Compliance Activities and Policy

5. Relationship with Employees

Basic points

(1) Employees are fundamental of all corporate activities for our company, we shall show necessary and sufficient respect for them, and shall positively support their personal and career growth.

(2) Although there are various elements to satisfy each individual employee, from the fundamental employment benefits such as compensation, to opportunities for them to achieve self-actualization, we shall support each employee and his or her growth as a human being by providing an environment where each individual employee can demonstrate his or her own best ability through their job.

(3) For that purpose, we shall respect all basic human rights, observe all laws, especially laws related to labor and employment, and maintain internal order and discipline by observing internal rules. We will also allow for a work environment where each individual can show his or her best efforts, perform faithfully his or her job and to continue to develop skills to maximize their ability.

1) Respecting Human Rights and Equality

We shall, at all times, maintain a sound working environment, and respect human rights, equality and personality of each individual.

(1) Clarion will make employment and employment-related decisions without regard to characteristics that laws require employers not to consider. They include such things as an applicant’s or employee’s race, color, religion, age, sex, national origin, sexual orientation, or disability, or any other basis like hobbies and school careers prohibited by applicable all laws.

(2) We shall never compel anyone to work by actions such as threats of violence, abuse, or slander and shall also never infringe upon human rights by bullying or harassing.

2) Prohibiting Sexual Harassment

We shall, at all times, abstain from words and behaviors that might give sexual unpleasantness to others.

(1) We shall, at all times, abstain from behaviors, words or remarks that are suggestive and which constitutes an unwelcome sexual advance or request for sexual favors, or any verbal, visual or physical conduct of a sexual nature that is (1) related to or conditional to the receipt of employee benefits, or (2) sufficiently severe or pervasive as to alter the conditions of employment and create an abusive working environment.

(2) We shall condemn any abuse of powers by employees who use their position of influence as a threat for sexual favors.

3) Protection of Personal Information

We shall, at all times, strictly control the confidentiality of personal information of employees and other outside personnel and the information that we come to possess in the course of our business activities.

(1) We shall strictly control all personal information we come to possess in the course of business and ensure that it is kept confidential.

4) Maintenance of Safe and Clean Working Environment

We shall maintain a safe and clean working environment with the understanding and observance of related laws and regulations.

(1) We shall maintain the working environment safe and clean as a top priority matter, and shall understand and observe the laws and regulations related to the safety and cleanliness in all business execution.

(2) In the event of a workplace accident, we shall minimize the influence from, investigate the cause of the accident thoroughly and put measures in place to prevent a recurrence.

5) Observance of Laws, Rules and Regulations Related to Labor and Workers

We shall observe all laws, rules and regulations related to labor and employment, and maintain a safe and pleasant working environment.

(1) We shall thoroughly administrate each individual’s working hours and days not exceeding those designated by Employment Act.

(2) We shall always let all supervisors pay attentions to their workers’ health conditions, mentally and physically.

(3) We shall abide by the Singapore Employment Act which spells out the rights and obligations of employers and employees and the basic terms and conditions of employment wherever applicable.

6) Rigid Distinction of Company and Private Matters

We shall make rigid distinction between company and private matters, and shall at no time bring personal interests into, or take company matters out of work.

(1) We shall make clear distinction between company matters and private matters, and shall not mix these matters.

(2) We shall never divert company expenses to private eating or drinking, nor shall we make use of company equipment for private matters.

(3) We shall never bring the company position into private, and shall also never involve subordinates into own private purpose.

(4) We shall not let private matters implicate the company and tarnish its reputation.

6. Relationship with Company and Company Properties

Basic points

(1) With the recognition that our company exists with the mission to contribute to society by offering valuable products, we shall build and maintain appropriate relationships with the stakeholders of our company.

(2) We shall observe our Corporate Philosophy, the Principle and other internal regulations.

(3) We shall adequately manage all company’s property, such as assets, information, documents and the like, and shall never use them unlawfully or improperly.

1) Observance of Company Rules and Standards .

We shall, at all times, observe company regulations and standards.

(1) We shall never commit any act that is prohibited by internal rules, regulations, policy, practice or standards, and never perform unlawful and unfaithful activity against those.

(2) In the event that a law, internal rule, regulation, policy, practice or standard is unclear, we shall address such questions to our direct supervisors or the appropriate department for clarification.

2) Following Proper Accounting Procedures

We shall follow proper accounting procedures complying with related laws, regulations, internal rules and standards in order to establish an effective internal cross-check system as well as to comply with external requirements.

(1) When we make an entry in a book or write out a slip, we shall make the entry accurately complying with related laws, rules and regulations, and also with internal rules and standards.

(2) We shall never make false or fictitious entry when reporting company accounts. Additionally, we shall never keep assets or liabilities off the books.

3) Prohibition of Activities with Conflicting Interests

We shall, at no time, engage ourselves in activities that compete with or conflict with our company’s business.

(1) We shall not work for the sake of our competitors and/or trading partners, and shall never have the pecuniary relation and/or a business with them without express instruction and permission by the company.

4) Prohibition of Political and Religious Activities

We shall, at no time, engage ourselves in political and religious activities inside company premises.

(1) An employee may not solicit for any cause or organization or distribute literature for any cause or organization during the working time of the employee who is doing the soliciting or the working time of the employee who is being solicited.

(2) Additionally, employees may not distribute literature at any time in working areas of the facility.

5) Control of Confidential Business information

We shall, at all times, control confidential business information in an appropriate manner, and in no case, disclose this information to the outside without prior permission from the company.

(1) We shall strictly control the confidential business information of both our company and our business partners. We shall never disclose such information to outside entities, nor shall we use this information for purposes other than business.

(2) In the event we need to release confidential information to an outside entity, we shall require confidentiality agreements to be made with all parties so that we can prepare for unforeseen divulgement.

(3) We shall never make fraudulent use of the corporate secrets of other companies.

(4) Even after an employee’s resignation from the company, he or she shall not disclose any confidential business information of either our company or other companies, and also shall not use them for any purposes.

(5) In order to prevent from leakage of such information by carelessness, we shall be aware of our surroundings when discussing confidential information while both in private and in public and shall never discuss this information anywhere it may be easily overheard.

6) Proper Administration and Deployment of Company Properties

We shall, at all times, maintain company property in safe working order and properly deploy these assets. Also, in no case shall we misappropriate them for personal purposes.

(1) We shall, at all times, deploy company properties only for the purpose of performing the business for which it is intended and only with the approval of a direct supervisor.

7) Proper Use of Information Systems

We shall use the company information system only for business purposes, not for the private purposes.

(1) We shall strictly control the ID and password connected to company information system, and prevent leakage of such data.

(2) We shall not use another person’s ID and password for fraudulent purposes or in any action that may violate that person’s privacy.

(3) With the popularization of information terminal, electronic mail, network and the like, in order to administrate properly and utilize digital information, we shall always maintain and upgrade secure information systems.

8) Proper Administration of Documents and Records

We shall, at all times, administrate documents, records and other information in a proper manner, always maintaining an understanding of their importance.

(1) We shall keep and protect documents and materials deemed as confidential corporate secrets. At the same time, we shall acquire outside documents and materials deemed confidential by others only by legitimate means.

(2) We shall compose, transmit, store and scrap any documents according to our written regulations and standards.

9) Protection of Intellectual Property Rights

We shall, at all times, protect intellectual property rights, acknowledging them as important assets.

(1) We shall protect all company intellectual property by prompt application for relevant patents.

(2) We shall not make, nor make use of, any unauthorized or fraudulent copies of computer software.

(3) We shall not use other company’s intellectual properties, nor violate their rights to intellectual property, without written agreement from the property holder.

7. Additional Rules

1) Scope of Application of the Principle

This Principle is applied in full to all employees of Clarion Asia Pte Ltd. It also applies to the personnel assigned to Clarion under contracts from other companies and to part-time and probationary employees, where applicable.

2) Modifications and Abolition of the Principle

This Principle shall be modified or abolished only after the approval at the Clarion Co. Ltd. Board of Directors Meeting.

3) Consultations and Reports

(1)In the event questions arise regarding the content and/or interpretations of the Principle, inquiries shall be addressed to the department administering affairs of compliance at Clarion Co. Ltd.

(2)In the event of a violation or threat of violation to the Principle, whether by individuals or groups, employees or outsiders, the individual discovering the violation (“Reporter”) shall report their facts to their departmental supervisor. It is the responsibility of the supervisor to insure that the facts are reported to a senior executive of the company. The Reporter may also report directly to the department administering affairs of compliance.

(3)The Reporter, as defined under the preceding clause, shall be protected from any disadvantageous treatment(s) due to the act of reporting.

4) Violation of Rules

Anyone in violation of the Principle shall be dealt with in accordance with company regulations in force at that time.

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