.
- Fall Protection Requirements:
• Full body harnesses and lanyards shall be worn and secured any time there is a fall hazard of more than six
(6) feet.
• Lifelines shall be erected to provide fall protection in each relevant work location. Horizontal lifelines shall be
a minimum of 2-inch diameter wire rope. Vertical lifelines shall be 3/4 inch manila rope or equivalent and
shall be used in conjunction with an approved rope grab.
• Structural steel erectors are required to "hook up" with full body harness and lanyard.
• Employees using lanyard to access the work or position themselves on a wall or column, etc., must use an
additional safety lanyard for fall protection.
- Manlifts must be used properly. As soon as a worker enters an articulating boom lift and before the lift is started,
the worker must put on the harness and attach the lanyard to the lift.
- Clothing must provide adequate protection to the body. Shirts with sleeves and long pants will be worn at all
times. No shorts are to be worn on projects. All employees, except welders and burners, must tuck shirt tails
inside trousers. Burners and welders will not be permitted to wear polyester or nylon clothing. Sturdy work boots
with rigid, slip resistant soles are required. No clogs, tennis shoes or loafers are permitted.
- All personnel will be required to attend safety meetings as stipulated by project requirements in order to meet
workplace safety standards.
- Firearms, alcoholic beverages or illegal drugs are not allowed on company or client’s property or in client or
Company vehicles at any time. When drugs are prescribed by a physician, the client’s safety officer / authorised
personnel must be informed. The use or possession of illegal drugs or alcoholic beverages on the jobsite will result
in immediate termination.
- Housekeeping shall be an integral part of every job. Each contractor, temporary worker or employee is responsible
for keeping his work area clean and hazard-free. Clean up is required at the end of the day.
- Burning and cutting equipment shall be checked daily before being used.
- Drinking water containers are to be used for drinking water and ice only.
- Defective tools will not be used. Examples of defective tools include chisels with mushroomed heads, hammers
with loose or split handles, guards missing on saws or grinders, etc.
- All extension cords, drop cords, and electrical tools shall be checked, properly grounded with ground fault
interrupters (GFI’s), and color-coded. This shall be part of the assured grounding program. Cords and equipment
that do not meet requirements shall be immediately tagged and removed from service until repairs have been
made.
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 - ”Horseplay" on the jobsite is prohibited. Running on the jobsite is allowed only in extreme emergencies.
- No contractor, temporary worker or employees is allowed to drive any vehicle without a valid driving license
and/or sufficient automobile insurance. No worker is permitted to ride in the bed of a truck standing up or sitting
on the outside edges of a truck. Workers must be sitting down inside the truck or truck bed when the vehicle is in
motion. Riding as a passenger on equipment is prohibited unless the equipment has the safe capacity for
transporting personnel.
- Adequate precautions must be taken to protect workers and equipment from hot work such as welding or
burning. Fire extinguishers shall be no further than 50 feet away from all hot work. Used fire extinguishers must
be returned to be recharged immediately. Use of welding blinds is required in high traffic areas.
- All scaffolding and work platforms must be built and maintained in accordance with Clients’ HSE specifications.
All ladders must be in safe condition without broken rungs or split side rails. Damaged ladders shall be removed
from service. Ladders shall be secured at the top and bottom and extend three (3) feet past the working surface.
Metal ladders around electrical work are prohibited. A step ladder shall never be used as an extension ladder. A
step ladder must only be used when fully opened with braces locked.
- Report all unsafe conditions and near accidents to client’s safety officer or authorised personnel so corrective
action can be taken.
- All floor openings or excavations shall be barricaded on all sides to ensure workers are aware of the hazards. Floor
holes shall be covered, with the covers secured and clearly marked.
- Warning signs, barricades, and tags will be used to the fullest extent and shall be obeyed.
- It is understood that the Client/ Company is not restricting itself to the above rules and regulations. Additional
rules and regulations as dictated by the job will be issued and posted as needed.

3.7. For Any Work assignment in Japan

You are required to read the information in this link http://www.jaf.or.jp/e/for-overseas-drivers/driving-in-japan.htm
and raise any questions to us immediately after having done so.

3.8. Guidance Note

As Spencer Ogden’s contractor, temporary worker or employee working on client premises, you must ensure that you
fully understand the importance of compliance with these Guidance Notes when on a Client's site and/or Client’s facility.
Your commitment to following the guidance outlined herein is a precondition of Spencer Ogden offering employment
and your failure to follow the important advice set out in the “HSE Guidance Note” may, the event of any injury, very
likely mean you will as a result be fully at fault or contributory negligent in causing that injury. Spencer Ogden’s HSE
Guidance Note is available for review on Spencer Ogden’s on-boarding package that will be send to you as another file.

3.9. precedence
Spencer Ogden’s full and extensive Health, Safety & Environment Management System is available for review on Spencer
Ogden’s website: www.Spencer-Ogden.com (copy available on request). This Health, Safety & Environment Policy
operates in conjunction with any applicable parts of that Health, Safety & Environment Management System. This Health,
Safety & Environment Policy further operates in conjunction with but is ultimately superseded by any equivalent client
Health, Safety & Environment Policy relevant to the work and / or the premises the contractor, temporary worker or
employee is working on. You will adhere to this Health, Safety & Environment Policy, relevant provisions of Spencer
Ogden’s Health, Safety & Environment Management System and the client’s applicable Health, Safety & Environment
Policy throughout your Assignment so as to ensure a safe working environment for all at the clients’ premises.

3.10. declaration
As a pre-condition of Spencer Ogden accepting you to work on the assignment, and by signing and acknowledging this
handbook, you hereby declare that you understand, are fully aware of and will comply with this Contractor & Temporary
Worker Health, Safety & Environment Policy, any applicable parts of Spencer Ogden’s full and extensive Health, Safety &
Environment Management Policy and any specific client Health, Safety & Environment Policy relevant to the work and /
or the premises that you are working on and that you will fully comply with the Client’s Health, Safety & Environment
rules and regulations at all times.

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4. Anti-bribery & corruption Policy
Spencer Ogden takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly
and with integrity in all its business dealings and relationships wherever it operates. It is the policy of Spencer Ogden,
including its subsidiaries and associated companies, to conduct all of its business in an honest and ethical manner to this
end has implemented and will enforce effective systems to counter bribery.
Spencer Ogden will uphold all relevant legislation to counter bribery and corruption in all the jurisdictions in which it
operates. However, as a United Kingdom headquartered company we remain bound by the laws of the UK and elsewhere,
including the Bribery Act 2010, in respect of our conduct both at home and abroad. Bribery and corruption are punishable
for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an
unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our
legal responsibilities seriously.

4.1 what is bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory
or personal advantage.

4.2 what is not acceptable?

It is not acceptable for you (or someone on your behalf) to:
- give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage
will be received, or to reward a business advantage already given;
- give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to
“facilitate” or expedite a routine procedure;
- accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a
business advantage for them;
- accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an
expectation that a business advantage will be provided by us in return;
- threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised
concerns under this policy; or
- engage in any activity that might lead to a breach of this policy.
For the avoidance of doubt, Spencer Ogden conducts its business to the highest standards and upholds all relevant
legislation to counter bribery and corruption in the jurisdictions in which it operates. To this end you confirm to Spencer
Ogden that you will not offer, give or agree to give any gift or other consideration to any employee or other representative
of Spencer Ogden or any other person, which could be perceived as an inducement or a reward for any act or failure to
act connected to the award or performance of any agreement.

4.3 facilitation payments and kickbacks

Spencer Ogden does not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments
are typically small, unofficial payments made to secure or expedite a routine government action by a government official,
such as speeding up a visa or license application. If you are asked to make a payment on our behalf, you should always be
mindful of what the payment is for and whether the amount requested disproportionate to the goods or services provided.
If you have any suspicions, concerns or queries regarding the payment, you should raise them with your Recruitment
Consultant. Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid
any activity that might lead to a suggestion that a kickback payment will be made or accepted by Spencer Ogden.
You will not enter into an agreement with Spencer Ogden if you are aware that any money has been, or will be, paid to
any person working for or engaged by either party, unless any such arrangement constitutes bona fide payment for the
Services or has been disclosed to Spencer Ogden in writing prior to the conclusion of the Agreement. The Contractor
and/or the Representative will notify Spencer Ogden in writing of any foreign public official employed or engaged by it in
connection with this Agreement

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4.4 gifts and hospitality
This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. We
appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and
acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or
hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

4.5 your responsibilities

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery
and other forms of corruption are the responsibility of all those working for us. All contractors, workers and employees
are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must maintain adequate books and records with regard to all relevant transactions and grant Spencer Ogden such
rights of audit as may be reasonable to verify compliance with the provisions of this clause.
You must notify your Recruitment Consultant as soon as possible if you believe or suspect that a conflict with this policy
has occurred, or may occur in the future. We reserve our right to terminate our contractual relationship with workers if
they breach this policy.

4.6 how to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are
unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised
with your Recruitment Consultant. If you are offered a bribe by a third party, and asked to make one, suspect that this
may happen in the future, or believe you are a victim of another form of unlawful activity; again please report any such
activity to your Recruitment Consultant.
Workers who refuse to accept a bribe or those who raise concern or report another’s wrongdoing are sometimes worried
about possible repercussions. Spencer Ogden aims to encourage openness and will support anyone who raises genuine
concerns in good faith under this policy. Even if they turn out to be mistaken. Spencer Ogden are committed to ensuring
that one suffers unfavorable treatment as a result of refusing to take part in bribery or corruption, or because of reporting
a good faith suspicion that an actual or potential bribery or corruption offence has taken place, or may take place in the
future.

4.7 declaration
As a pre-condition of Spencer Ogden accepting you to work on the assignment, and by signing and acknowledging this
handbook, you hereby declare that you understand, are fully aware of and will comply with this Anti-Bribery & Corruption
Policy at all times.

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5. SANCTIONS Policy
This Sanctions Policy of Spencer Ogden aims to ensure that Spencer Ogden complies with all relevant and applicable
sanctions, embargoes and political trade restrictions put in place against target countries. As a UK headquartered
company with global operations Spencer Ogden is required to observe sanctions put in place by the United Nations, the
European Union and the Office of Foreign Assets Control (USA).

5.1 consequence of failing to comply with sanctions

Penalties for failing to comply sanctions and embargoes can be severe and can result in criminal charges being brought
against you and against Spencer Ogden, potentially resulting in significant fines and/or imprisonment. Accordingly, any
breaches of this policy will be dealt with severely and may result in dismissal.

5.2 sanctions policy & declaration

Before working satisfy yourself that in accepting any position you will not cause yourself or Spencer Ogden to breach any
sanction or any trade embargo. Except with Spencer Ogden's prior written approval, you undertake not during the term
of the Assignment travel to and / or supply services in or for any country, or to any business, client or person, that is
subject to any sanction or embargo, whether issued by the European Union, the United Kingdom, the United Nations and
/ or the United States of America or any other country or body. In the event the client requests you to commit any act
that would or might cause you to breach the above undertaking, you will immediately notify Spencer Ogden and will
immediately refrain from carrying out such action. You acknowledge that your failure to notify or to observe the
provisions of this policy may render you liable to criminal proceedings. As a pre-condition of Spencer Ogden accepting
you to work on the assignment, and by signing and acknowledging this handbook, you hereby declare that you
understand, are fully aware of and will comply with this Sanctions Policy at all times.

5.3 sanctioned countries

The below list of countries are subject to some form of international sanctions and for the avoidance of doubt Spencer
Ogden will not currently undertake any business activity whatsoever in these countries:

CUBA IRAN NORTH KOREA RUSSIA SUDAN SYRIA

The below list of countries and companies are or are potentially subject to some form of international sanctions and you
undertake not during the term of the Assignment to travel to and / or supply services in or for any country on this list,
except where you have first obtained Spencer Ogden's prior written approval,
Central African
Afghanistan Guinea Bissau Libya Serbia Yemen
Republic
Democratic
Albania Ivory Coast Macedonia Somalia Zimbabwe
Republic of Congo

Belarus Egypt Iraq Myanmar (Burma) Tunisia

Bolivia Equatorial Guinea Lebanon Republic of Guinea Ukraine

Republic of Guinea-
Bosnia Eritrea Liberia Venezuela
Bissau

The territories listed above are subject to financial sanctions against specific individuals or institutions and/or military end-
use sanctions preventing export of particular technologies. The specific sanctions may not prohibit all trade with these
countries but any placement must be considered on a case by case basis to ensure that Spencer Ogden does not breach
any applicable sanction or embargo. Be aware that it may take time to obtain a decision on whether any particular
placement may proceed. Note also that in countries such as Afghanistan, Iraq and Libya, etc. the security situation may
also prevent placements being made.

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5.4 approved countries
The below countries are not subject to sanctions and Spencer Ogden will undertake business activity in these countries:

Abu Dhabi (UAE) Chile Greenland Malawi Paraguay Sweden

Ajman (UAE) China Grenada Malaysia Philippines Switzerland
Algeria Colombia Guadeloupe Maldives Peru ------------------
American Samoa Comoros Guam Mali Poland Taiwan
Andorra Cook Islands Guatemala Malta Portugal Tajikistan
Angola Costa Rica Guyana Martinique Portugal (Madeira) Tanzania
Anguilla Croatia ------------------ Mauritania Puerto Rico Thailand
Antigua & Barbuda Curacao Haiti Mauritius ------------------ Togo
Argentina Cyprus Honduras Marshall Islands Qatar Tonga
Armenia Czech Republic Hong Kong Mayotte ------------------ Trinidad & Tobago
Aruba ------------------ Hungary Mexico Ras Al-Khaimah (UAE) Turkey
Azerbaijan Denmark ------------------ Micronesia Reunion Turkmenistan
Australia Djibouti Iceland Moldova Romania Turks & Caicos
Islands
Austria Dominican Republic India Monaco Rwanda ------------------
------------------ Dominica Indonesia Mongolia ------------------ Uganda
Bahamas Dubai (UAE) Ireland Montenegro Samoa Umm Al-Qaiwain (UAE)
Bahrain ------------------ Isle of Man Montserrat Saint Helena United Arab Emirates
Bangladesh Ecuador Israel Morocco San Marino United Kingdom
Barbados El Salvador Italy Mozambique Sao Tome & Principe United States of
America
Belgium Estonia ------------------ ------------------ Saudi Arabia Uruguay
Belize Ethiopia Jamaica Namibia Senegal US Minor Outlying
Islands
Benin ------------------ Japan Nepal Seychelles Uzbekistan
Bermuda Falkland Isles Jordan Netherlands Sharjah (UAE) ------------------
Bhutan Faroe Islands ------------------ Netherlands Sierra Leone Vanuatu
Antilles
Botswana Fiji Kazakhstan New Caledonia Singapore Vietnam
Brazil Finland Kenya New Zealand Slovakia Vatican City State
British Indian Ocean France Kiribati Nicaragua Slovenia Virgin Islands (US)
Territory
British Virgin French Guiana Kuwait Niger South Africa ------------------
Islands
Brunei French Polynesia Kyrgyzstan Nigeria South Korea Zambia
Bulgaria French Southern ------------------ Niue Spain
Territories
Burkina Faso Fujairah (UAE) Laos Northern Mariana Spain (Canary
Islands Islands)
------------------ ------------------ Latvia Norway Sri Lanka
Cambodia Gabon Lesotho ------------------ St Kitts & Nevis
Cameroon Gambia Lithuania Oman St Lucia
Canada Germany Liechtenstein ------------------ St Maarten
Cape Verde Georgia Luxembourg Pakistan St Pierre & Miquelon
Cayman Islands Ghana ------------------ Papua New Guinea St Vincent &
Grenadines
Chad Gibraltar Macau Palau Suriname
Channel Islands Greece Madagascar Panama Swaziland

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6. Data Protection Statement
The information that you provide to Spencer Ogden in any form including on any CV given, will be used by Spencer
Ogden Pte Ltd and/or Spencer Ogden Consulting Sdn Bhd to provide you with work finding and related services. In
providing this service to you, you consent to your personal data being included on a computerised database and consent
to us transferring your personal details to our clients.
We may check the information collected, with third parties or with other information held by us.
We may also use or pass to certain third parties information to prevent or detect crime, to protect public funds, or in other
way permitted or required by law.
All data subjects are entitled to know what personal information the company holds and processes about them and why;
how to gain access to it; and how to keep it up to date.
All data subjects have the right to access any personal information kept about them by the company, either on computer
or in a manual filing system. A subject access request may be made in writing only to the Contracts and Compliance team
at ccs.apac@spencer-ogden.com.

7. Contractor & temporary worker Handbook declaration

I hereby acknowledge and confirm that I have read and understand the content of this Spencer Ogden Contractor &
Temporary Worker Handbook. I further understand that as a pre-condition of Spencer Ogden accepting me to work on
the assignment, and by signing and acknowledging this handbook, I confirm I am fully aware of and will comply with
the various obligations set out in the Policies that form part of this handbook.

Signed:

Print name:

Date:

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