All Employees shall adhere to the highest standards of behavior during their course of employment with the Company including:

• Honesty
• Integrity
• Respect for people
• Impartiality
• Transparency

Purpose

The purpose of this Code of Conduct is to describe the standards of behavior and conduct required from all Employees in their dealings with customers, suppliers, clients, co-workers, management, agents and the general public. All Employees shall observe the standards set out in this Code of Conduct at all times. Non-compliance with this Code of Conduct shall result in disciplinary action.

Scope

This Code of Conduct applies to all Employees including temporary and contract staff.

I. Professional Integrity

Employees must conduct all business dealings and relationships with honesty, integrity, respect and impartiality for others. Employees must loyally and faithfully carry out their duties and always deal fairly and honestly with customers and others with whom we do business. No Employee shall knowingly permit any transaction to occur through his or her offices that does not meet the Company Code of Conduct.

Relationships with customers, suppliers, competitors, and Employees are to be based on transparent dealing, with transparent competition in quality, price, service, and on compliance with applicable laws and regulations.

II. Bribes and Kickbacks

A. The Company does not permit bribes, kickbacks, or any other illegal, secret, or improper payments, transfers, or receipts. This prohibition applies both to the giving and the receiving of payments or gifts.

B. No Employee shall offer, give, or transfer any money or anything else of value for the personal benefit of any Employee or agent of another business entity for the purpose of:

• Obtaining or retaining any business that the business entity itself would not otherwise provide
• Receiving any kind of favored treatment that the business entity itself would not otherwise provide
• Inducing or assisting such Employee or agent to violate any duty to his employer or to violate any law.

C. No Employee shall misuse Company funds, including, without limitation, the misappropriation of such funds for the personal benefit of Employees of the Company, or customers.

No outside agent of any kind shall be used to circumvent the prohibition against bribes, kickbacks, and other illegal, secret, or improper payments. Fees, commissions, and expenses paid to outside agents must be based upon proper billings, accurate recordkeeping, and reasonable standards for services rendered.

III. Gifts and Entertainment

No Employee or any member of his or her family shall directly or indirectly accept any money, objects of value, gift, favor or concessionary offer from any organization, firm or individual that has or is doing or seeking business with the Company. All Employees must disclose unauthorized transactions, any gift, favour or concession received to Management. Providing excessive gifts or entertainment to others who may represent potential business is prohibited.

A. Employees may accept only business-related meals or entertainment when authorized by Management and when the value involved does not exceed SGD100/- and clearly will not create an obligation to the donor.

B. Any payments or transactions must be accurately recorded in the Company’s books and records and must be consistent with applicable law and accepted practice in the community.

IV. Protection and Use of Company Property

All Employees of the Company are responsible for protecting and taking reasonable steps to prevent the theft or misuse of, or damage to Company’s assets, including all kinds of physical assets, movable, immovable and tangible property, corporate information and intellectual property such as inventions, copyrights, patents, trademarks and technology used in carrying out their responsibilities. All Employees must use all equipment, tools, materials, supplies, and Employee time only for Company’s legitimate business interests. Company’s property must not be borrowed, loaned, or disposed of, except in accordance with appropriate Company’s policies. All Employees must use and maintain Company’s property and resources efficiently and with due care and diligence.

V. Confidentiality

A. Except as properly authorized by the Company, it is the responsibility of all Employees to maintain the confidentiality of:

• Proprietary information of the Company
• Information entrusted to the Company by principals or customers that is otherwise not readily available to the public.

B. Employees shall not discuss confidential Company business with outsiders or with anyone else who does not have a legitimate need to know the information. Employees shall refer outside enquiries regarding the Company to the persons in the Company authorized to respond to the particular inquiry.

C. Except as required by law and in the course of performance of duties, no Employee shall, without prior authority or approval from the management, disclose or divulge or make public any information.

D. Transactions of a confidential nature relating to the business of the Company or the affairs of its customers or other Employees, which may come to the Employee’s knowledge or possession in the course of his Employment shall not be divulged to a Third Party.

VI. Conflicts of Interest

A. No Employee shall use his or her position within the Company or information acquired during employment in a manner that may create a conflict, or the appearance of a conflict, between the Employee’s personal interests and those of the Company.

B. All activities conducted as an Employee of the Company shall always place the lawful and legitimate interests of the Company over personal gain.

C. Absent of written authorization by the Company, no Employee shall be affiliated with any buyer, purchasing agent, or provider of goods or services to the Company. Such affiliation generally is inconsistent with the Employee’s capacity to deal equitably with all buyers, to fairly and honestly service principals, and to discharge his or her responsibility to the Company.

D. No Employee shall engage in any outside employment or hold any position without the prior written consent from the Management. All outside appointments and activities (including business activities), directorships and employment must be declared and approved in advance. If Employees are considering accepting an external appointment, they must consider if accepting this position may give rise to the possibility of conflict. If they have been given permission to take such employment or to have other business relationships, they must ensure that these activities do not negatively affect their ability to fully and effectively perform their role for the Company or Company’s reputation and/or its services to customers or the Company’s current or future business plans.

E. If an Employee has any reason to believe there may be a conflict of interest, he or she shall immediately disclose the matter to an immediate supervisor or the Chief Executive.

Consequences of Non-Compliance with this Code

The obligations outlined in this Code prescribe and regulate the standards of conduct required of all Employees of the Company.

Where an Employee suspects a breach of the Code may have occurred, he or she shall seek advice from their Supervisor, Manager or Chief Executive.

An Employee whose conduct falls below the standards outlined in the Code will render the Employee liable to disciplinary action. Some breaches of this Code may also have consequences for Employees and other members of the Company under criminal or civil provisions of the general law.