WILMAR MYANMAR HUMAN RESOURCE POLICY POLICY NUMBER : HR/D/002 POLICY TITLE : CODE OF CONDUCT DATE ISSUES + 23! MAY 2024 REVIEW DATE Trust, Transparency, and Compliance: A Guide for Wilmar Myanmar Limited Employees CODE OF CONDUCT Poge 1 of 22Establishing Trust through Commitment: Wilmar Myanmar Limited and its brands has been a steadfast presence in Myanmar since 1996, carning the trust and support of consumers, customers, and society at large. As we stride forward in alignment with our Vision, underpinned by the core values of "Passion and Integrity," we are resolute in our pursuit of sustainable business growth while embodying an indispensable role within our stakeholder community. Foundations of Compliance: In our unwavering commitment (o upholding our esteemed reputation, compliance stands as the bedrock of all our endeavors. Compliance, to us, signifies the meticulous fulfillment of both legal mandates and ethical obligations, in harmony with internal and extemal regulations, as well as societal expectations. By adhering steadfastly to these principles, Wilmar Myanmar Limited not only safeguards its credibility but also fortifies the trust bestowed upon us by our stakeholders, thus mitigating the perils of unforeseen financial repercussions, Proactive Adherence: Our dedication to compliance extends beyond passive observance; it entails a proactive response to the evolving demands and expectations of our constituents. By anticipating and adapting to the dynamic landscape of regulatory frameworks and societal norms, ‘we ensure the perpetuity of our brand integrity and sustain the confidence vested in us Guardians of Trust: Every member of our team serves as custodians of our brand legacy, recognizing that our actions reverberate across our stakeholder ecosystem. Through unwavering commitment to compliance, we not only preserve the trust eamed over years of dedication but also cultivate an environment conducive to fostering enduring relationships with consumers, customers, and society at large. In our steadfast adherence to these principles, Wilmar Myanmar Limited reaffirms its pledge to remain a beacon of trust and reliability within the Myanmar market, Best Regards, cory Pan (/ General Manager Wilmar Myanmar Limited CODE OF ConDUCT Page 2 of 22Definition of Compliance For Wilmar Myanmar Limited, compliance goes beyond the level of just observing laws and ordinances and is defined as follows. Wilmar Myanmar Limited and their employees will observe laws and ordinances and all internal and external rules and regulations, uphold social norms, fulfill legal obligations and social ethical responsibilities, and thereby prevent unexpected losses and loss of credibility and maintain and increase stakeholders’ trust in Wilmar Myanmar Limited. Here, stakeholders refer to Consumers, Environment, Communities, Employees, Business Partners, and Shareholders/Investors. Below we list specific compliance items and desired behaviors (as well as actions that are prohibited) as Guidelines, in light of daily corporate activities Weare asking all group companies to thoroughly implement systematic detailed approaches to observing compliance in accordance with these Guidelines. Relation between Wilmar Myanmar Limited’s Philosophy, Vision and Values and Compliance Guidelines Wilmar Myanmar Limited Compliance Guidelines are the actions that are demanded by law and by social ethics among the actions sought in Company’s Philosophy, Vision and Values. Please consider the Compliance Guidelines the minimum necessary action standards that must be observed by each Wilmar Myanmar entity and their employees. General Rules Observe all laws as a matter of course, respect social norms, and strive to conduet sensible corporate activities. a. Observe all domestic and foreign laws. b. Be fully aware of the corporate ethics expected for Wilmar Myanmar Limited and act sensibly with responsibility as a member of society in accordance with Company's Philosophy, Vision and Values. ¢. Promptly and accurately report both positive and negative information to your superiors, CODE OF coNDUCT Page 3 of 224. 4.1. Relati 4.1.1. Product Safety Detailed Rules with Consumers a. Always pay attention to safety in product manufacturing, development, storage, sales, transportation, and other product procedures. Fully understand and observe all safety standards and laws related to product safety and aim at achieving higher safety. b. Immediately confirm the facts whenever receiving information regarding product safety. When it is determined that there is a problem, contact the concerned business units and respond appropriately. c. Respond promptly, sincerely, and politely to customer comments, swiftly determine the cause, and make efforts to prevent reoccurrence. 4.1.2, Protection of Personal Information Personal information that has been acquired in the course of business shall be used only for the intended usage purpose of such information (except for cases where disclosure is required by applicable laws and regulations). The information shall be strictly managed to prevent divulgence to unintended people and external parties 4.2. Observance of the Antimonopoly Act Do not engage in actions that are in violation of the Myanmar Competition Law, including the use of illegal means for cartels or the maintenance or determination of resale prices. Engage in free and fair competition, * Thiy includes prohibition of unfair trading practices under the Myanmar Competition Lav. 4.3, Relations with Environment 1. Environmental Conservation Based on the basic policy outlined below, top management will exert its leadership and all employees will cooperate to introduce environmental measures to corporate activities. We will pursue environmental preservation as one of our top-priority issues while setting high goals. CODE OF CONDUCT Page 4 of 22i, We will pursue environmental preservation throughout the entire value chain and all aspects of our business activities. ii, We will ensure environmental preservation through assessments and audi 4.4, Relations with Communities 4.4.1. 44.2. a. ©, Observance of All Types of Laws, Regulations, and Business Laws Observe all types of laws and regulations*, observe the relevant re all business laws governing the products and services handled, acq required permits and licenses, submit all notifications, and follow all other required procedures without fail. * These include Companies Act, Myanmar Contract Act, State, Income Tax Act, FDA Act, Myanmar Investment Law, Myanmar Citizens Investment Law and Highway Traffie Law. Regulations on Donations and Political Contributions Observe all relevant laws* and follow proper methods when mal political contributions and donations to all types of organizations. *These include the Election Law. Obtain prior approval in accordance with intemal company rules when implementing all types of contributions and donations. Strictly refrain from bribery, provision of illegal profits, and illegal political contributions as a matter of course, and from all collusive political and governmental actions that could invite misunderstandings and strive to build up sound and transparent relations, Harmony with Relevant Countries and Local Communities When conducting business, we will respect the economy, society and culture of relevant countries and areas inside/outside the country. CODE OF CONDUCT Page 5 of 224.5. Relations with Employees 4.5.1. Workplace Health and Safety Give top priority to securing health and safety, strive to maintain a safe and healthy workplace environment, and understand and observe all laws and regulations related to work health and safety. * Related legislation includes the Industrial Safety and Health Law. 3.2. Observance of Labor Laws Observe all labor-related Jaws and strive to maintain a comfortable and healthy workplace environment. Leaders must thoroughly manage members’ working days and working hours, and always pay attention to members’ physical and psychological health. * In relations to prevailing Labor laws in Myanmar which includes Factory Act 1951, Social Security Law 2012, Settlement of Labor Dispute law 2012, Minimum Wages Law 2013. 4.5.3. Observance of the Work Regulations a. Employees must always observe the Work Regulations. b. Do not engage in any acts prohibited by the Work Regulations ©. Do not engage in any dishonest acts or any improprieties that violate the working regulations, 4.6. Prohibition of Political Activ ies Do not engage in any political activities during working hours. 4.7. Respect of Human Rights and Prohibition of Discrimination “Always strive to maintain a workplace environment that is safe and comfortable to work in, respect everyone’s human rights, and do not engage in acts that lead to discrimination. a, Do not engage in any form of discrimination based on differences of race, ethnicity, nationality, social status, lineage, sex, disability, health conditions, ideology, faith, occupation, or occupational status CODE OF CONDUCT Page 6 of 22b, Inaccordance with internationally recognized standards, we support and practice the elimination of all kinds of forced labor and substantial abolition of child labor. Implement human rights training and other human rights education activities throughout the company and actively participate in these activities. 4.8, Prohibition of Harassment a, We will never engage in physical, sexual, psychological and economic abuse, harassment, or neglect (language and behaviors that offend others, and retaliation for the harassed party's response, such as imposing undue disadvantage on the harassed party’s work conditions, or aggravating the work environment). b. Asamatter of course, do not personally engage in any words or acts that may be construed as harassment, and strive to create an atmosphere whereby ha ©. Positively participate in harassment training implemented by the smeni will not occur in your workplace. ‘company. 4.9. Prohibition of Drink-Driving, Problem Drinking & Drugs Policy Do not engage in driving under the influence of alcohol, drugs or drink-driving, Drink responsibly; do not engage in problem drinking and drugs. Strict disciplinary actions or dismissals for Wilmar Myanmar Limited employees who: a, Drives a company vehicle in the course of the performance of their duties, commits an alcohol related offense which leads him to the loss of driver’s license and as a result are unable to perform their normal duties; b. Damages to company property and/or property of a third party - where they may personally liable for the cost of repairs and replacements; or ¢. If caught in possession of illegal drugs or under influence of illegal drugs. 5. Alcohol Policy 5.1. Employee Responsibility: CODE OF CONDUCT Page 7 of 22a, Each employee should be aware of their aleohol intake limit and NOT to engage in excessive drinking (to be under the influence of alcohol). b. Excessive drinking not only impairs the employee’s judgement, but could also endanger the safety of others, ©, Asa-safety pre-caution, employees under the influence of alcohol are not permitted to drive a vehicle, Instead, these employees are encouraged to take public transport or make special arrangements with colleagues. 4d, Employees who do not abide by Wilmar Myanmar Limited Alcohol Policy can be subjected to appropriate disciplinary measures, 6. Drugs Policy a. Drug taking is defined as taking of drugs by an employee other than those ion, which drugs prescribed as medi pairs employee's ability to perform his/her duties, or his/her attendance at work is interfered with, of he/she endanger the safety of others. b. Possession of Mlegal drugs: employees caught to have illegal drugs in possession which includes but not limited to heroin, cannabis/marijuana, cocaine, ecstasy and amphetamines. Wilmar Myanmar Limited views seriously on employees taking drugs or in possession of illegal drugs. If found the employees shall be terminated immediately upon breach of these rules. If suspected, Company shall subject a search be carried out on staff"s possessions. In addition, possession of or dealing in illegal drugs on Company premises shall be reported to the police. 7. Entertainment and Gifts 7.1. Prohibited Acti ies: Organization funds/assets cannot be offered, paid, loaned or transferred directly or indirectly to any Government Official, particularly if the payment or gift is for an illegal purpose under the Myanmar Law or in influencing the decision ofa Government Official. Employees are not allowed any corruption as any dishonest or fraudulent behavior wherein someone uses their position of power to benefit themselves at the expenses of other person/parties (examples: bribery, embezzlement, CODE OF CONDUCT Page 8 of 227.2. Permitted Activities: nepotism, extortion, kickbacks, money laundering, entertainment, commis ion fraud or conflict of interest). Cash & non-cash payments or donations by organization to customers and suppliers for valid business purposes or for promotional activities are allowed ifthey: a, Are designed to promote the sale of the Company’s products or to enhance generally the business relationships between the Company and its suppliers and customers; and b, Are legal and are acceptable by local community standards and custom. In the event that an employee is presented with a pecuniary benefit or gift, it is imperative that they promptly disclose such offerings to their immediate lance and advice superior or Head of Department, who will offer 2 accordingly. Conflicts of Interest a. During their employment with the Group or Company, all Employees are not allowed to engage in any form of gainful employment or business act ted by ity, unless specific prior approval in writing has been gr: the Group or Company. b. All Employees, particularly field staff (non-desk bound employees) are strictly prohibited in engaging in any type of private work or trade for personal benefit notwithstanding whether such work is carried out within ot outside Company’s premises. c. All Employees should always aet in the Group or Company’s best interest. d. To avoid situations which are of potential conflict of interest, the Employees should not engage in any activity, interest, investment or association that ‘may interfere with their judgment concerning the Group's or Company's best interests. e, Failure to safeguard such information shall be regarded as “Breach of Trust” and shall result in termination of service and / or legal action. CODE OF CONDUCT Page 9 of 22f. The Company cannot define every situation of conflict of interest, However, the following situations shall always be considered as conflict of interest i, Ifthe Employee or any member of his immediate family or relatives hhas a significant interest in one of the Group’s or Company’s suppliers, be it products or services, customers or competitors without obtaining written approval from the General Manager. ii, If the Employee engages in a significant personal business transaction involving the Group or Company for profit or gain without obtaining written approval. iii, If the Employee or any member of his immediate family accepts money, gifts of more than nominal value, excessive hospitality, loans or special treatment from any supplier, customer or competitor of the Group or Company. “More than nominal value” refers to a gift or favorreceived in any form, which prevents an Employee from acting in the best interest of the Group or Company. iv. If the Employee steals, loans or gives away Group or Company property without obtaining proper approval vy. Ifthe Employee knowingly breaches the Group or Company's rules and procedures, 8. The Employee is advised to consult Management if he is uncertain about a situation of potential conflict of interest, h. An Employce may be required to serve as a director of the Company or of ‘other companies within the Group. In this case, the Employee shall be entitled to the directors and meeting fees/allowances (if any) payable by the relevant Company. An Employee shall not serve as a director of corporations which are not related to the Company or the Group without the approval of the General Manager. However, an Employee may assume directorships of non-profit or public service corporations such as religious, educational, cultural, social welfare, philanthropic or charitable institutions provided that the discharge of these responsibilities does not interfere with his duties and responsibilities to the Company, CODE OF CONDUCT Page 10 of 228.1. Relations with Business Partners 8.1.1.Appropriate Transactions with Suppliers and Observance of the Contract Act a. Conduct transactions with suppliers with common sense and in good faith, and handle these transactions fairly and justly. Completely observe all stipulations of the Subcontract Act. b. We will demand of suppliers that they comply with laws, regulations and social norms, and implement environmental measures in line With our efforts to jointly achieve appropriate procurement practice 8.1.2. Appropriate Business Entertainment and Exchange of Gifts a, Absolutely refrain from deviating from the range of general social common sense in providing entertainment and gifts to trading partners and in receiving entertainment and gifts from trading partners. b. We will not offer unjustifiable entertainment, gifts, benefits and other economic interest to public servants and people in a similar position, 8.2, Relations with Shareholders and Investors 8 Appropriate Accounting Treatment Wilmar Myanmar Limited’s accounting record and reports are relied upon by the Government, Stakcholders, Management, creditors, and others. These reports shall be in accordance with Myanmar and Intemational Accounting Standards, The records and reports must contain reasonable details to accurately reflect Wilmar Myanmar Limited's assets, liabilities, revenues, and expenses. Providing false information in the supporting documentation, accounting records and accounting reports is a serious wrongdoing. Responsibility Wilmar Myanmar Limited employees involved in transactions shall ensure these transactions: CODE OF CONDUCT Page 11 of 22b. e fi CODE OF CONDUCT Are adequately supported with correct documentation, with accurate amount; ii, Nature of transaction correctly reflected and entered into the right account classification and in the proper accounting time period. Estimates To the extent estimates are necessary in such financial reports to management, (e.g, annual business plans or budgets, rolling estimates, capital budgets or request for approval of CAPEX), such estimates shall be based upon good faith judgement. Payments No payment or other asset disposition by or on behalf of the ‘Company shall be made without supporting documentation. Sales Alll Sales must be recorded accurately. Invoices must show the correct details, price and invoice amount, Customers must not be overcharged. Any gratis or rebates must be properly approved. Purchases All payments made by Wilmar Myanmar Limited (including advertising, marketing and promotional participation) shall be supported by complete and accurate documentation issued by the correct supplier showing the actual purpose of the payment. Aceruals (including provisions) Accruals (e.g., provisions for uncollectible receivables and prepaid and accrued expenses, including advertising and marketing) shall be supported by appropriate documentation and based on good faith estimates as required by Wilmar Myanmar Limited’s accounting policies and Generally Accepted Accounting Principles. Employees must not intentionally over or underestimate any accruals, Cash Deposits and Accounts All company funds must be made known and accurately recorded in the accounting records. All bank accounts and cash accounts must Page 12 of 22be properly accounted for in Company’s accounting records. All cash received shall be promptly captured in the Company’ accounting records and deposited in a bank account maintained with bank or other financial institution approved by Wilmar Myanmar Limited Board h. Appropriate Use of Company Assets Use company assets efficiently, recognize that they must be kept in a condition whereby they can always be used, and handle both tangible and intangible assets appropriately to prevent damage, theft, ete, Do not use company assets or expenses for personal purposes, 8.3, Appropriate Use and Management of Information Assets a, Employees shall not use Company’s resources or information for personal benefit b. Strictly manage company information system IDs and passwords and prevent their leakage outside the company. ¢. The company will take serious disciplinary action against employees who personally posted without any approval in relating to the company’s information, company products’ information, company’s BODs, management teams and superiors’ information and personal comments, ‘company’s staff information and personal affairs, posted on the personal social network and any other media and social network are strongly prohibited. This affects the company’s reputation. 8.4. Installation of Ilegal Computer Software An Employee is not permitted to install any unlicensed software (c. . games, shareware, freeware, screensavers, icons, etc.) in his/her computer. *As part of Wilmar Group, Wilmar Myanmar Limited employees comply with the Group Information Security Rules. 8.5. Management of Company Secrets Manage company secrets appropriately, and do not disclose or leak company secrets without company permission. CODE OF CONDUCT Page 13 of 22a, Strictly manage company secrets and do not leak company secrets outside the company or use them for purposes other than business purposes. b. When disclosing company secrets outside the company conclude confidentiality contracts and otherwise strive to prevent unexpected leaks. * Av part of Wilmar Myanmar Limited employees comply with the Group Information Security Regulations, 8.6. Protection of Intellectual Property Company intellectual properties are important company assets, Use company intellectual properties appropriately and strive to protect company intellectual property rights. Do not engage in any activities that violate other companies’ intellectual property rights such as unauthorized copying of other companies’ computer software. Conclude appropriate contracts when using trading partners’ intellectual properties, and do not wrongfully use said properties. 9. Supplementary Rules . Scope of Application of the Compliance Guidelines ‘The Guidelines apply to all Wilmar Myanmar Limited fulltime and temporary employees, ‘Compliance Any employee who violates the Code of Compliance Guidelines detailed out in point 4, based on the degree of violation may be subjected to the variety of disciplinary action being taken by the Company which ranges from being reprimanded (warning), being put on a probation, suspension, demotion, salary reduction, bonus reduction or elimination or dismissal When the behavior of an executive or employee has been deemed to violate these compliance guidelines, she/he will be penalized in accordance with internal rules. 9.2. Acceptance of Compliance Guidelines The Human Resource Department shall ensure that every employee, eurrent and new, receives and acknowledges receipt of this Code, ensure that every employee is given the Awareness Briefing followed by a refresher on an annual CODE OF CONDUCT Page 14 of 22basis. A copy of the details an acknowledgement of the training attended proof shall be filed accordingly in each employee's respective personal file. Revisions or abolishment of these Compliance Guidelines shall be determined by the General Manager after deliberations for the above purposes shall comprise Human Resource Department, Compliance Committee, General Manager! Director as the advisor. 9.3. Others 9.3.1. Misuse of Posi n An Employee must not use his position or the Company’s/Group’s name for personal advantage in political, investment or retail purchasing transactions, or in similar types of activities The use of position to obtain preferential treatment not normally accorded to the Company’s Employees at large is discouraged 9.3.2. Insider Trading a. An Employee shall not deal in the securities of any company listed or pending listing on a stock exchange at any time when he is in possession of information, obtained as a result of his employment with the Company which is not generally available to shareholders of that company and the public and which, if it were so available, would likely bring about a materi change in the market price of the shares or other securities of the company concemed. b. If an Employee possesses insider information, he is also prohibited from influencing any other person to deal in the securities concerned or communicating such information to any other person, including other members of the staff who do not require such information in discharging their duty. Confidentiality An Employee must take every precaution to protect the confidentiality of company information. An Employee shall not CODE OF CONDUCT Page 15 of 22during, or after termination of his employment with the Company (except in the proper course of his duties or with the Company's written consent) divulge or make use of any secrets, copyright ‘material, or any correspondence, accounts or dealings of the Company. An Employee shall not in any way use information so obtained for finar b. Trade Secrets An Employee shall faithfully serve the Company and in particular, shall not at any time while employed by the Company or after the end of his employment, disclose or make use, otherwise than on behalf of the Company, of any trade secrets or confidential information of the Company. 9.3.4, Restriction on Solicitation An Employee shal! not, at any time within two (2) years from the end of his employment with the Company, either solely or jointly with, as principal or as an agent for any other person, firm or company, directly or indirectly, solicit, interfere with or endeavor to entice away from the ‘Company, any person, firm or company who at any time during his employment with the Company, were Employees, principals, agents, suppliers or customers of or in the habit of dealing with the Company or Group. 9.3.5.Media Relations 9.3.6. Trade Union, Political and Social Act All enquiries from the media e.g., TV, radio, press, ete. must be referred to the General Manager. An Employee is not permitted to give interviews for any purpose connected with the Company or the Group without the prior consent of the General Manager, ties If an Employee is involved in trade union activities, permission has to be sort from the Management in writing before such activities can be CODE OF CONDUCT Page 16 of 22undertaken. An Employee shall ensure that his involvement or participation in these activities will not infringe on or interfere with his duties and responsibilities to the Company. 9.3.7. Forced Labor ‘The Company believes that our workers should have rights to their work on a voluntary basis, which means that all forms of forced labor ted. The company aims to protect workers, the free choice of employment not including bonded, indentured and prison labor are prol requiring deposits, retaining identity documents or withholding wages. To let workers, terminate their employment contract after reasonable notice, All workers have freedom of movement which allows them to have free access to toilets, water breaks without any restrictions, disciplinary action or termination. Likewise, workers are allowed to leave their work for some circumstances such as personal or family emergencies or illness without the fear of disciplinary action, discrimination or termination of employment. 93.8. Child Labor The company does not employ workers under the age of 18, The company wants to make sure that no child labor is used to produce merchandized for our buyers/customers, especially in areas performing hazardous work. Age verification and document validity checking is made during employment process. 9. Social Media Usage Employees must refrain from disclosing any information pertaining to the company, including its name and relevant details, as well as any information regarding the brands of products manufactured by the company. Expressing opinions that suggest superiority over others is prohibited. Furthermore, sharing defamatory statements about the company or its employees on personal social media platforms, even with consent, is strictly prohibited. Employees are also prohibited from CODE OF conDUCT Page 17 of 2210. 10.1, sharing personal opinions in writing, Additionally, expressing support for one another is strictly prohibited Whistle-blowing Policy Whistle-blowing Policy (WbP) Escalation Process As the Wilmar Myanmar Limited is committed to the highest possible standards of integrity, transparency and accountability, to safeguard shareholders” interest, ed fully is commitment to support its WbP (Whistle-blowing policy) which is to enable and the Company’s assets and reputation, Wilmar Myanmar ‘Company’s businesses to respond nimbly to changes in the environment and to ensure that the corporate culture of integrity, transparency and accountability and governs all the Company’s businesses. Whilst Wilmar Myanmar Limited understands that employees may be reluctant to express their concem of fellow colleagues violating the Guidelines and subjected to harassment or victimization in the workplace, the WP serves to encourage, and provide a channel for employees to report in good faith and in confidence, without fear and reprisals, concerns about possible improprieties in financial reporting or other matters. This WbP provides to the employee the followings: a. A set of procedures to enable them to raise concerns in good faith, and receive feedback from the Company on actions, if any, taken in respect of such concerns; b. Assurance that employees will be treated fairly, and to the extent possible, is protected from reprisals or victimization for WbP in good faith. Such good faith reporting MUST not be made recklessly, maliciously, and/or for personal gain. losures: Whistle-blowing does not include the following types of di a. Operational matters which should be dealt with in normal course of works; or ‘CODE OF CONDUCT Page 18 of 22ul. 2. b. Human resource or other issues for which the place resolution procedure set up by the company is in place The scope of the WbP shall include the followings: Any employee who has a reasonable belief that there is a serious misconduet, actual or suspected should reroute to the assigned contaets to enable right actions to be taken: Areas Person to report to: 4. Financial or professional misconduet b, Improper conduet/unethical behavior /_ violence at the workplace Irregularities & non- compliance with the laws /regulations Conflicts of interest e, Health / safety of individual f Other matters that may affect shareholders’ interests Roles of Compliance Committee On behalf of the Management Team, a committee will be formed to exercise overall control and supervision over compliance issues, and work toward the full enforcement of these Compliance Guidelines. The Committee shall draft, promote, and support policies for the full enforcement of these Compliance Guidelines at Wilmar Myanmar Limited, and implement regular monitoring and reporting to the General Manager / Director the status of compliance in an effort to establish the Plan-Do-Check-Action (PDCA) cycle. WbP- The Steps: a. WP encourages an employee who makes a report in good faith, to put his name to such disclosure as disclosures made to the Company anonymously, are much less powerful. b. Concems are better in writing highlighting the following details: i, Name: CODE OF CONDUCT Page 19 of 2213. 14. a ii, iii iv, v. Department: Reasons (Title of concerns) Supporting details giving the names (involyed), date and place where possible: Signature: Note: Form template shall be distributed ¢. If it is not convenient to place the concern in writing, an employee may telephone or e-mail to Group Head of Human Resources (per details provided in the table above), d. The cases of c ems received shall be investigated internally, Depending on the nature of the cases, the various cases may be subjected to one of the following actions: i i I. Case resolved by agreed action without the need for investigations Case may involve independent (domestic) enquiry; Case be referred to the extemal auditor; and /or Case be referred to the polie: . The Company shall ensure that any employee who makes a disclosure in good faith: ii, WoP— Will not be penalized or suffer any adverse treatment for doing so; and Will be protected to ensure that the employee is not personally disadvantaged by having made the good faith report, including harassment and vietimization, What not to do: Any employee who does not act in good faith and makes an allegation without having a reasonable ground for believing it to be substantially true, or makes it for purposes of personal gain, or maliciously, may be subject to appropriate action by the Company. Compliance Q&A What kinds of behavior are deemed “harassment”? CODE OF CONDUCT Page 20 of 22A Q A Harassment mainly refers to “sexual har ment.” Their explanation follows. “Sexual harassment” here refers to unwelcomed sexual behavior or acts of both. physical and non-physical which are vulgar in nature, which makes a person, feel offended, humiliated, or intimidated. Verbal (nonphysical) gestures include ‘obscene remarks. In order to eliminate harassment, it is important that each and every employee at the office acknowledge and accept the differences of cach other, mutually respect their personalities, and communicate appropriately on a daily basis. How are information assets managed? It is important to habitually observe information security rules to prevent information assets from divulgence, tampering, and improper use. @ Al Many kinds of important information assets such as managerial information, sales information, technical information, and personal information are kept inside the company. If these information assets are divulged, tampered, or used improperly, this may not only inhibit our business activities, but also cause a lot of trouble for our customers and partners, and we may immediately lose trust from stakeholders, Furthermore, this may impact the entire Wilmar Myanmar Limited, Specific rules for the management of information assets include: only allow access authority to those who need it; do not leave information assets on your desk; use a locked storage space for information assets; always keep cell phones, PCs and documents in sight when taking them out of the office; when using external memory devices such as USB memory, borrow them from the company; and enerypt data as necessary. What points require particular care in the handling of personal information? Understand the scope of personal information. CODE OF CONDUCT Page 21 of 22A2 Personal information refers to information that enables the identification of specific individuals such as name, date of birth, phone number and address. Ifa combination of several types of information allows identification of speci individuals, this will also be deemed as personal information, Handle and manage personal information appropriately. When acquiring personal information, you must explain the specific purpose of use and obtain consent from the person concerned. It is not permitted to use the information for other purposes and provide it to third parties without permission from the person concerned (except for eases where disclosure is required in accordance with applicable laws and regulations). Lists of personal data that allow easy identification of specific individuals must be handled with great care because they may have considerable impact. Appropriate handling and attentive management are required to avoid disturbing holders of personal information as a result of accidental divulgence. VALIDITY AND AMENDMENTS. This policy is effective from the date of singing. Any revisions, adjustments, or additions to this policy must authorized. Approved By Cory Pan General Manager CODE OF CONDUCT Page 22 of 22