Mun Hean Code of Conduct

Mun Hean emphasizes the importance of employees understanding the rules of conduct governing the Group’s operations, to which they are individually accountable, and the consequences of failing to adhere to these rules.

Mun Hean has implemented this Code of Conduct to establish the principles of behaviour that should govern the actions of employees. It serves as a guide to uphold the highest standards of personal and corporate integrity when interacting with Mun Hean’s competitors, customers, suppliers, fellow employees, and the community.

This Code of Conduct outlines the standards and rules of behaviour that all and employees must adhere to. These standards apply universally across all jurisdictions and legal entities under the Group’s operation. Additionally, they may be complemented by specific requirements tailored to individual countries or business contexts. The rules of conduct encompass various general categories:

• Employee Behaviour – covers what is considered acceptable and unacceptable conduct, including guidelines for personal behaviour and Mun Hean’s policies regarding workplace harassment.

• Business Behaviour – focuses on ethical standards in business practices, such as anti-corruption measures, guidelines for giving and receiving gifts, hospitality, and promotional expenses, interactions with third-party associates, and managing conflicts of interest.

Any breach of the conduct rules outlined below is considered misconduct and may lead to disciplinary measures against an employee. Employees are urged to report any breaches of this Code using the procedure outlined in the Mun Hean Whistle-Blower Policy. Any efforts to identify a whistle-blower or retaliate against someone making a genuine report are seen as serious misconduct and must be avoided.

1) Employee Conduct

Mun Hean has consistently upheld a policy of strict compliance with all laws and regulations across all countries where the Group operates. Employees of Mun Hean are expected to consistently prioritize actions guided by the highest standards of integrity, in alignment with the Mun Hean Core Values. Employees need to recognize that we value not only the outcomes achieved but also the methods used to achieve them.

a) Employees are required to adhere to and abide by all laws and regulations of Singapore, the local laws and regulations of any other countries where the Group conducts business operations.
b) Employees are expected to consistently prioritize actions that serve the best interests of the company.
c) Employees are obligated to conduct themselves with honesty and exercise reasonable care, skill, and diligence in fulfilling their duties and responsibilities at all times.
d) Employees should avoid situations where their personal interests may conflict with their obligations to the relevant Group company.
e) Employees are required to use the powers and assets entrusted to them solely for purposes authorized by the relevant Group company.
f) Employees must consistently ensure that the Group’s physical and electronic assets, records, and intellectual property are adequately protected and safeguarded at all times.
g) Employees are responsible for handling personal data encountered during their employment with care and ensuring it is properly safeguarded.
h) Employees must refrain from using any information acquired through their position for personal gain or to benefit others improperly, or to cause harm to any Group company.
i) Employees are prohibited from participating in any business or employment outside of their work hours that could potentially compete with any Group Company, create conflicts of interest, or harm Mun Hean’s interests.
j) Employees should collaborate with colleagues in a way that enhances the efficient operation of Group business. They should also recognize and act upon the understanding that all employees share the responsibility for supporting and adhering to the Group’s goals and objectives.
k) Employees should refrain from possessing or using alcohol in the workplace and in any situation where their behaviour or performance at work may be affected.
l) Employees are prohibited from possessing or using recreational drugs in any situation, even if such use is permitted under local laws.
m) Employees are expected to take responsibility for their actions on social media and ensure that their actions align with Mun Hean’s values and guidelines at all times.
n) Employees should be aware of risks within their direct area of work and workplace settings. They should promptly report any risks, hazards, or potential issues that may impact their department or business unit to their supervisor.

2) Workplace Health, Safety and Environment

(a) Safety is fundamental at Mun Hean. We conduct our business with a strong emphasis on valuing and safeguarding the safety of our employees, those involved in our operations, customers, and the public. Mun Hean is dedicated to preventing all accidents, injuries, and occupational illnesses through the active engagement of all stakeholders. We are committed to safeguarding the health and safety of our employees and to operating without causing harm to people or the environment.

(b) Health & Safety
• Adhere to all Health, Safety, and Environment rules and procedures in the workplace.
• Do not interfere with or manipulate any safety device or equipment.
• Only engage in tasks for which you have received appropriate training and are qualified to perform.
• Cease work immediately if you believe it is unsafe and notify your supervisor. Do not take unnecessary risks.
• Report any accidents, injuries, illnesses, or unsafe conditions to your supervisor. Do not assume that others will take care of it.
• Ensure that your performance is not compromised by factors such as lack of sleep, fatigue, drugs, or alcohol.
• Familiarize yourself with the appropriate procedures to follow in the event of an emergency in your workplace.

(c) Environment
• Contribute to environmental conservation efforts by reducing paper and energy consumption, minimizing waste generation, and recycling whenever feasible.
• Safely handle, use, and dispose of chemicals and waste materials.
• Inform your supervisor immediately of any releases, spills, or leaks that pose a risk to the environment.

3) Workplace Harassment

(a) Mun Hean strictly prohibits discrimination based on any factor, including ethnicity, gender, religious beliefs, nationality, age, or physical disability. Our goal is to cultivate a work environment that encourages mutual respect among employees and fosters harmonious working relationships. We consider harassment to be any behaviour that creates an intimidating or hostile workplace, interferes with an individual’s job performance, and negatively impacts their employment or career advancement opportunities.

(b) Examples of harassment encompass, but are not restricted to, epithets, slurs, negative stereotyping, intimidating behaviours, and the distribution, display (within or outside your work area), or emailing of written or graphic materials that demonstrate hostility towards individuals based on their ethnicity, gender, religious beliefs, nationality, age, or physical disability.

4) Business Dealings and Compliance with Laws

The rules of business conduct outlined below apply to all business dealings and transactions of Group companies in every country where they operate.

5) Ethical Conduct

Mun Hean conducts its business with integrity, fairness, impartiality, and adherence to ethical standards and all relevant laws and regulations. Integrity must be the foundation of all our relationships, including those with customers, suppliers, communities, and employees. In challenging situations, employees are expected to have the courage and determination to do what is morally right and ethical.

6) Anti-Bribery and Corruption

The anti-bribery and corruption policies and measures outlined below are essential to safeguard the business, resources, and reputation of the Mun Hean Group.

(a) Employees must never, under any circumstances, offer, or authorize the giving, directly or indirectly, through third parties, of any bribe, kickback, illicit payment, benefit in kind, or any other advantage to a government official or entity, private sector customer, supplier, contractor, or any other individual or entity. This should not be done as an inducement or reward for improper performance or non-performance of duties. Facilitation payments, which are payments or gifts made to expedite or ensure the performance of routine governmental actions that officials are already obligated to perform, such as issuing permits or providing services, could also pose bribery risks. Therefore, employees must refrain from making any facilitation payments on behalf of any Group company.

(b) Likewise, employees must never, under any circumstances, solicit or accept, directly or indirectly, any bribe, kickback, illicit payment, benefit in kind, or any other advantage from any government official or entity, customer, supplier, contractor, or any other individual or entity. This should not be done with the intention to induce or reward improper performance or non-performance of duties.

7) Gifts and Hospitality

It is essential to exercise sound judgment when giving or receiving gifts and hospitality. The offer and acceptance of gifts or hospitality should be avoided if they could influence or be perceived to influence business transactions or dealings, or if they are not reasonable and genuine. Employees should refrain from giving or receiving gifts or hospitality (including entertainment, meals, business travel, tickets to social, entertainment, or sports events, etc.) that are excessively valuable, offered too frequently, or could create a sense of obligation for either party. Cash or cash equivalents as gifts or hospitality are strictly prohibited and must be avoided.

8) Donations and Contributions

(a) Donations, sponsorships, and contributions made on behalf of a Group Company must not serve as a guise or cover for bribery. They should only be made without the anticipation of receiving business benefits in return.

(b) When making any donation or contribution, the following guidelines must be followed:

• Donations and contributions must always be conducted transparently and documented appropriately.
• Documentation must include the identity of the recipient, the purpose of the donation or contribution, and the reasons for providing it.
• Donations or contributions must adhere to the laws of the country where the donation is intended to be made.
• Donations or contributions should be directed to organizations rather than individuals whenever feasible.
• Anonymous donations are not permitted.
• Payments into private or personal bank accounts are strictly prohibited.
• Approval must be obtained as required by the Group Donations and Sponsorship Policy.

No donations or sponsorships may be made to any political party or politicians for campaign or related purposes.

9) Dealing with Third Party Associates

(a) Third Party Associates refer to individuals or entities not owned or controlled by a Group Company, who provide services or engage in business activities on behalf of a Group Company. These individuals or entities include, but are not limited to, joint venture partners, consortium members, commercial agents, sales representatives, distributors, consultants, advisors, service suppliers, contractors, subcontractors, and any other service providers acting on behalf of a Group company in connection with its business operations.

(b) The assistance and local expertise provided by Third Party Associates can be crucial. However, to mitigate the risk of fraud or corruption on their part, Third Party Associates should be informed of and, if applicable, adhere to Mun Hean’s business conduct rules.

(c) It is crucial for employees to closely monitor a Group Company’s relationship with Third Party Associates. Each Third Party Associate should undergo careful selection and evaluation before being engaged by a Group Company, based solely on merit. It is the responsibility of on each employee to be familiar with the Third Party Associates with whom they conduct business behalf of a Group Company. Employees should understand the services provided by each Third Party Associate to the Group Company and the manner in which these services are delivered

10) Official Records

(a) In order to facilitate financial audits and prevent improper payments, it is crucial that the books and records of each Group Company maintain comprehensive and accurate information about all transactions and expenditures incurred by the Company. This documentation should provide a clear record of what was paid, to whom, the purpose of the payment, where it was made, and when. Any attempts to create false or misleading records are strictly prohibited.

(b) Employees requesting approval for a payment must furnish sufficient supporting documentation to facilitate authorization of the payment.

11) Conflict of Interest

All employees and officers of the Group must refrain from engaging in any situation where their personal interests conflict with the interests of the Group. This encompasses transactions involving securities of the Group, any affiliate, or any non-affiliated organization, as well as dealings with suppliers (including service providers), customers, and other third parties.

12) Reporting

Unless prohibited by applicable law, employees are required to report any violations of this Code or relevant laws (e.g. the Singapore Prevention of Corruption Act and other applicable anti-bribery laws) following the procedures outlined in the Mun Hean Whistle-Blower Policy. Appropriate disciplinary measures, such as suspension or termination of employment, will be implemented if an employee is found to have breached the rules of conduct outlined in this Code.

13) Review

Mun Hean will periodically review this Code. This review aims to ensure that the Group’s businesses are conducted with integrity and in accordance with ethical standards, safeguarding the interests of the Group and fostering a harmonious and ethical work environment for all employees.

Version 1.0 April 2024