1. The terms, conditions and procedures in this handbook supersede those published earlier.
   


2. The company reserves the right to review and change any terms, conditions or procedures contained in this handbook as it deems fit. Changes will be communicated to employees through normal company channels e.g. notice boards, e-mails and the handbook will be updated as and when necessary.


3. This handbook is the property of the Company and must be kept properly by the respective Department Head for staff reference purpose.


4. If you have any further questions or require clarification on any item, please contact the Human Resource Department.

In line with our HR values, our remuneration adhered to the relevant minimum wages laws and regulations and is competitive and fine-tuned to meet staff needs. We also have the following practices to offer and reward you:

• Best Employee Award, Best Salesperson Award, Best Company Award & long service award.


• Training and development programs to grow and enrich our staff talents and skills.


• Performance-based bonus, & sales commission.


• Extra incentives for achieving company KPIs. Local and Overseas Incentive Trips. Employee Share Options have been offered to staff to nurture a greater sense of ownership within the Beshom Group of companies.


• Hire & Purchase loan, and personal loan with discounted rate for staff.


• Group Personal Accident and Hospitalization & Surgical Insurance Scheme.


• Sport Club organizing sporting and social events to bond relationship between staff, family and community.

We strive to upload ethical labour standards including avoiding and preventing all forms of child labour, forced labour and trafficked labour as well as excessive working hours. We do not discriminate against anyone based on race, religion, gender, age, disabilities and nationality. Employees are not governed by any restrictions to freedom of association and collective bargaining.

During or at the end of the probationary period, the Company may offer in writing permanent employment to those employees who are, in the opinion of the Company, suitable for employment with the Company, or

The Company is entitled to not confirm those employees who, in the opinion of the Company are unsuitable without having to offer any reasons or details for such decision.

For female employees, culottes, shorts, 'hot pants' or revealing dresses are also not to be worn in the office.  The following dress code shall applies:

• Confirmation of a probationary employee
• Merit / Promotion appraisal
• Annual merit appraisal

In-house training may be provided from time to time as Management deems fit. Employees may also be sent for external training programs or courses whenever necessary. These employees may be required to serve the Company under a bonding contract for a period that is to be determined by the Company.

Should the employees for whatsoever reason terminate their service with the company during the bonding period, they shall be liable to refund to the Company all training costs and allowances incurred.

Employees are advised to refer to the Training Department on training policies and procedures.

The rest periods of employees may be staggered or changed to accommodate the company operations.

Employees may be required to work overtime on normal working days, rest days or public holidays. Employees shall not refuse the Company's request to work overtime without justifiable and acceptable reason.

Employees who wish to undertake overtime work must obtain prior approval from their department manager or supervisor before overtime work is undertaken.

1. Employees with salary up to RM4,000 and below
2. Production & warehouse supervisor, executive and Manager with salary up to RM4,000 and below
3. Production and warehouse manual worker with salary up to RM4,000 and below

All sales personnel, executive (grade 7) & managerial level employee are not entitled to overtime claims but replacement leave will be granted accordingly.

Employees attending training after working hours or on rest days or public holidays are not allowed to claim overtime as training is viewed as part of their career development.

Note
Employees are allowed to carry forward their annual leave not more than 5 days to the following year.

• Emergency cases
• Availability of panel doctors e.g. on Sundays or public holidays, if Company's panel doctors are closed.
• Distance and reasonable travelling time involved.

An employee must immediately inform his department manager or supervisor when a medical practitioner or dentist grants him sick leave. He must also forward the medical certificate to his department manager or supervisor within 48 hours of commencement of such sick leave. If he fails to notify or forward the medical certificate to his department manager or supervisor, he will be deemed to have breached his contract of employment.

Employees taking excessive sick leave may be required to undergo a thorough medical check-up. If the employee is found to be unfit, he may have his employment terminated on medical grounds. If the employee is found to be fit, counseling will be given. If the situation persists, disciplinary action will be taken against the employee.

An employee who reports to the Company panel doctor or a registered medical practitioner for purpose of treatment or otherwise, and who is subsequently not granted sick leave shall report for duty as soon as possible after completion of the visit, failing which shall be treated as absent from work. In such cases, the employee is required to submit the time slip (shows the time of the visit) issued by the company panel doctor or registered medical practitioner to his department manager.

• Employee is hospitalized or
• Employee is deemed ill enough to be hospitalized but is not, for any reason whatsoever as certified by a medical practitioner.
  

Employee shall be entitled to sixty (60) days paid leave per calendar year (including rest days and public holidays).

The Company's responsibility is limited to payment of premium for the insurance policy. In event of an accident resulting in injury for which benefits may be payable, the Company will assist the employee concerned or his legal representatives to make a claim under the policy. The benefits are only available if the same are payable under the policy, and the Company is not liable to pay any benefits not paid by the insurers due to whatever reasons.

If the Company has to incur expenses such as medical, funeral and repatriation expenses, as a result of the accident, the Company is entitled to deduct such expenses from the benefits received from the insurance company.

The insurance coverage and insured categories are as follows:

• Emergency cases
• Availability of Company’s panel doctors e.g. on Sunday or public holiday, if the company’s panel of doctors are closed
• Distance and reasonable travelling time involved
  

• TCM Practitioner of Hai-O Raya Chain Store and Peking Tongrentang only.
• General dental treatment (limited to four (4) claims a year)
• Health screening (limited to one (1) claim a year and must support with medical report)
  

# Medical claim for immediate family is also applicable to General Manger, Assistant General Manager and head of company.
* immediate family members refers to spouse & children of age 18 years and below.

• Use or influence of drugs, alcohol and any other intoxicating substances
• Sexually transmitted diseases, AIDS and related illnesses or conditions
• Medical expenses incurred in maternity, confinement or miscarriage or abortion
• Surgical, dental treatment (orthodontic, related treatment for beauty purpose)
• Beauty treatment and plastic surgery
• Circumcision
• Mental cases
• Self-inflicted injury, injury / illness due to fighting, illegal / immoral activities, dangerous sports / activities, indulgence and intemperate behavior, lack of reasonable care and self-discipline.
• Conditions, illness and diseases existing at the time of joining the Company

All reimbursement must be submitted to HR Department and supported with original receipt and medical report. Reimbursement limit is as below:

• Flower bouquet/ fruit basket cost not more than RM150/= during staff visitation period.
• Company products value not more than RM120/=

On the demise of the employee, bereavement aid of RM1,000 will be granted by the Company to the next-of kin.

Probation employee will not be entitled to any bereavement aid but will be granted one (1) day compassionate leave.

• Marriage Leave - three (3) consecutive working days on occasion of employee's first marriage.
• Paternity Leave
  - Eligible male employees will be entitled to 7 consecutive days of Paternity Leave (up to 5 confinements)/ irrespective of number of spouses.
  - Concerned staff shall notify employer on the pregnancy of his spouse at least 30 days from the expected confinement or as early as possible after the birth.
  - Employee is required to submit child’s birth certificate to HR department as a supporting document to apply the leave.

Probation employee will not be entitled to any marriage gift but will be granted one (1) day marriage leave.

A copy of proof document is required for the above entitlement.

10 years' service- long service plaque and RM1,500/=
20 years' service- long service plaque and RM3,000/=
25 years' service- long service plaque and RM4,000/=
30 years' service- long service plaque and RM6,000/=
35 years' service- long service plaque and RM8,000/=
40 years’ service-long service plaque, RM10,000/= and watch or Hai-O Cash Voucher or one (1) Smart Gadget with value of RM 2000/=
45 years' service- long service plaque and RM12,000/=
50 years’ service -long service plaque, and RM 13,000/= and Hai-O Cash Voucher or one (1) Smart Gadget with value of RM 2000/=

Terms and conditions of the loan schemes can be obtained from the mentioned companies.

Approval by the department manager is required before using own vehicle or public transport on company's business and for the amount of reimbursement claim.

Employee (excluded Salesperson) granted Petrol Card/ Traveling Allowance is not entitle for mileage reimbursement.

Employees can claim last month reimbursement on first week of each month. Late submission will be rejected.

Reimbursement for accommodation per night shall be as per actual expenses or as per below recommended rate. If the room rate exceeds the recommended range, staff must provide valid reasons and get approval from superior.

General Manager, Assistant General Manager and those of job grade 1-3 is entitled to single occupancy accommodation for both local and overseas official travelling.

Outstation allowance is payable based on below category of employees. This allowance is not applicable to employees of Grade 1, 2, and 3.

1. Travelling made above 70km radius from the resident address of the salesperson.
2. Must attached sales/collection generation report to qualify for claims.
3. For outstation based salesperson travelling to Head Office for official matter such as meeting or training is excluded.
4. Company reserves the absolute right to reject claims that is without supportive valid reasons.

Managers who are travelling to ASEAN countries must travel by budget airline. If the manager needs to travel by non-budget airline, please provide justification and obtain approval from superior.

However the purchase quota is controlled at the discretion of the Management.

The Company will also contribute on 1:2 basis based on the total monthly contribution to the club.

1. Manager
2. Non manager
3. Branches/ Outlets (Hai-O Raya chain stores & Sahajidah Hai-O Marketing's branches)

1. What are the employee outstanding performances
2. How does the employee exemplify the company's corporate value
3. How does the employee performance contribute to the company

1. A paid overseas trip arranged by the company
2. Computer or smart gadget price NOT more than RM 2,500/=
3. Hai-O cash vouchers worth RM 2,500/=

1. Sales growth rate (%)
2. Gross profit growth rate (%)

1. A paid overseas trip arranged by the company
2. Computer or smart gadget price NOT more than RM 2,500/=
3. Hai-O cash vouchers worth RM 2,500/=

1. Company Vehicles
2. Petrol Card
3. Mobile Telephone
4. Computer Notebook
5. Tools and Equipment

Once the Company's property issued to employees' it is the responsibility of the employees to take good custody and care until they are returned to the Company.

Any discovery of loss, damage or stolen Company's property must be reported to the Management immediately. The employee shall bear the cost of any loss, damage or stolen Company property due to carelessness or ignorance.

1st occurrence

• A written record will be served to the employee
• Employee is to bear the summon charges, if any
• Compensation for damages on company vehicle shall be waived

2nd occurrence onwards

•  A written record will be served to the employee
• Employee is to bear the summon charges, if any
• Employee is to bear compensation for damages on company vehicle not exceeding RM300 in total.

1. Observe strictly all safety rules and regulations;
2.  Always use safety equipment and apparatus when required.
3. Report any unsafe conditions and fire hazards immediately to the Company;
4. Report injuries regardless of degree in the Company premises immediately to the department manager or supervisor, the Human Resource Department.

1. Security guards are authorized to check all employees including their car entering or leaving the Company.
2. The Company reserves the right to conduct body search on any employee whenever necessary.

All employees are required to give their full cooperation to the Company security guards.

Employees shall not be permitted entry into or shall be ordered to leave the Company's premises if he commits the following acts or falls into the following category:

1.  Carrying firearms or any dangerous weapons or substance.
2. His personal attire being in an unhygienic state which may affect the health and work of other employees.
3. Suspended from work.
4. Acting in an irresponsible manner which is detrimental to the reputation or maybe harmful to the Company or prejudicial to the order of good discipline and conduct.

All employee records and salaries are regarded as confidential. Employees are not to divulge such information to another employee or any other persons.

1. Dismiss the employee without notice;
2. Demote the employee;
3. Suspend the employee from work without payment of wages for a period not exceeding two (2) weeks; or
4. Impose any other lesser punishment, as the Company deems just and fit such as warning letter, deferment / withholding bonus or increment or reduction of salary.

1. That might on reasonable grounds, be perceived by the recipient as placing a condition of sexual nature on his/her employment (sexual coercion i.e. usually a superior having the power over salary and promotion attempts to coerce a subordinate to grant sexual favors) or
2. That might, on reasonable grounds, be perceived by the recipient as an offence or humiliation, or threat to his / her well being, but has no direct link to his / her employment (sexual annoyance i.e. by an employee against a co-employee or company's client against an employee).

1. at work related social functions
2. in the course of work assignment outside the workplace
3. at work-related conferences or training sessions
4. during work-related travel
5. over the phone
6. through electronic media

1. Verbal harassment
   e.g. offensive or suggestive remarks, comments, jokes, jesting, kidding, sound, questioning.
2. Non verbal or gesture harassment
   e.g. leering or ogling with suggestive overtones, licking lips, holding or eating food provocatively, hand signal or sign language denoting sexual activity, persistent flirting.
3. Visual harassment
   e.g. showing pornographic materials, drawing sex-based sketches or writing sex-based letters, sexual exposure.
4. Psychological harassment
   e.g. repeated unwanted social invitations, relentless proposals for dates or physical intimacy.
5. Physical harassment
   e.g. inappropriate touching, patting, inching, stroking, brushing up against body, hugging, kissing, fondling, sexual assault.

However, if the accuser or any party is found to have made false accusations or evidence, they will be liable to disciplinary action up to and including dismissal.

The decision on the matter, made by the Executive Director shall be final.

1. Change of address or telephone number
2. Marital status and spouse particulars
3. Particulars of children
4. Acquisition of new educational or professional qualifications

Only notices approved by the department manager can to be displayed on the notice board.

All staff is welcomed and encouraged to fully utilize this benefit. All suggestions received will be kept strictly confidential. The best suggestion of the year will received a gift from the Management.

1. The Beshom Group adopts a zero-tolerance approach towards bribery and will not pay bribes to anyone for any purpose.
2. The Group takes the upholding of its anti-bribery stance across the Group’s business seriously and expects the same from stakeholders internal and external to the Group’s businesses, extending to all the Group’s business dealings and transactions in all countries in which it operates.
3. Directors, Employees, suppliers, Distributors, Business Associates, and any third parties working with, for or on behalf of the Group shall adhere to and observe the Group's anti-bribery stance and relevant provisions, policies, and procedures established by the Group.
4. The Group treats any violation of this Policy seriously and will undertake necessary actions, including, but not limited to, review of employment or appointment, disciplinary actions, dismissal, cessation of business relationship, and reporting to the authorities, consistent with the relevant laws and regulations.
5. The Group is committed to comply with the relevant anti-bribery laws and regulations, breaches or violation of which may cause great damages to the Group which may include reputational damage, legal fines, or even jail sentences.

1. "bribery" refers to the act of corruptly authorising, giving, agreeing to give, promising, offering, soliciting, receiving, or agreeing to receive any gratification;
2. "gratification" shall have the meaning as defined in the Malaysian Anti-Corruption Commission Act 2009, i.e.:
3. where this Policy refers to the act of "giving" or "paying" a bribe it also refers to actions amounting to the act of agreeing to give, promising, or offering a bribe;
   
   
   1. money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;
   2. any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
   3. any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;
   4. any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;
   5. any forbearance to demand any money or money’s worth or valuable thing;
   6. any other service or favour of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and
   7. any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f);
   
   
   
4. where this Policy refers to the act of "receiving" a bribe it also refers to actions amounting to the act of soliciting or agreeing to receive a bribe;
5. "facilitation payments" shall have the definition consistent with that provided by Transparency International, which is: a small bribe, also called a 'facilitating', 'speed', or 'grease' payment, made
6. to secure or expedite the performance of a routine or necessary action to which the payer has legal or other entitlement;
7. "Employees" include full-time, part-time, probationary, contract and temporary employees;
8. "Service Providers" include the Group's contractors, sub-contractors, consultants, distributors, agent representative, or any parties performing work or services for or on behalf of the Group;
9. "Business Associates" include the Group's joint-venture entities, joint-venture partners, associate companies, and business partners, as well as Service Providers;
10. "Officer of a Public Body" shall have the definition as provided in the MACC Act 2009; and
11. "Foreign Public Official" shall have the definition as provided in the MACC Act 2009.

• the Group is expecting to be audited by, or to apply, obtain, or renew a licence, permit, approval, audit report or any other types of clearance (generally referred to as the "Clearance") from the Authority in the near future; or
• the Group has just applied, obtained, or renewed a Clearance (including the issuance of an audit report) from the Authority in the recent past.

• the Group is expecting to apply, obtain, or renew a Clearance from the said Authority in the near future; or
• the Group has just applied, obtained, or renewed a Clearance from the said Authority for the Group's business activities in the recent past.

• general complaints about the Group’s products or services;
• matters which are trivial or frivolous or malicious or vexatious in nature or motivated by personal agenda or ill will;
• matters pending or determined through any tribunal or authority or court, arbitration, or other similar proceedings.

1. A whistle-blower may make the Disclosure either in writing (including email) or orally.
2. A whistle-blower shall include the basis or reasons for his/her concerns including as many details as possible in relation to the Disclosure. However, A whistle-blower is not expected to obtain substantial evidence of proof beyond reasonable doubt when making a Disclosure.
3. The whistle-blower has the right to remain anonymous when making a Disclosure. However, it is usually easier to conduct a more effective and fair investigation if he/she could identify himself/herself and disclose as much information as possible within his/her knowledge.
4. First Contact Point
   
   
   1. If the whistle-blower is an employee of the Group, his/her first contact point shall be his/her direct superior or line manager. However, for any reason, if it is believed that this is not possible or not appropriate, he/she may report to the Head of Group HR, as follows:
      Head of Group HR: Jessica Lim
      Office No.: +(603) – 3342 3322 ext. 513
      Email: jessicalim@beshom.com
   2. If the whistle-blower is a distributor of the Group, he/she shall make the Disclosure to the SHOM Compliance Unit, via the following email: COE@shom.com.my.
   3. If the whistle-blower is neither an employee nor a distributor of the Group, he/she shall make the report to the Head of Group HR.
   
   
5. Prescribed Persons
   
   If a whistle-blower believes that it will be inappropriate to report to the First Contact Point, the whistleblower can make the Disclosure to any of the Prescribed Persons, as follows:

   Prescribed Persons	Group Managing Director	Group Executive Director
   Name	Mr. Tan Keng Kang	Mr. Hew Von Kin
   Office No.	+(603) - 3342 3322, Ext:518	+(603) -3342 3322, Ext:515
   Email	GrpDir@beshom.com

   
   For any Disclosures made via email to the Prescribed Persons, the email shall be addressed to the dedicated whistle-blowing email provided above, which is accessible by all Prescribed Persons.
   
   For any Disclosures made via phone calls, orally, or in writing, the Prescribed Persons are generally required to inform each other of the Disclosure.
   
   If the Disclosure issue involves any of the Prescribed Persons or any Directors, it shall be made to the Independent Directors of the Group, in accordance with Item 3(f) below.
   
   
6. In the case where making a Disclosure to management is a concern, then the report may be made directly to the Chairman or the Audit Committee Chairman, who is an Independent Director of Beshom, as follows:
   
   

   	Chairman, Senior Independent Director	Audit Committee Chairman
   Name	Mr. Ng Chek Yong	Dato' Lee Teck Hua
   Email	ngcy@beshom.com	leeth@beshom.com

   
   
7. Any persons who receives a verbal Disclosure in accordance with Paragraph 3(d), (e), or (f) above shall put in writing the Disclosure and its details which is to be confirmed by the whistle-blower.

1. In addressing any Disclosures, depending on the seriousness of the alleged Wrongdoing, the relevant authorities within the Group shall decide on how the Disclosure shall be handled, including investigation, enquiries, and deliberations on the outcome.
2. All alleged Wrongdoings involving fraud or bribery shall be notified to the Audit Committee, who shall have the authority to designate any person, within the Group or external to the Group, to oversee and conduct relevant investigation.
3. All alleged Wrongdoings involving a Director or a Prescribed Persons shall be escalated to the Audit Committee, who shall handle the Disclosure, including investigation, enquiries, and deliberations on the outcome.
4. In general, an independent party, which may be the internal audit, an external independent auditor or professional, or an Independent Director, shall always be involved in an investigation process.
5. Any person, including Directors if any, who are related to or involved in the alleged wrongdoing concerning the Disclosure shall be excluded from the investigation, recommendation, and deliberation procedures to ensure the objectivity and independence of the Disclosure handling process.
6. All Disclosures received and handled by the First Contact Point and Prescribed Persons are required to be summarised in a report to the Executive Risk Committee, at least once in a year.

1. A whistle-blower shall be informed of the status of his/her Disclosure, including the outcome of the deliberation, as far as reasonably practicable, in writing.
2. The alleged wrongdoer, which may include the whistle-blower in the event the whistle-blower is implicated or discovered to be involved in the allegation, may be asked to attend a meeting to discuss the allegations and he/she shall take all reasonable steps to attend the meeting. He/she shall be given an opportunity to answer the allegations at the meeting which shall be minuted.
3. If an investigation is conducted on a whistle-blower who is implicated or discovered to be involved in the allegation, it shall not be treated as a reprisal against the whistle-blower but a facilitation of factfinding and decision making.

1. Every effort will be made to protect and keep confidential a whistle-blower's identity, subject to relevant legal constraints.
2. A whistle-blower shall be protected from reprisal within the Group as a direct consequence of a Disclosure made in good faith. A reprisal refers to any disciplinary actions, which may include a warning or letter or reprimand, demotion, loss of merit, loss of bonus, suspension without pay, or termination of employment. Any such reprisal against the whistle-blower shall be consider a serious breach of this Policy.
3. If a whistle-blower reasonably believes he/she is being subjected to harassment, victimisation, reprisal as a direct consequent of having made a disclosure under this Policy, he/she may reach out to higher authority as provided in Paragraph 3(e) or (f) above. Essentially, the complaint shall be processed in a similar manner as a whistle-blowing Disclosure.

• Act honestly, diligently and in good faith when discharging and performing duties and responsibilities;
• Act honestly, diligently and in good faith when discharging and performing duties and responsibilities;
• assist company to promote and maintain a good, safe and healthy working environment;
• Contribute towards achieving the Company's objectives to the best of your abilities, while making decisions consistent with the Code;
• consult your superior or HR department manager if you have any questions about the Code.

• act promptly and in good faith by raising it with your superior and such breach or violation remain confidential before a full investigation is conducted. The authorized personnel will investigate the matter promptly;
• take your concern beyond your superior to Managing Director or Executive Directors if the suspected breach you have reported was not resolved;
• report directly to Group Chairman if the possible breach involves any member of the Board and keep Audit Committee informed;
• be prepared to cooperate in the investigations regarding violation of the Code.

• his/her immediate supervisors/ managers or higher authorities along his/her reporting line; or
• the Head of Group HR, the Group Executive Director cum Chief Financial Officer, or the Group Managing Director if the supervisors/ managers mentioned above are not applicable or contactable.

• lead by providing a model of high standards of ethical conduct, creating a positive work environment reflecting the content and the spirit of the Code;
• be vigilant in preventing, detecting and responding to any violations of the Code;
• protect those who report violations.

• All gifts and entertainment given or received shall be in accordance with the Group's Policy on Gift, Entertainment, and Hospitality.
• You may accept gifts that are appropriate to the business relationship.
• When you receive gifts, you should report to your superior or may be required to handover the gifts to the Group Admin Department for company use or as a lucky draw gifts for staff whichever purpose that may deem fit. And such receipt shall be properly recorded by Group Admin Department.
• Customary business entertainment such as lunch, dinner, or sporting events, is appropriate if it is made known to the superior and of a reasonable nature, and its purpose is conducting business discussions or fostering better business rapport.

• Keeping electronic and paper documents and files containing confidential information in a safe place;
• Not discussing confidential matters where they could be overheard, for example, in public places such as elevators, hallways, restaurants, etc.
• Transmitting confidential documents by fax or e-mail, only when it is reasonable to believe this can be done under secure conditions;
• Restrict from using confidential documents as recycled papers; and
• Shredding off documents instead of disposing in dustbin once the documents need to be discarded.

• To give first consideration to the objectives and purchasing policies of the Company;
• To strive to obtain the maximum value for each ringgit of expenditure;
• To support the principle of fair competition as a basis for selecting suppliers and awarding business to suppliers (minimum two quotations must be sought for making fair comparison);
• To fully comply with the internal purchasing process of purchase requests and purchase orders when awarding business to a supplier. No purchase will be done without a properly authorized Purchasing Order;
• To authorize Purchasing Order within the approved purchase limit;
• To make every reasonable effort to negotiate an equitable and mutually agreeable settlement of any controversy with a supplier.

• Act honestly, professionally and in good faith when discharging and performing duties and responsibilities;
• Ensure due diligence is observed when disseminating financial or relevant information that is accurate, complete, timely and understandable in reports and documents that Beshom files with, or submits to, government agencies, securities commission, Bursa Securities and in other public communication;
• Refrain from directly or indirectly taking any action to fraudulently influence, coerce, manipulate or mislead persons preparing the financial statements or to otherwise take any action directly or indirectly that would cause such financial statements to be materially incorrect or misleading;
• Ensure that the company's accounts and reporting complied with applicable approved accounting standard in the country it operates;
• Give due consideration to assessing the quality of financial controls, including internal controls over Financial reporting, as well as to implementing control improvements;
• Ensure that the professional competences and skills are maintained at a level that is consistent with the responsibility of their job, with due observance of requirements from professional bodies.

• Our objective is to conduct our business in the safest possible manner consistent with the Occupational Safety & Health Act, and any other applicable legislation.
• Employees at every level, including management are responsible and accountable for the Company's overall safety initiatives.
• Complete and active participation by everyone, everyday in every job is necessary for the safety among all workers on the job site.
• An injury and accident-free workplace is our goal.

1. I have read and fully understood the contents of Beshom Group’s Code of Ethics & Business Conduct, including the Group's Anti-Bribery Policy and specific policies referred therein.
   
   
2. I shall at all times comply with Code of Ethics & Business Conduct laid down being essential for the proper conduct of my employment with the Group.
   
   
3. I shall continue to abide on the code of confidentiality (item 10) of the Code of Ethics & Business Conduct after termination of my employment with the Group.
   
   
4. I declare that, to the best of my knowledge: (tick whichever is applicable)
   (   ) I am not aware of any conflicts that I have with the Group, its personnel, or its business.
   (   ) apart from the conflicts declared below, I am not aware of any other conflicts that I have with the Group, its personnel, or its business.
   

   	Name of Conflicted Party (actual, potential, and perceived)	Relationship with Conflicted Party	Nature of Conflict of Interest Situation with the Beshom Group and Detailed Description (e.g. shareholdings, directorships, or close family member relationship)
   ( i )
   ( ii )
   ( iii )
   ( iv )

   I agree to notify the Beshom Group, as soon as practicable, on any emerging or new actual, potential, or perceived conflict of interest situations arising.
   
   
5. I declare that: (tick whichever is applicable)
   (   ) I have never been convicted of any crimes or offences, other than traffic offenses (if any).
   (   ) I have been convicted of the following crimes or offences, other than traffic offenses (if any).
   
   
   
6. Failing to comply with the Clauses 2, 3, and 4 above, the Group has the right to undertake any disciplinary action against me for serious misconduct including suspension or dismissal or even legal actions.

All directors, employees and personnel of Beshom Holdings Berhad and its subsidiaries and associate companies (“BESHOM Group” or “Group” or “Company”) have a duty of maintaining the confidentiality of information received by them in the course of their employment or engagement. This Confidentiality Policy stipulated the confidentiality and non-disclosure duties and obligations of the directors, employees and personnel of BESHOM Group.

The directors, employees and personnel of BESHOM Group will, in the course of their employment and engagement, become aware of and possess information of the Group or of third parties disclosed to the Group that is not generally known. This may include information which if disclosed could jeopardise the interests of the BESHOM Group. It may also include commercial trade secrets disclosure of which could harm the interests of the Group.

All directors, employees and personnel of the BESHOM Group have a duty to keep such information strictly confidential and to use it only for the proper purposes in accordance with the law.

The purpose of this Confidentiality Policy is to lay down the principles that must be observed by all who work with the BESHOM Group and have access to confidential information.

This policy, where relevant, should be read in conjunction with the appointment letter and/or employment contract applicable to directors, employees and personnel, and other work rules, policies and procedures applicable to BESHOM Group directors, employees and personnel.

Confidential information includes any information which is not publicly known. It can concern technology, business, finance, transaction or other affairs of a company. It includes information which is commercially valuable such as the Group strategic proposals, business plans, trade secrets, trading terms with suppliers & customers or business information on products costing & profit margin, as well as personal information.

Examples of confidential information include but are not limited to: any document, discovery, invention, improvement, patent specification, production procedures, designs, know-how marketing and sales data, formulations, plans, ideas, books, accounts, data, reports, drafts of documents of all kinds, correspondence, client information, lists and files, decisions, product information, import and export, information about employees, strategies, drawings, recommendations, office precedents, policies and procedures, forecast, budget and financial information in any form, i.e. physical, electronic, electro- magnetic or otherwise, whether in written, oral or electronic form prepared by BESHOM Group, that given the nature of the information or circumstances surrounding its disclosure, would reasonably be considered Confidential Information, regardless of whether it is identified as being “Restricted Information” at the time of disclosure.

Confidential information to do with unpublished inventions or design that can be particularly sensitive. For instance, disclosure of an unpublished information invention or design before a patent application is filed will cause irreversible loss of intellectual property rights to the owner of the invention or design. Even after a patent application is filed, care must be taken not to disclose improvements to the invention or design. Trade secret protection will also be lost through open disclosure of the secret.

BESHOM Group expects all of its directors, employees and personnel to handle all confidential information in a sensitive and professional manner. The Group directors, employees and personnel are under an obligation not to gain access or attempt to gain access to information which they are not authorised to have. The Group, however, recognises the importance of a transparency culture with clear communication and accountability. The BESHOM Group wishes to maintain personal and organisational safety and expects all directors, employees and personnel to handle confidential information in a way which protects organisational security.

The purpose of confidentiality is essentially two fold. Firstly, it protects sensitive or confidential information of the Group and its stakeholders, suppliers, business associates, clients and customers. Secondly, in order for the Group to be effective, BESHOM Group directors, employees and personnel must be able to share information and knowledge, and therefore confidentiality is necessary as a condition of trust.

The best protection against breaches in confidentiality is to keep the number of employees and personnel who have access to sensitive information to a necessary minimum.

Intentional, repeated, accidental, or unauthorised disclosure of any confidential information by any member of staff will be subject to disciplinary action. Any such disciplinary action will take account of the confidential and possible sensitive nature of the information and will make sure that in dealing with it, no further breaches of confidentiality take place.

• must keep confidential all confidential information;
• may use confidential information solely for the purposes and in performing their duties as a director and employee of the BESHOM Group; and
• may only disclose confidential information to persons who are aware that the confidential information must be kept confidential and who have a need to know (but only to the extent that each person has a need to know).

• all confidential information in material form;
• those parts of all notes and other records in whatsoever form, based on or incorporating confidential information;
• all copies of confidential information and notes and other records based on or incorporating confidential information; and
• all copies of confidential information and notes and other records based on or incorporating confidential information; and

The obligation of maintaining confidentiality and non-disclosure will continue even after the end of the period of employment or engagement in respect of all confidential information.

Any directors or employee found to be in breach of this confidentiality and non-disclosure obligation, whilst employed by the BESHOM Group will be disciplined, and in serious instances, dismissed. Any ex-employee found to be in breach of this confidentiality obligation may be subject to legal action being taken against them, dependent upon the circumstances of the breach, including cancellation / withdrawal of any or all benefits if extended to the ex-employee by the Company.

This policy will operate in conjunction with the contract of employment or letter of appointment for BESHOM Group directors, employees and personnel.

Confidential information is only to be disclosed on a "need to know" basis, and only when the information is necessary to the director or employee for performing his or her employment duties effectively.

7.1 Subject to “need to know” basis, the confidential information including the data generated from the Group Internal Information System to be disclosed only when prior authorization been obtained:-

1. With the approval of the head of company or his/her reporting superior (with job grading not lower than grade 4) for a particular purpose;
2. With the approval / authorization by the Group Managing Director / Group Executive Director:
   • For information containing a wider scope of confidential and sensitive data;
   • For employees of job grading 4 and above.

The BESHOM Group director or employee must be able to justify any decision when information has been disclosed.

• (i) It is at the date of disclosure or thereafter becomes public knowledge through no fault of the disclosing Party (providing that in doing so the disclosing Party shall not disclose any Confidential Information which is not public knowledge);
• (ii) It can be shown by the disclosing Party to the reasonable satisfaction of the other Parties that the Confidential Information has been known to it prior to the Confidential Information being disclosed by the other Parties to the disclosing Party.

No written document containing confidential information must be left visible where it can be read by anyone. This includes telephone messages, computer prints, letters and other documents. All hardware containing confidential information must be exercised a reasonable degree of care and stored / saved in a secure environment.

Employees should also exercise caution to avoid misusing or unintentionally disclosing confidential information. This includes keeping electronic and paper documents and files containing confidential information in a safe place; and transmitting confidential documents by e-mai or through other electronic means or mobile devices only when it is reasonable to believe this can be done under secure conditions;

• Restrict from using confidential documents as recycled papers; and
• Shredding off documents instead of disposing in dustbin once the documents need to be discarded.

This Confidentiality policy shall be periodically reviewed taking into consideration the needs of the Group as well as any development in rules and regulations that may have an impact on the discharge of one duties and responsibilities.

1. Failure to obey reasonable order or lawful instruction.
2. Loitering.
3. Late attendance for duty without reasonable excuse.
4. Ceasing work before the proper finishing time.
5. Any action contrary to company operating procedure.
6. Absence without prior leaves.
7. Absence without doctor's sick certificate.
8. Interfering with another person's work or distrubing others during working hours.
9. Failure to clock in and out the office / factory.
10. Inciting or aiding another employee to commit any of the above offence.

1. Negligence of duty.
2. Sleeping whilst on duty.
3. Smoking in places where smoking is prohibited.
4. Any immoral act within the Company's premises.
5. Reporting for duty in an intoxicated state.
6. Threatening to cause physical harm or injury to other employee or their families or intimidation of whatever nature.
7. Causing or instigating discontentment employees against the Company or its officers.
8. Refusal to submit to a search when instructed.
9. Holding unauthorized meeting in the Company's premises.
10. Under police detention or imprisonment for criminal or subversive acts / offences.
11. Engaging in any forms of gambling or dart games whether for money or not.
12. Willful insubordination.
13. Unreasonably refusing to work overtime or to work on rest day or public holidays when instructed.
14. Willful slowing down of work or inciting other to do so.
15. Inciting or aiding another employee to commit any of the above offences.

1. Gross negligence resulting in damages to the Company's properties or financial losses.
2. Stealing company's products or properties, or misappropriation of Company's funds.
3. Stealing another person's properties within the Company's premises.
4. Riotous, disorderly behaviour, fighting or assaulting another employee within or outside the Company's premises.
5. Interference and sabotaging with the lawful administration of the company.
6. Clocking in or clocking out for another employee.
7. Conduct within the Company premises, which is likely to endanger the life or safety of any person or cause damage to property.
8. Assaulting a superior officer within or outside the Company's premises.
9. Disclosing the Company's commercial or manufacturing secrets or calculations or designs to any unauthorised person.
10. Falsification, defacement, or destruction of any record of the Company.
11. Acceptance of bribes, and kick-backs to act contrary to the Company.
12. Inciting or aiding or abetting another employee to commit any of the above offences.

1. Any other offences that are committed and not listed here shall be dealt with in accordance with the seriousness of the misconduct.
2. All Heads of Departments, Executives, and Supervisors are authorised personnel to initiate the appropriate disciplinary action for the enforcement of the discipline and to receive and deal with grievances appropriately.
   

LIST OF COMPANY'S PANEL DOCTORS

The purpose of this Email and Internet Usage Policy is to outline the guidelines and rules for using the company’s email and accessing online resources while connected to the organization's network or using company-owned devices. This policy aims to ensure the security, integrity, and professional use of the company’s email and internet. This policy also aims to promote a productive and respectful work environment while safeguarding the organization's assets and reputation.

This policy applies to all employees, contractors, consultants, and any other individuals who have used the company’s email and access to the organization's network or use company-provided devices to access the internet.

Email and internet usage are permitted for work-related purposes, including research, communication with colleagues and clients, accessing online tools or services relevant to the job duties, and other activities directly related to official responsibilities.

1. 4.1  Engaging in any activity that violates local, state, national, or international laws and regulations is strictly prohibited.
2. 4.2  Accessing, downloading, or sharing any illegal or pirated software, copyrighted materials, or confidential information is strictly prohibited.
3. 4.3  Visiting or accessing inappropriate, offensive, or explicit content, including websites promoting violence, hate speech, discrimination, or harassment, is strictly prohibited.
4. 4.4  Using the Internet for personal financial gain, commercial ventures unrelated to the organization, or any unauthorized business activities is prohibited.
5. 4.5  Participating in online gaming, gambling, or engaging in other non-work-related recreational activities is not allowed during work hours.
6. 4.6  Uploading or distributing malware, viruses, or any malicious software is strictly forbidden.
7. 4.7  Bypassing network security measures, attempting unauthorized access to other systems or accounts, or any activity that compromises the organization's security is prohibited.

1. 5.1  Email accounts provided by the organization are designated for official communication purposes related to work responsibilities.
2. 5.2  Exercise discretion and professionalism in all email communications, ensuring adherence to the organization's code of conduct and policies.
3. 5.3  Do not use email for transmitting sensitive or confidential information unless authorized by the management. All confidential business documents attached must be password protected.
4. 5.4  Refrain from forwarding chain letters, spam, or any unauthorized mass emails that could compromise the organization's network or reputation.
5. 5.5  Avoid using the organization's email for personal correspondence or violate any other sections of this policy.
6. 5.6  Regularly review and manage emails to maintain mailbox efficiency.
7. 5.7  Report any suspected phishing attempts, suspicious emails, or security threats promptly to the MIS department.

1. 6.1  Employees are responsible for protecting sensitive information and data while using the company’s email and internet. This includes not sharing sensitive information with unauthorized individuals or storing it in insecure locations.
2. 6.2  Use strong passwords for all online accounts, and refrain from using the same password for work and personal accounts.
3. 6.3  Exercise caution when clicking on links or downloading files from unknown or suspicious sources.

1. 7.1  Exercise caution when posting on social media or engaging in any online discussions related to work matters.
2. 7.2  Do not disclose confidential or proprietary information about the organization, its clients, or colleagues without proper authorization.

Avoid unnecessary or non-work-related internet usage that may strain the organization's network resources or compromise network performance.

The organization reserves the right to monitor the company’s email and internet usage on company networks and devices to ensure compliance with this policy and to protect the organization's interests.

Violation of this Email and Internet Usage Policy may result in disciplinary action, which can include verbal or written warnings, suspension, termination, or legal action, depending on the severity and frequency of the offence.

Employees are encouraged to report any suspected policy violations or security incidents promptly to their superiors or the Group HR department.

The organization reserves the right to update or modify this policy as needed. Employees will be notified of any policy changes promptly.

All employees must acknowledge that they have read, understood, and will comply with this Email and Internet Usage Policy.

By adhering to this Email and Internet Usage Policy, we can ensure a secure and productive work environment while maintaining the organization's integrity and reputation.

1. This written notice serves to inform you that your personal data is being processed by or on behalf of BESHOM.
   
   
2. The personal data processed by us include all information contained in Employment Application Form, together with other information we may obtain about you, including but not limited to personal data collected through both oral and/or written communications with you and all other relevant documentation.
   
   
3. We are processing your personal data, including any additional information you may subsequently provide, to perform all functions relevant to our appointment of you as an employee/intern of BESHOM and performing such other contract as may have been entered between you and us and such other purposes as may be related to the foregoing (“Purposes”). It is obligatory that you supply us with the personal data unless we otherwise specify. If you fail to supply to us the personal data which is obligatory to be provided by you, we may not be able to process your personal data for any of the Purposes.
   
   
4. In addition, you hereby expressly consent to our processing of your sensitive personal data such as information about your NRIC No. nationality, date of birth, race, religion, marital status, health, weight, height, contact details, Driving License No. Bank Account No. etc for the Purposes.
   
   
5. You may access and request for correction of your personal data and to contact us with any enquiries or complaints in respect of your personal data to Group HR department.
   
   In accordance with the PDPA:
   1. We may charge a fee for processing your request for access or correction; and
      
      
   2. We may refuse to comply with your request for access or correction to your personal data.
      
      
6. Your personal data may be disclosed to our related entities, licensees, auditors, banks, governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, business partners and/or service providers and any such third party requested or authorized by you for any of the above Purposes or any other purpose for which your personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above Purposes.
   
   
7. Your personal data may be transferred to a place outside Malaysia.
   
   
8. You are responsible for ensuring that the personal data you provide us is accurate, complete and not misleading and that such personal data is kept up to date.
   
   
9. We may request your assistance to procure the consent of third parties whose personal data is provided by you to us and you agree to use your best endeavors to do so. You shall indemnify us in the event we suffer any loss or damage as a result of your failure to comply with the same.
   
   
10. In the event of any inconsistency between the English version and the Chinese version of this notice, the English version shall prevail over the Chinese version.