HEALTH, SAFETY & ENVIRONMENT POLICY

SERIKANDI GROUP OF COMPANIES (SKG) recognises the social and economic importance of protecting the health and safety of all employees, contractors, visitors and others who may be affected by the conduct of our operations, and in minimising the environment impact, of our operations, and is committed to lead by example in promoting health and safety, and good environmental practice, in all of our operations.

SERIKANDI GROUP OF COMPANIES (SKG) is responsible for:

• Provision and maintaining a safe and healthy work environment at all our workplaces.
• Setting HSE objectives, targets and goals annually and to be reviewed by management at the required intervals to measure our performance, to achieve excellence in our results and to continually improve our HSEperformance.
• Complying with all applicable HSElaws, rules and regulations.
• Eliminating hazards and reducing HSErisks through establishing HSErisk assessments on a regular basis.
• Seeking the support of our employees or representatives, to participate in the development, planning, implementation, performance evaluation and actions for improvement of the HSE management system.
• Communicating and making this policy available to all levels of the company, contractors, associates, affiliates and those interested parties as appropriate.
• Provide education and training to our employees so that they have the knowledge, skills, and understanding to perform their responsibilities and duties as expected.
• Encourage everyone to promptly report non-compliance or unsafe conditions and to take immediate action to prevent injuries or environmental accidents.
• Protecting workers from reprisals when reporting incidents, hazards, risks and opportunities.
• Routinely review and verify performance through audits, performance reviews and evaluations and implement actions to allow for continual improvement of the HSEmanagement system.

All employees, contractors and visitors are responsible for adhering to the policy, and are expected to understand that they are individually responsible for their own health and safety and of those arou nd them.

All employees, contractors and visitors and others who are affected by our operations, are encouraged to intervene and stop any unsafe acts and conditions, and to report hazards and near misses.

Violation of this policy will be cause for disciplinary action up to and including termination of employment.

• In our endeavors, we strive to pursue quality management practices that are designed to enrich the quality of life for its employees, develop them to their fullest potential and maximize their productivity levels in all aspects of the work involved
• Our levels of understanding for the needs of our employees aim to ensure fairness and equality as well as complete and utter transparency in all our dealings with our employees
• Serikandi strives to continuously foster a climate of openness, mutual trust and teamwork in order to ensure that the end product, which is the delivery of services to our customers, is not compromised

Serikandi Employment Policy

• Serikandi is fully committed to provide an efficient and reliable service to all its clients. The company’s basic approach in order to deliver service of high quality and standard involves the recruitment of highly trained and qualified personnel. Once employed, the company expects them to remain with Serikandi for the rest of their career life. The following are major points in Serikandi’s Employment policy.
• Priority is given to the employment of suitable Bruneian Citizens who possess the right qualification and experience. Regional staff will only be recruited as contract basis, and provisions are made for the positions to be replaced once a suitable candidate is obtained.
• Serikandi provides its employees with opportunities to progress. Training and courses are given to staff to encourage and motivate them to develop to more responsible position.
• Serikandi is a service – obtained business and expects its employees to possess a high degree of discipline, courtesy and show genuine interest to the Company’s customers
• The most important obligation of Serikandi is the maintenance of safe operation coupled with the appreciation of the need to protect the health of the customers by providing good nutrition in conditions of absolute sanitation. Serikandi expects all employees to abide by rules and regulations governing the above HSE principles.

Localization

As part of the effort of the Government of His Majesty the Sultan and Yang Di-Pertuan of Brunei Darussalam to facilitate the sustainable development of capabilities, competencies and competitiveness, Serikandi Group of Companies is participating to support the industry within Brunei by maintaining and promoting Bruneisation in the Corporate Group for an overall minimum of 70%, thus, providing job opportunity, job allocation and on the job training. In order to do so, HR Department has to maintained regular channel of communication with all Government agencies to ensure that we adopt and comply with the Local Law & Legislation.

Government agencies:-

• PMO
• Labour Department
• APTK
• Immigration Department
• EICF/ IBTE Program

The Department heads is responsible to maintain the local employment target for their respective department.
Priority for employment should be given to qualified Bruneian and Permanent Resident.
All employees are engaged under a written contract of employment specifying the position, the contract period, basic salary and other terms and conditions as per Brunei Labour Law.

In Serikandi, We:

• Comply with all relevant quality standards and International codes
• Review of Specifications, Procedures and specified standards utilized on the construction site
• Prepare ITP Documents
• Prepare Fabrication & Installation Procedures
• Prepare Final Dossier
• Engineering Services
• Construction Services
• Electrical & Instrumentation Services
• Installation & Commissioning services
• Assure the quality of all Equipment, materials, structures, components and systems utilized in the construction, manufacturing and operation of all types of Industrial facilities
• Materials Inspection & Welding Procedure Qualification and witnessing , Internal Audit & Sub-contractors Audit
• Benefit from Quality assurance and Quality control (QA/QC) both off-site at manufacturers’ facilities and on-site during the construction process
• QAQC of the organizations involved in the construction, manufacture and operation of your facility
• Factory acceptance tests of installations and equipment’s
• Pre-shipment inspections and loading supervision during the transportation phase
• Monitoring storage methods and preventive maintenance systems of plant equipment before and during installation

Definition of Bribery and Corruption

Bribery is defined as the offer or the acceptance of a financial or other form of benefit intended to encourage or influence the recipient of the benefit to act improperly or unfairly in the award of business or in the execution of their duties . Corruption is defined as dishonest or fraudulent conduct by those in power, typically involving bribery. Bribery and Corruption could include the following:-

• Paying individuals with authority or influence over the award of business in order to influence them to make an award in favour of the giver or his organization .
• Exchanging expensive gifts or providing extravagant entertainment to individuals with the intention of influencing the award of business to the giver or his organization.
• Making charitable donations to a third party or their family member(s) and/or close associate(s) with the intention of unfairly influencing the award of business to the giver or his organization.
• Accepting payments or other inducements from third parties, including joint venture companies, consortium partners, third party agencies, vendors, suppliers, subcontractors and any other entities which carry out business with SERIKANDI in order to award business or grant another benefit to them
• Manipulating SERIKANDI procedures to award a contract to a specific sub-contractor, service provider and/or vendor in return for some form of payment or other benefit.
• Offering payments or other forms of benefit, whether directly or indirectly, to any government official, officials of the clients or third parties.

Scope

The policy applies to all personnel employed by SERIKANDI, joint venture companies, consortium partners, third party agencies, vendors, suppliers, subcontractors and any other entities which carry out business with SERIKANDI.

• No briberv or corruption: SERIKANDI does not engage in bribery or corruption. It is contrary to the Company's policy for any employee or third party acting on behalf of SERIKANDI to request, offer, solicit, make or receive any payments or inducements which are illegal, unethical or represent a breach of trust.
• Ethical, Professional and Legal Standards: All employees are required to strictly follow SERIKANDl's Business Integrity and code of Conduct policy which details the Company's commitment to ensuring that its business is conducted in all respects according to rigorous ethical, professional and legal standards.
• Compliance with law: SERIKANDI respects all laws relevant to countering bribery and corruption in all the jurisd ictions in which the Company operates, particularly laws that are directly relevant to specific or local business practices. Appropriate legal advice is sought as necessary.
• Compliance Committee: The Compliance Committee is responsible for establishing this policy within SERIKANDI, supported by an appropriate corporate culture which prohibits bribery and corruption
• Reporting requirement: All Employees are encouraged, without fear of retaliation, to report if they observe any violation of Company policy, rule, regulation, etc. as part of this policy as well as Company's Business Integrity and Code of Conduct Policy. If any employee believes that the terms of this policy are not being correctly adhered to, they should bring this to the attention of their immediate Supervisor at once and the supervisor in turn will forward it to the compliance committee so that necessary actions can be taken.
• Consequence Management: Any concerns raised by any person relating to any alleged non­ compliance with the terms of this policy will be immediately investigated. The Compliance Manager will report to the Compliance Committee any such concerns and the outcome of any investigations conducted into such issues. The compliance committee will take appropriate disciplinary action which may include dismissal from employment and may expose individuals to civil or criminal proceedings.

Objective

SERI KANDI Business integrity policy sets out the mandatory rules and regulations in respect of human rights, anti-corruption, improper payments and fraud. The purpose of the policy is to secure that all of SERIKANDI business operations are conducted in an ethical manner and in compliance with applicable laws and regulations .
The policy applies to all personnel employed by SERIKANDI, joint venture companies, consortium partners, third party agencies, vendors, suppliers, subcontractors and any other entities which carry out business with SERI KANDI.

• Local and Foreign Laws: We must comply with the laws and regulations of the country that apply to us wherever we do our business. Bribery and facilitating payments: We win business on the strength and quality of our service offerings. We do not directly or indirectly give gifts or other valuables to any government officials, officers or employees of the clients, third parties or suppliers in order to obtain a business advantage, and likewise, our employees do not accept gifts or entertainment from anyone in return for business or personal benefits. Kickbacks: A kickback is an illicit payment made to someone in return for facilitating a transaction or in exchange for services rendered. We expressly prohibit our officers, employees or representatives, suppliers and sub-contractors from Providing, attempting to provide, or offering to provide any kickback and Soliciting, accepting, or attempting to accept any kickback.
• Conflicts of interest: Conflicts of interest exist when an employee is in a position to influence a decision that could result in a personal gain for the employee, a relative, or a close friend. We must avoid any activity which may give rise to a conflict of interest. We make all business decisions objectively, not on the basis of any individual employee's personal benefit or advantage.
• Political contributions: We will not make any political contributions in order to obtain an unlawful business advantage. SERIKANDI shall comply with all public disclosure requirements.
• Philanthropic contributions: We may make contributions only for bona fide charitable purposes and only when permitted by the laws of the country in which contribution is made. No contributions shall be made for getting an unlawful benefit to the business.
• Extortion: We shall reject any direct or indirect demand by any one for pecuniary or other advantage to act or refrain from acting in relation to his or her duties.
• Gift, hospitality and entertainment: We shall avoid offering or receiving any gifts, meals, entertainment, hospitality or payment of expenses whenever these could materially affect the outcome of a business transaction, or are not reasonable and bona fide expenditures or are in violation of the laws of the country of the recipient.
• Books of accounts and financial statements: The employees are required to keep accurate and proper books and accounting and other records which give a true and fair view of the financial position, results of operations, transactions, assets and liabilities of the company. These documents must be maintained in accordance with applicable generally accepted accounting principles and SERIKANDl's own internal controls and accounting procedures. The employees must never do anything that compromises the integrity of the company's books of account and financial statements.
• Zero tolerance policy: We do not tolerate any practice that is not borne of honesty, integrity and fairness, anywhere we do business. We do not tolerate the direct or indirect offer, payment, solicitation or acceptance of bribes in any form. Facilitation payments are also prohibited. We will refrain from doing business with parties who have demonstrated unethical business practice.
• Communication training and internal control: Any changes to the policy will be communicated to all concerned and we will organize periodical training and awareness of business integrity to all levels of employees. Internal control shall be performed on all levels in the company. The Internal audit team shall perform audit within business Integrity, the result of audit will be presented to senior management.
• Reporting requirement: If you believe that SERI KANDi's Business integrity and code of conduct policy has been breached or there is a possibility of breach, you should report it to your immediate supervisor or line manager and the supervisor or line manager shall report it to the senior corporate management . Everyone is encouraged to report it without fear that your employment or any other benefits from the company will be adversely affected. We are committed to providing our employees with the resources and support to achieve these standards of business integrity. All reports should be made in good faith and be properly documented. Reports of suspected violations will be treated seriously and whistle-blowers confidentially will be maintained to the fullest extent possible. Employees making such reports will not be subject to retaliation, threats or harassment, and their identity will be held in confidence to the extent permitted by law.
• Consequence Management for Violation of this policy: All employees are responsible for understanding and complying with this policy and with all other applicable SERIKANDI policies. Failure to abide by this policy or other policies may result in investigations and which will result in disciplinary action up to and including termination of employment in accordance with local laws. If any Clients, Joint venture partners, third party representatives, suppliers or subcontractors of SERIKANDI violate this policy, it may result in termination of any existing contract/agreement or business with such party who violates the policy.
• Declaration: You must declare all gifts and hospitality given or received for /from Government Officials or other third parties, clients, subcontractors or vendors any gifts and hospitality that could be perceived as influencing or creating a Conflict of Interest, and declined gifts of cash or of an excessive nature, including personal items.
• Co-operate with Government Authorities: We will fully support and co-operate with local government or its institutions agencies or authorities to prevent corruption and to build integrity in business environment.

Definitions

Conflict of Interest:

A conflict of interest may occur if an interest or activity influences or appears to influence the ability of an individual to exercise objectivity or impairs the individual's ability to perform his or her employment responsibilities in the best interests of SERIKANDI.
An individual is considered to have a potential conflict of interest when:

• He or she or any member of his or her immediate family may receive a financial or other significant benefit as a result of the individual's position at SERIKANDI.
• The individual has the opportunity to influence granting, business, administrative, or other material decisions in a manner that leads to personal gain or advantage; or
• The individual has an existing or potential financial or other significant interest which impairs or might appear to impair the individual's independence in the discharge of their responsibilities to SERIKANDI.

Immediate family:

A member of one's Immediate Family means:

• Spouse
• A Child grandchild, parent, grandparent, brother, sister, uncle, aunt, nephew, niece or the spouse of any such person
• A person having a step-relationship described above
• Parents-in-law, brothers-or sisters-in-law, sons- or daughters-in -law
• Any person who resides in the same household as you

The policy applies to all personnel employed by SERIKANDI, joint venture companies, consortium partners, third party agencies, vendors, suppliers, subcontractors and any other entities which carry out business with SERI KANDI.

• Avoid Conflicts of Interest wherever possible: All employees of SERIKANDI should avoid conflict of interest where ever possible.
• Withdraw from decision-making Employees should withdraw themselves from any decision making that creates, or could be perceived to create, a Conflict Of Interest.
• Disclose Conflicts of Interest: Avoiding a conflict of interest may not always be possible or practical. An Employee who cannot avoid a conflict of interest must disclose it. If you believe you have a potential conflict involving a family member or other individual, disclose it to your manager .
• Do not use your position to get favoured treatment: Employees should not use their position at SERIKANDI to obtain favoured treatment for themselves, their family members, or others with whom they have a significant relationship. This applies to purchases, hiring, promoting, selecting contractors or suppliers, and any other business matter.
• Reporting requirement: All Employees are encouraged, without fear of retaliation, to report if they observe any violation of Company policy, rule, regulation, etc. as part of this policy as well as Company's Business Integrity and Code of Conduct Policy. If any employee believes that the terms of this policy are not being correctly adhered to, they should bring this to the attention of their immediate Supervisor at once and the supervisor in turn will refer the matter to the compliance committee so that necessary actions can be taken .
• Consequence Management: Any non-compliance this Policy will not be tolerated and can lead to disciplinary and other actions up to and including termination of employment.

Scope

The policy applies to all personnel employed by SERIKANDI, joint venture companies, consortium partners, third party agencies, vendors, suppliers, subcontractors and any other entities which carry out business with SERIKANDI.

• No offer/Giving or Acceptance with the intention to influence : Hospitality, Gifts and entertainment should never be offered or accepted with the intention to influence - or appear to influence - business decisions or relationships in any way. Hospitality, Gifts and entertainment, offered or received, will only be acceptable if they are:
  • Reasonable
  • Appropriate
  • Legal
  • Not intended to influence
  • Provided in accordance with this policy
• Exclusions I Exceptions: Promotional items of insignificant value, of an advertising nature, an occasional business meeting meal, or other items of smallvalue may be accepted. Gifts outside of these guidelines would be deemed unacceptable and shall be declined, or returned if already accepted.
  SERIKANDI employees can accept the following:
  • A plaque or an award.
  • Items of insignificant value that are given to everyone (such as pen, pencil,diary, key chains, T-shirts, coffee
  • mugs, bags).
  • Information materials that are provided by vendors to everyone (such as booklets, audio or video tapes).
  • An occasional business meal. Repetitive mealtime meetings should be discouraged.
  • Meals associated with pure entertainment, where SERIKANDI business in not being discussed, are not considered
  • business meals.
  • Festival (Hari Raya, Chinese New Year) gift baskets or food may be accepted if shared with other employees.
• No cash: Employees may not give and/or receive gifts of cash (including gift cards) to/from customers, suppliers, or government officials under any circumstances.
• Declaration: Employees should declare any form of hospitality, gift or entertainment offered/given or received irrespective of value in the form provided.
• Reporting requirement: All Employees are encouraged, without fear of retaliation, to report if they observe any violation of Company policy, rule, regulation, etc. as part of this policy as well as Company's Business Integrity and Code of Conduct Policy. If any employee believes that the terms of this policy are not being correctly adhered to,they should bring this to the attention of their immediate Supervisor at once and the supervisor in turn will refer the matter to the Compliance Committee so that necessa ry actions can be taken.
• Consequence Management :Any non-compliance this Policy will not be tolerated and can lead to disciplinary and other actions up to and including termin tion of employment.

Definitions

• Retaliation: Retaliation occurs when an employer takes an Adverse Action against an employee because she/he engaged in a Protected Activity.
• Adverse Action: Adver se action includes, but is not limited to Demotion; Suspension; Termination; Failing to hire or consider for hire or promotion; Failing to give equal consideration in making employment decisions or to make impartial employment recommendations; adversely impacting working conditions or otherwise denying any employment benefit to an employee; Creating a hostile or intimidating work environment.

The policy applies to all personnel employed by SERIKANDI, joint venture companies, consortium partners, third party agencies, vendors, suppliers, subcontractors and any other entities which carry out business with SERIKANDI.

• Protection for concerns raised in good faith: All employees are prohibited from retaliation even if the concerns raised are not confirmed following an investigation. However, an employee may be subject to Adverse Action if the employee knowingly made a false allegation, provided false or misleading information in the course of an investigation, or otherwise acted in bad faith.
• No Exemption for Own Misconduct: This anti-retaliation policy does not exempt employees from the consequences of their own misconduct or inadequate performance, and self-reporting such issues is not Protected Activity.The policy also does not prevent SERIKANDI from managing employee performance and addressing conduct issues after an employee has engaged in Protected Activity, so long as Protected Activity is not the reason for the performance management.
• Obligation to Raise Concerns: All employees are required to report any suspicion of improper or wrongful activity. Reports of suspected improper or wrongful activity will be treated confidentially.
• Consequences for Policy Violation: Employees who believe they have either witnessed retaliation or been personally retaliated against or that any other violation of this policy has occurred, must immediately notify the Compliance Committee. Any employee who retaliates against an employee engaged in a Protected Activity or who otherwise violates this policy is subject to disciplinary action, up to and including termination of employment.