10.

0 EMPLOYEE'S CODE of CONDUCT

10.1 BASIC POLICY

To establish and maintain co-operative and harmonious working relationships among
all management and employees based on mutual respect and understanding and
upon a common interest in achieving the Company’s objectives. These working
relationships must be based on good bilateral communications within the Company
and by exercising sound managerial and supervisory practices.

EM Pizarra Construction believes that maintaining a high level of discipline is

essential in order to ensure safe and efficient operations. It also believes in the rapid
ventilation of grievances at all levels and in their humane and just resolution to the
satisfaction of both the Company and the employees concerned.

10.2 RESPONSIBILITIES
10.2.1 LINE MANAGERS AND SUPERVISORS
a. It is the responsibility of all line managers and supervisors to create co-
operative and harmonious working relationships with their employees.
b. They should be aware of their supervisory responsibilities and of the
Company’s policies and procedures.
c. They should also help their employees to understand their responsibilities and
obligations, and to feel free to discuss their problems in an open and
reasonable manner.
d. It is essential that managers and supervisors develop the habit of
communicating with their employees on a regular basis.

10.2.2 EMPLOYEES
It is the responsibility of all employees to work to the best of their abilities, to try to
improve their work performance and productivity, to understand their
responsibilities and obligations and to comply with the Company’s rules and
regulations.

10.2.3 HUMAN RESOURCES DEPARTMENT

It is the responsibility of Human Resources Department to:

a. Provide advice and assistance to line managers, supervisors and employees

to on employee relations and grievances issues.
 b. Ensure compliance with grievances and corrective guidance procedures.
c. Recommend to General Management such new policies and procedures or
changes to existing ones, in the field of employee relations, as may be
necessary.
d. Responsible for maintaining relevant records / documentations of employee’s
grievances.

10.3 HARASSMENT POLICY

EM Pizarra Construction is committed to providing a work environment that is free
of discrimination. In keeping with this commitment, the Organization maintains a strict
policy prohibiting all forms of harassment of any person for any reason, including
race, sex, colour, religion, age, disability or veteran status. Furthermore, it prohibits
harassment in any form including verbal, physical, and visual harassment.

10.4 SEXUAL HARASSMENT

Sexual harassment refers to behaviour which is personally offensive, which will
undermine the dignity and modesty of a person, which debilitates morale, and
therefore interferes with work effectiveness and mental status of a person. EM
Pizarra Construction will not tolerate sexual harassment and such behaviour, as
defined below, is strictly prohibited. Furthermore, any retaliation against an individual
who has reported sexual harassment, or retaliation against individuals for
cooperating in an investigation of a sexual complaint will not be tolerated. Employees
covered under this policy include individuals working at a EM Pizarra Construction
facility, other assigned locations, on business travel or socializing for business or
corporate sponsored events.

Quid pro quo harassment is defined as “visual / gestures / unwanted sexual

advances, oral or otherwise, requests for sexual favours, and other verbal or physical
conduct / abuse of a sexual nature" when submission to such conduct is made either
explicitly or implicitly a term or condition of an individual's employment or is used as
the basis for employment decisions affecting such individual. Quid pro quo
harassment involves someone in a supervisory capacity, or position of influence over
another employee, who can confer or withhold a tangible employment benefit and
can use his discretion based on the employee's response to sexual advances,
requests for sexual favours, or physical conduct of a sexual nature. Such sexual
harassment includes harassment by an individual of the same gender.
Hostile or offensive work environment harassment is defined as a conduct which has
the purpose or effect of unreasonably interfering with an individual's work
performance or creating an intimidating, hostile, uncomfortable or offensive work
environment due to sexual advances, gender based animosity, or a sexually charged
workplace. Hostile or offensive work environment harassment does not involve a
direct sexual bargain between a supervisor and subordinate, as in quid pro quo
harassment, but includes any form of sexually oriented harassment that is sufficiently
severe to alter the conditions of the victim's employment and create a hostile or
offensive work environment. Hostile or offensive work environment sexual
harassment can involve supervisors, co-workers and even non-employees such as
client representatives, visitors, contract labourers, consultants, vendors, and other
third parties who interact with employees based on a business relationship with the
Organization.

Conduct involved in sexual harassment includes:

10.4.1 VERBAL HARASSMENT

e.g., epithets, derogatory comments, slurs, kidding, teasing, jokes commenting
about another's body or appearance, offensive sexual flirtations, sexual advances
or propositions, gender based comments and ridicule, inquiries into one's sexual
experiences, and personal life discussion of one's sexual activities, threats, insults,
name calling, whistles or catcalls, sexually explicit or offensive language.

10.4.2 PHYSICAL HARASSMENT

Assault, stalking, staring, trick or horse play, impeding or blocking movement, physical
contact such as patting, pinching, hugging or brushing against another's body

10.4.3 VISUAL AND NONVERBAL FORMS OF HARASSMENT

e.g., derogatory posters, SMS, MMS, sexually oriented cartoons or drawings, the
display of sexually suggestive objects or pictures, such as calendars / emails and
screen savers, or demeaning graffiti, demeaning or sexually suggestive gestures.

10.4.4 REQUESTS FOR SEXUAL FAVOURS

Sexual advances / oral or otherwise which condition an employment benefit upon an
exchange of sexual favors.
10.5 CONFLICTS OF INTEREST
It is the responsibility of each employee to avoid situations involving not only conflicts
of interest, but also situations which give the appearance of a conflict. In complying
with this basic policy, it is expected that employees will not:

a. Have any direct or indirect personal financial interest in EM Pizarra Construction

operations.
b. Participate in or influence the purchase of goods or services from an organization
in which they may, directly or indirectly, have a financial interest
c. Accept gifts, cash or other items of any kind, except those associated with usual
business practices and courtesies of a nominal value from any person or
business entity which is involved in any way with Citiscape. Any activity on an
uncustomary nature and those that are not in line with usual business practices,
must be reported to and approved by the management
d. Utilize the Company’s funds for unlawful purposes
e. If an employee is misusing his / her position in the Company for the acquisition or
acceptance of bribe or personal benefits from Company employees or outsiders,
he / she at the 1st offence shall be dismissed without notice and benefits and
without prejudice to proceedings of Public Prosecution. If an employee does not
abide by the policies related to conflict of interest (listed above), he / she, at 1st
offence, shall be dismissed without notice and benefits.

10.6 CONFIDENTIALITY

All employees must observe strict secrecy in respect of EM Pizarra Construction

business contacts and their commercial affairs and should not use, divulge or
communicate any such information to third parties. This applies both during and after
the term of employment with EM Pizarra Construction. Upon termination,
employees must ensure that all records are returned to the office. All employees
shall be subject to disciplinary actions in cases of confidentiality violation; as follows:
a. Providing information & forms related to Company without permission
b. Divulging any secret of Company.
10.7 STAFF UNDERTAKING OTHER WORK

a. EM Pizarra Construction staff is not allowed to undertake full or part-time work

without approval from the management. However, it is recognized that staff
members might be asked to undertake duties of an honorary or semi-honorary
nature. This should not interfere with the performance of duties for EM Pizarra
and details of posts held should be notified to the management.
b. Employees are expected to achieve high level of expertise at EM Pizarra
Construction and as a result may be asked by EM Pizarra Construction to
provide advice to third parties on a consultancy basis. Offers of consultancy work
should be notified to the management for approval prior to acceptance. In
accepting consultancy work, staff will be expected to ensure that the work
undertaken does not conflict with EM Pizarra Construction objectives or
interfere with the performance of their responsibilities within EM Pizarra
Construction.
c. All employees shall be subject to disciplinary actions in cases of unauthorized
undertaking of other work.
10.8 HEALTH, SAFETY & ENVIRONMENT (HSE) POLICY

HSE performance is an integral part of the Company’s business and HSE matters
will be treated with the same priority as other primary business objectives. The
Company is strongly committed to provide a safe and healthy work environment
to all employees. The employee shall abide by all Safety rules and regulations
declared by the Company and wear personal protective equipment in the
designated areas and maintain all items issued to the employee by the Company.

10.9 NON-SMOKING POLICY

To ensure the continuing success of the Company’s Health Safety & Environment
Policy, A No-Smoking policy is introduced to provide a healthy working
environment for our employees. As an eco-friendly move, the Company has
adapted a No-Smoking policy within the areas specified but not limited to below:
 Shared enclosed offices
 Open-planned work areas
 Half-height partitioned cubicles
 All Company Vehicles.
 Lavatories
 Stairways
 Rooftops
 Corridors

10.10 INTOXICATION
Illegal possession of alcoholic beverages or drugs within the Company premises
/ work sites / vehicles and / or if an employee is found in a state of drunkenness
or under the influence of drugs during working hours are unlawful and shall be
subject to disciplinary action.

10.11 DRESS CODE

Employees are expected to adhere to a business like dress code at all times
during working hours, to preserve the Company’s image as a professional
organization.
10.12 DISCIPLINARY POLICY & PROCEDURES

A high standard of discipline is essential to encourage improvement of

employees’ performance, attendance, maintaining and achieving standards of
conduct and ensuring consistent and fair treatment of employees. Each case
must be investigated thoroughly before disciplinary action is taken. The employee
must be aware of the nature of his / her offence and in case of repetition, what
sort of discipline will be taken against him / her.

Disciplinary action must be taken as soon as possible after the offence has been
committed, taking into consideration the following:
a. Investigation should start immediately, but not later than 30 days from the
offence is known to the Company, otherwise the case would have lapsed and
no further action can be taken
b. From the date of completion of investigation, no action can be taken after the
lapse of 60 days
c. The employee will have the right to appeal against any disciplinary action.
d. All warnings issued will be retained in the respective employee’s file for a
period of one year.

10.13 INITIAL ACTIONS

a. Departments/ Subsidiaries Heads are responsible for the conduct of their

subordinates during working hours. He / she may be required to verbally warn
those with minor offences immediately and inform HR in writing.
b. In case the offence requires as disciplinary action more than a verbal warning,
the Department / Business Head shall immediately inform the offenders that
further investigation will take place and further disciplinary action may be
taken.
c. Line Managers / Supervisors shall report the incident / offence to his
Department Head in writing. The Department Head will arrange for
investigation.
d. In certain cases, when the offence is serious the employee may be
suspended from work on the day the incident is reported to authorities
concerned, in case of:
 Strike.
 Assault of another employee or damage to Company property.
  During the suspension period the employee shall not be entitled to any
remuneration. If it is proved that the employee is innocent, he / she should
be paid all his / her remuneration for the suspension period. Warning Letter
may be issued.

10.14 INVESTIGATION
a. Investigation should be carried out by the Line Manager in the presence of HR
(Investigation Committee)
b. It is important to give the employee every opportunity to defend him / her and
explain his / her point of view.
c. The Investigation Committee will prepare a final report with proper
recommendation.
d. If dismissal is recommended, a Disciplinary Committee should be formed to
study the case. The Disciplinary Committee members are as follows:
i. HR Operations Manager (or his representative).
ii. Department Head.

10.15 FINAL ACTION

10.15.1 ORAL / VERBAL WARNING
a. The Line Manager / Department Head shall inform the employee officially.
b. The Line Manager shall report the case to HR to update records and filing.

10.15.2 WRITTEN WARNING

1. HR Department shall prepare the Warning Letter for HR Operations
Manager Signature based on the Investigation Committee Report.
2. HR Department shall hand it over to the employee.
3. The employee must sign the Warning Letter.
4. Line Manager shall explain to the employee the seriousness of the
offence and the reason why the warning is issued, and will explain to
him / her next course of action is case of repetition.
10.15.3 SUMMARY DISMISSAL
Procedure is the same as above. Careful consideration of the Committee’s
recommendation should be taken into account. The Department Head shall
initiate the termination form and forward it for General Manager’s signature.

10.16 EMPLOYEE GRIEVANCE

A grievance may arise when an employee believes that his/her status, benefits or
entitlements have been adversely affected by an incorrect or inappropriate
decision or behavior. All grievances must first be submitted through the
established management channels before referring them to any authority for
consideration. Grievances shall normally be resolved promptly and at the lowest
management level possible. All grievances and the records of the proceedings
shall be kept confidential. Accurate records detailing the nature of grievance,
management’s stand and the action taken shall be maintained.

10.16.1 PROCEDURE
STEP 1 A verbal or written grievance may be submitted by the grievant to the
immediate supervisor. The supervisor shall:
 Assess the grievance and verify the facts
 Discuss the grievance with the employee and provide him / her
an answer
 Ensure it is resolved satisfactorily within Twenty (20) working
days
 Prepare a written report on the nature of grievance and the
action taken
STEP 2 If the grievance or complaint is not resolved to the satisfaction of both
the immediate supervisor and the employee, the latter may present the
matter to the next management level for consideration. The department
manager will take all of the above steps and also inform the Human
Resource on the proceedings and actions taken.
STEP 3 Normally, a decision rendered at Step 2 shall be considered final.
However, at the lack of a satisfactory conclusion, the issue can be
referred to the Department Manager / GM for reconsideration. The
Department Manager / GM may decide to interview the employee or
arrange for the Human Resources Manager to do so on his behalf. As
in the previous steps, a summary report on grievances appealed to the
Department Manager shall be maintained by the Human Resources.
10.17 EXCLUSIONS
If the grievance is an issue concerning the Manager authorized to hear or give a
decision on a grievance, the matter shall automatically be referred to the next
higher level.

10.18 DISCIPLINARY CODE

(Table No. 16 "Disciplinary Code")

Disciplinary Action
Category Type Of Offence
4th
1st Offence 2nd Offence 3rd Offence
Offence
1  Minor negligence Verbal Written warning Final written Termination
 Minor infringements of reprimand with loss of warning with
regulations increment & loss of
promotion increment &
promotion

2  Leaving job without 1st written 2nd written Final written Termination
permission warning with warning with warning with
loss of loss of loss of
 Poor time-keeping increment and increment & increment &
 Infringement of Company ’s promotion promotion promotion
time keeping & attendance
policy & procedure

3  Disorderly behaviour on Written Final written Discharge

duty or in Company warning with warning with
premises. loss of loss of
increment & increment and
 Insolence promotion promotion
 Malingering
 Negligence resulting in
minor damage to Company
property
 Absence without
permission or good excuse
for less than 7 days
 Misuse of Company
property
4  Unauthorized interference Final written TERMINATION
with plant or equipment warning with
loss of
 Petty theft increment &
 Abuse of a supervisor or promotion
colleague, likely to provoke
assault
 Careless driving of a
Company car
 Absence without
permission or good excuse
up to 20 intermittent days
during one year or up to 7
consecutive days
 Infringement of Safety or
other published regulations
which could lead to minor
accident, injury, damage or
loss of Company property
 Failure to carry out or obey
specific instructions or
standing instructions
related to work
 Indecent behaviour.
5  Violating the safety TERMINATION
instruction of work or the
place of work
 Absence without a valid
reason for more than
twenty intermittent days
during one year or more
than 7 consecutive days.
 Sleeping during work in
cases where continued
attention is required
 Failure to carry out basic
duties under the contract of
employment and
continuing to commit such
breach despite being
warned
 Committing an error
causing substantial
material loss to the
Company provided that the
Labour Department is
notified of the incident
within 48 hours from the
time when the Company
 learns of its occurrence.
 Selling alcohol
 Caught with illegal
possession / influence of
alcohol
 Quarrelling under the
influence of alcohol

6  If an employee is found not TERMINATIO

suitable during or end of N with no end
probationary period of service
indemnity and
 Divulging any of the without notice
secrets of the Company period.
 Final conviction by a
competent court in an
offence of breach of
honour, honesty or public
morals
 If found during working
hours in a state of evident
drunkenness or under the
influence of drugs
 Committing an assault
during work against
supervisor or colleague
 Assuming false identity,
personality or nationality or
submitting forged
certificates or documents
 Breach of Conflict of
Interest Policy

10.19 DOCUMENTS & RECORDS

 Warning Letter
 Disciplinary Action Form