Code of Conduct

Fore note

As much as we love to cover as much information to help you, as our employee, to understand more about the Company, the policies and standards expectations for business activities. The following information in this document are the key essentials that are being highlighted and explained.

From time to time, the Human Resource Officer may update this document and update all employees on the changes included.

If there are any areas in the Code of Conduct that you are unsure or unclear of, please kindly reach out to your Manager or the Human Resource Officer for guidance and assistance.

Being Aware of the Code

Integrity - The Quintessential of Code of Conduct

What makes the Company to be the brand of the Quintessential Business Partner to our customers? It is not just our products and services. It is also how we do our work and the integrity of our actions. Integrity is the foundation and essential element to our success.

The Code of Conduct is to help you as a guide:

• When you might face a situation where the right thing to do is not so obvious

• To conduct yourself honestly and ethically

• To uphold our values and beliefs and protect our reputation

• To understand what the Company expects from you

• To make good decisions every day

• To comply with the laws, regulations and standards that apply to our Company

While the Code cannot answer every question, it can help you where to go for guidance when the answer is not clear.

Administering Modifications and Waivers

The Core Team Leader(s) is responsible for administering the Code, and it is overseen by the Authorized Officer.

The Company may modify the Code, as necessary. Any changes and/ or waivers of the Code, must be approved by the Authorized Officer. In situations where it is required to be disclosed by law, we will quickly and properly disclose and update the members.

Who is covered under the Code

It does not matter where you work or what you do for the Company - you have full responsibility to use good judgement and follow our Code. That includes every employee at every level of the Company. The Code also applies to controlled subsidiaries and entities in which the Company either owns a majority interest or manages operations.

All employees, and any others subject to the Code, must acknowledge that they have read and agreed to uphold the Code.

Anyone who works on the Company’s behalf (including suppliers, consultants and other business partners) must share our commitment by following the principles of the Code when providing products and services to the Company or acting on our behalf.

Uphold the Law

Laws and regulations may vary widely from country to country. Because our Company is incorporated in the Republic of Singapore, our employees often are subject to Singapore laws, in addition to the laws of the country where they work. Sometimes local laws or practices can conflict with our Code or the law, in cases like these, contact our legal counsel for guidance.

Your Rights as an Employee

While we expect you to follow our Code, we also recognize your rights as a Company employee. Nothing in this Code or in any Company policy is intended to limit or interfere with your rights under the law.

When a Code Violations Occurs

When one of the employees fails to follow the Code or applicable laws, ignores someone else’s failure to follow the Code or pressures someone else to violate the Code, a violation has occurred.

We take all potential Code violations seriously. Code violations may lead to disciplinary action that matches the nature and circumstances of the violation. Code violations are also documented in your employee record.

The Company has other policies and processes governing performance, conduct and behavior. Policy violations that are not Code violations will be handled under the appropriate policy or procedure.

What you need to do

As employees, each of us has a responsibility to:

• Know and live the Code - read it and follow it, along with any other policies that apply to your job.

• Think before you act - use good judgement, demonstrating the values and beliefs in every action you take.

• Follow the law - understand the laws that apply to your job and our business.

• Ask for help - when an answer is unclear, ask for guidance before taking action

• Stay alert - pay close attention to any activity that is inconsistent with our Code, our policies or the law

• Report concerns - do not ignore a violation. Prevent harm to our Company and its reputation by reporting your concern immediately.

If you are holding a leadership appointment, you have additional responsibilities to:

• Model the Code - promote a culture in alignment with the Company vision, mission, values and beliefs by making ethical decisions and showing it in everything you say and do. Never encourage or direct any employees to achieve a business result at the expense of violating our Code or law.

• Talk about the Code - read the Code and understand it. Refer to it. Make ethics conversations part of your routine.

• Be informed - recognise that you may not always find the answers that you need in the Code, so know where to go for answers when there are questions

• Expect the best - discuss the importance of ethics and compliance and let employees know you expect them to always do what is right

• Be responsive - encourage employees to come to you with questions or concerns. Listen to them carefully and offer guidance when they need help.

• Take action - look out for misconduct and report it, when you encounter it.

How to make Good Decisions

Doing what is right is our goal. If the right thing to do is not clear, ask yourself:

• Is it consistent with our Code?

• Is it legal?

• Does it follow our policies?

• Does it benefit the Company as a whole - not just a certain individual or group?

• Would I be comfortable if my actions were made public?

If you answered “YES” to all of these questions, the action is probably okay. But any “NO” or even “MAYBE” answers are a signal to STOP and GET ADVICE or ASK QUESTIONS. After all, it is always better to ask before you act, especially when you are not sure.

Reporting Concerns

When you sense that something is not right at work, or saw something or heard about an act that may violate our Code, our policies or the law, you have a responsibility to share your concerns by reporting right away - even if you are not sure a Code violation has occurred.

When you report concerns, you help us handle the issues properly, fix problems before they occur and remedy situations that have already happened. You also help build trust with each other and with our customers, suppliers and other business partners.

How do I share Concerns?

For Code Matters, talk to either:

• Your line Core Team Leader(s)

• Human Resource Officer

• Authorized Officer

For Legal Matters, contact our Legal Counsel.

For Financial and Accounting Matters, contact our Accountant.

What happens when You report a Code Concern?

When you report a code concern:

• You may choose to remain anonymous, where permitted by law

• If you do give your name, we will do all we can to protect your identity consistent with conducting a thorough investigation

• We take every report seriously and our assigned investigator will investigate it thoroughly and as confidentially as possible

• We expect everyone involved to cooperate fully and honestly

• Outcomes from the investigation are presented to the investigation panel, who will determine, based on the investigatory facts presented, if there has been a violation of the Code.

• Where the investigation panel determines that a Code has been violated, it will determine a fair and consistent disciplinary action in accordance with applicable law.

• Those found to have violated the Code can seek reconsideration in accordance with our grievance policy.

No Retaliation

You are our eyes and ears of our Company, and we value your help in avoiding and uncovering possible misconduct. We strictly prohibit retaliation of any kind against anyone who shares a good-faith concern or participates in a Code investigation.

We define retaliation under our Code as any action that would likely deter someone from reporting a Code concern or participating in a Code investigation. While we take anti-retaliation provisions of our Code very seriously, these provisions do not protect you from a disciplinary action for your own misconduct.

No False Accusations

As much as we encourage honest reporting, we do not tolerate knowingly false reports. Making a false accusation can divert investigatory resources away from credible good-faith concerns and damage morale. Report what you have a reasonable, good-faith belief to be true, but never knowingly make a false accusation, lie to investigators or refuse to cooperate in an investigation, as these actions may also violate our Code.

Protecting our Assets

Protect Confidential Information

Confidential information is non-public information. By protecting confidential information about our Company, it helps us maintain our competitive advantage and preserve our reputation as the Quintessential Business Partner.

Our responsibility when it comes to information is:

• Knowing what kinds of information are considered confidential

• Knowing the ways to protect it

• Understanding the Confidentiality provisions of the Company.

We consider any confidential information about the Company as well as certain information about our employees, customers, suppliers, and other business partners that you may have (or access) as part of your job, to be confidential information. It can be written, spoken or electronic.

You should:

• Share confidential information only with those who have both the authorization to access it and a need to know the information in order to do their jobs.

• Take appropriate steps to protect confidential information, especially when engaging with external individuals or entities, before allowing them to gain access to our information and follow our rules described in the appropriate policy.

• Watch what and where you say confidential information that can put that information at risk of being disclosed, or possibly misused.

• Ask your upline Core Team Leader(s) or Company legal counsel, if you are unsure whether information can be shared or how to share it.

Your duty and responsibility of confidential information lasts beyond your employment. Your commitment to protect confidential information applies to work when you came to the Company and it applies when you leave.

Protect Company Assets

The place we work in, the things we use and develop to do our job in the Company are company assets that we are each entrusted to protect. We use them to carry out Company business and must protect them from damage, loss, misuse and theft.

Do not use Company Assets:

• For an outside business or other personal gain

• For anything illegal or unethical

Personal use of some assets, within reasonable and as allowed by appropriate policies and procedures, is permitted, but your use should be appropriate, lawful, and never interferes with the job you, or any other employees, is doing. Certain assets may require approval before use.

The following are categories of Company assets, but is not limited to:

• Physical assets - physical property and resources, such as vehicles, equipment and tools, that may be made available to each of us to do our jobs. Never lead, sell or give away unless you are authorized to do so.

• Electronic assets - electronic property and resources, such as computers, hardware, software, mobile devices, and other media, utilized. The information you create, share or download onto Company systems belongs to the Company, and we reserve the right to monitor the system use at any time, to the extent permitted by law.

• Intellectual property - intellectual property, such as patents, copyrights, trademarks and trade secrets, are valuable Company assets. The Company owns any work product, such as ideas, processes and inventions, that you develop or design in your work with us, to the extent permitted by law. The ownership continues even if you leave our Company.

You should:

• Safeguard the Company’s assets, when you do so, you safeguard our ability to grow and thrive

• Do your part by following our policies and using good judgement

• Protect with a passion

• Observe good security practices

• Use care with any property that has been issued to you

• Do your part to prevent misuse, unauthorized use, or access to our facilities.

Accurate Records and Reporting

Each of us, at every level of the Company, has a responsibility for ensuring the accuracy of all Company business and financial records.

We all handle Company “records” when doing our job. Be sure to follow all internal policies, processes, procedures, standards and practices so that our records accurately reflect all transactions. Be honest, accurate and complete in what you record.

Accurate recordkeeping and reporting helps us to:

• Meet our legal and regulatory requirements

• Maintain financial credibility that reflects positively on our reputation and credibility

You should:

• Record and classify transactions in the proper accounting principles and guidelines.

• NOT falsify or misrepresent any record, account or transaction.

• Include appropriate and supporting documentation and approvals that are required

• Where your job requires you to, disclose information to the regulatory authorities, and make sure the information you provide is full, accurate, timely and understandable.

• Know and follow the policies that relate to maintenance, storage and disposal of records.

• NEVER destroy or dispose of information that might be needed for an investigation, an audit, or a legal proceeding.

• Ask your upline Core Team Leader(s) or Company legal counsel, if you are unsure what is required.

Accountability

We are accountable for our own actions and consequences that follow. Every employee, at all levels, has their role and responsibility to carry out their job in an accountable manner.

Conflict of Interest

We are all expected to act in the best interest of our Company. This means we must NEVER allow our personal interests to influence our actions on behalf of the Company. Every decision we make while on the job must be objective and with our Company’s business interests in mind.

Before you act on the Company’s behalf, you need:

• To be able to recognize and avoid potential conflicts of interests

• Get to know the types of situations that can lead to conflicts or the appearance of a conflict

• Disclosed any and all potential conflicts and approved by the relevant authorized parties.

• Seek approval if you have a second job or consulting opportunity, as long as it does not interfere with your ability to do your job with the Company.

• Seek approval if you are required to speak or make presentations as Company employees or because of our expertise arising from our job responsibilities.

• Seek approval if you are accepting a role as a director, advisory member or officer for another organization that may interfere with your obligations to the Company

• Be aware of personal relationships with any third party that you work with that can give rise, or the appearance of, preferential treatment to your friends and family.

A conflict happens when you allow personal interests to interfere with the business decisions you make as an employee. Even the appearance of a conflict is inappropriate and can damage our Company and our reputation.

Is it a Conflict of interest, ask yourself:

• Could my personal interests or relationships influence the decisions I made?

• Could it look that way to someone else?

If you answered “YES” or even “MAYBE” to all of these questions, that is a signal to STOP and GET ADVICE or ASK QUESTIONS. After all, it is always better to ask before you act, especially when you are not sure.

Gifts, Meals and Entertainment

We value the relationships we have built with our employees, customers, suppliers and other business partners. It is important that these relationships remain positive and ethical - never influenced by offers of inappropriate gifts or hospitality.

We do not exchange gifts or entertainment that look like an attempt to improperly influence a business decision. No matter if you are the giver or the recipient.

You should:

• Decline gifts of any value from current or potential person of interest if it would create the appearance of conflict of interest

• NEVER request gifts, meals, entertainment or favors from these third parties.

• NOT ACCEPT if it is given in exchange for some action.

• Seek approval from the Human Resource Officer if you receive gift that you are unsure if it is excessive or not

• Where in the event cannot decline the gift, to accept and notify the Human Resource Officer, who will work with you to donate, distribute or raffle it among a large group of employees.

• Share our Company’s rules regarding gifts with the giver to help prevent similar situations in future.

• Where you are the giver, ensure the gifts, meals or entertainment supports a legitimate business purpose and it is reasonable and appropriate under the circumstances.

• NEVER offer anything that would violate any rules (be it our Code or the person of interest) and put the person in a potentially uncomfortable position

Managing Business Relationship

Our customers, suppliers, and other business partners place a great deal of trust in our brand and we are determined to meet and/ or exceed their expectations. They are our partners - essential to our Company’s growth and success.

Our relationships with our customers, suppliers, and other business partners must:

• Be fair, positive and productive

• Always based on mutual trust and respect

• Be an ongoing process of building relationships

• Require an enduring commitment to high standards of business conduct

• Demonstrate honesty and a commitment to our values.

The relationship is not a unilateral obligation. Therefore, you have a responsibility to:

• Ensure that they know, adhere and uphold to the Code and any other policies

• Help ensure that we are doing business with those who share our commitment to doing what is right

• Give proper representation of the products and services, and NOT engage in any unfair, deceptive or misleading practices

• Be fair and honest in your interactions with them, and AVOID anything that even looks like a possible conflict of interest

• Hold them accountable for any violations that you see or suspect

• Make your decisions objectively based on the procurement requirements; such as sourcing, selection and due-diligence requirements, set in the relevant policy

Managing Your Employment

You as an employee, have been entrusted with the responsibility to do your best for the best interest of the Company. You are an Asset to the Company - essential to our Company’s vision and mission.

In the course of your employment journey with us, you have a responsibility to:

• Ensure that you know, adhere and uphold to the Code and any other policies

• Ensure that jobs assigned/ tasked to you are completed accurately and timely in accordance to the requirements required.

• Participate in the activities of the Company, whenever possible, that does not interfere with your job

• Hold each other accountable for the actions and consequences of the actions

• Make good decisions and/ or judgements in your job

The Employee Handbook is a guide that explains the specifics of your employment journey. If you are unclear or have any questions, you should seek guidance from the Human Resource Officer.

Compliance with Policy and the Law

Privacy Laws

The basis of any good relationship is trust. When our customers, suppliers, or any other business partners do business with us, they entrust us with their personal information or third parties’ personal information. Our employees do the same way when they join the Company.

We take responsibility and obligations to our employees, customers, suppliers, or any other business partners seriously to collect, use and process any personal information only for legitimate business purposes and protect it from possible loss, misuse or disclosure.

We recognize the responsibility and follow the laws requiring us to protect personal information that can identify an individual or which relates to an identifiable individual. Please know that certain personal information can be sensitive and require an extra level of protection and a higher duty of care based on applicable law.

If you are working with personal information as part of your job, guard this information well by following the Company’s policies regarding the access, transfer and use of this information. The personal information can include information about anyone such as:

• Email addresses, including business email addresses

• Telephone numbers

• Employee ID number

• IP-address

• Credit card information

• Financial information

• Medical information

• Names of family members

• Name and government identification number

You should:

• Use it with care, if you have to use it. Only collect personal information for legitimate business reasons, and only use it for the purpose of its collection.

• Access only the limited amount of information that you need to do your job, and only share on a need-to-know basis with authorized person(s) who also need the information for completing their work.

• NEVER share it with any unauthorized person(s) outside of our Company or anyone in the Company who does not require use of such information to complete their job.

• Secure the personal information as you would your own, protecting it from deliberate or accidental exposure.

• Do all you can to handle it properly and uphold data privacy and protection laws wherever we work

Be committed to protecting personal information of our customers, and other third parties. Follow the Privacy Policy to comply with our legal obligations to protect personal information from unauthorized disclosure and ensure integrity and availability of personal information.

Care for our Communities

We Show that We Care

The special ingredient to making the Company a special place is more than what we create - it is about the people who create it and the customers, suppliers and any other business partners who enjoy what we create.

Our products and services are made for people by people who care about delivering their best. While the Code cannot encompass all of our important Company policies, there are some standards that sit at the core of who we are as a Company even if they are administered by other parts of the Company, which establish a foundation for respecting people and environments across the communities.

We have to look beyond ourselves and our needs, setting our sights on building a better community, a better world. We expect the best from ourselves, making sure our business decisions always have a positive impact on communities, the environment and people everywhere.

Remember as an employee, you represent the Company to the world. You can help demonstrate our vision, mission, values and beliefs by upholding our high standards and being aware of your own actions and how they might affect others.

You should:

• Promote fairness, diversity and inclusion by showing respect and appreciation towards others’ varied backgrounds, skills and cultures.

• Watch out for harassment, regardless of form - such as verbal, physical, visual or sexual in nature.

• Speak up against any non-compliance, suspected non-compliance or violations so as to ensure a safe environment for you and for others in the Company.

• Care for people by protecting the safety of co-employees, suppliers and the public, and follow laws regarding working conditions.

• Do your part by using resources responsibly to preserve the environment.

• Respect, learn from and support the communities and cultures with which we work and making a personal impact towards them.

Final Note

Be inspired and work each day in a way that inspires others.

Follow not only our Code, our policies, and the laws and regulations that apply to your work, but also your conscience. When something does not feel right or puts our Company, our people or those we serve at risk, report your concerns. When you do, you preserve our good name and reputation and help us to better navigate the journey for generations to come.