Confidential

Code of Ethics and Standards of Conduct

Foreword

The Code of Ethics and Standards of Conduct (the “Code”) requires all directors and employees to
observe high standards of business and personal ethics in the conduct of their duties and
responsibilities. As employees and representatives of Straits Construction, or any of its subsidiaries,
employees must practise honesty and integrity in fulfilling their responsibilities and comply with all
applicable laws and regulations.

It is the responsibility of all directors and employees to comply with the Code of Ethics and Standards
of Conduct and to report violations or suspected violations such as:

• Criminal offences or failure to comply with legal obligations

• Unlawful conduct (fraud, corruption)
• Financial malpractice
• Breaches of codes of conduct
• Abuse to employees
• Disregard of safety rules
• Dangers to the public or the environment
• Any attempt to cover up any of the above

Code of E thics

Straits Construction’s fundamental ethical principles are:

➢ Each employee is responsible for the propriety and consequences of his or her actions.

➢ Each employee must conduct all aspects of company business in an ethical and strictly legal
manner and must obey the laws of the country.

➢ Employee conduct on behalf of the company with fellow colleagues, suppliers, sub-contractors,
the public and one another must reflect the highest standard of honesty, integrity and fairness.

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Standards of Conduct

Conf li ct of Int er e st

Each employee must be careful to avoid situations that might involve a conflict of interest or appear
questionable to others. In general, there are two major areas of concerns:

1. Participating in activities that conflict or appear to conflict with Straits Construction

responsibilities, and

2. Giving or receiving anything that might influence the recipient or cause another person to
believe that the recipient may be influenced – this includes offering or accepting bribes,
kickbacks, illegal payments, or gratuities.

Employees must avoid any actions or situations in which private interests or personal considerations
may affect an employee’s judgment in acting in the best interest of Straits Construction or that may
appear to involve a conflict of interest with it’s activities. These include any external appointments,
secondary employment, business, financial or other relationships with suppliers, customers or
competitors by Straits Construction employees, their close family, or their close associates outside of
Straits Construction.

P rot ect ion of St ra it s Con st ruc t io n P rop e rt ie s

Each employee has an obligation to safeguard and protect all Straits Construction data, company
properties, proprietary information and funds under their control against loss, theft and misuse.

S afe , P ro pe r an d P ro f es s ion al Wo rk En vi r onm ent

Each employee must maintain a safe, proper & professional work environment, illegal and
counterproductive actions will not be tolerated on Straits Construction premises at all times. Such
actions include possession or use of, or trafficking illegal drugs, alcohol abuse, gambling, fighting,
assault, endangering the life, health or safety or abuse of an employee.

Dat a, R e co rd s and R epo rt s

All employees are responsible for preparing all Straits Construction business documents as completely,
honestly and accurately as possible. These records include but not limited to timekeeping records,
expense reports, accounting records, test and progress reports, cost estimates, contract proposals, and
presentations to customers, the public or Straits Construction management, and any representation,
either written or oral, made by any employee or representative in the conduct of Straits Construction
business shall be factual, fully substantiated, and verifiable.

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Ma int ai nin g Conf id en t ia lit y

Each employee shall maintain strict confidentiality and proprietorship of all information pertaining to
Straits Construction and its associated company, learnt during the course of employment, and each
employee shall undertake not to share this information outside Straits Construction during or after
employment.

P rot ect ed D i sc lo su re

All employees have a responsibility to report any genuine concerns in a reasonable and responsible
way. If an investigation confirms that an employee has made a disclosure for malicious or vexatious
reasons this could lead to disciplinary action.

An employee who raised a genuine concern in accordance with this policy will not be at risk of any form
of retribution as a result provided that they acted in good faith. The individual should not be making the
disclosure for personal gain.

Straits Construction undertakes that no reprisals will be taken against individuals who raise genuine
concerns, and also guarantees the right for staff to keep their identity confidential.

Straits Construction will not tolerate harassment of any individual who does decide to report violations
or suspected wrongdoing. No director, officer or employee who has in good faith reports a violation of
the Code shall suffer harassment, retaliation or adverse employment consequence. An employee who
retaliates against someone who has reported a violation in good faith is subject to discipline up to and
including termination of employment.

Act ing in G o od Fa it h

Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in
good faith and have reasonable grounds for believing the information disclosed indicates a violation of
the Code. Any allegations that prove not to be substantiated and which prove to have been made
maliciously or knowingly to be false will be viewed as a serious disciplinary offence.

Conf id enti al it y

Violations or suspected violations may be submitted on a confidential basis by the complainant or may
be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the
extent possible, consistent with the need to conduct an adequate investigation.

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Rep or tin g Vi ol at i on s or S us pe ct ed W ro ng doing

If any employee has reasons to believe that a violation of these standards of conduct or any other
company procedures has occurred or is likely to occur, it is their obligation to contact the Senior
Management or Human Resource Department who shall:

• take all concerns seriously and investigate them

• recognize the difficulty the employee may have in raising them
• give the employee an unequivocal guarantee that where they raise concerns responsibly and
reasonably they will be protected against victimization
• seek advice from other professionals where appropriate
• support the employee throughout the process and maintain their anonymity within the company
as far as possible.

All reports shall be promptly investigated and appropriate action shall be taken and if warranted, the
Human Resource shall set up a Committee of Inquiry and keep the employee and Management
informed of the outcome.

Computer Use

Only licensed software will be used on the Company’s computers. All users are given a specific
password to get into the network system. The password must not be placed around the computer
and should not be given to any other person except with prior approval by Management. No users
are allowed to modify any system files. No users are allowed to install any software in their
computers without authorization of the Management.

I have read and understand the above contents as spelt out and I shall undertake to comply accordingly.

Accepted By

Myo Min Zaw 5.7.2023

…………………………………… …………………………………..
Name of Employee Signature/Date

STRAITS CONSTRUCTION SINGAPORE PTE LTD

Code of Ethics and Standards of Conduct

Confidential