Supplier Code of Conduct

Kwan Yong Holdings Limited (“KYH”) is committed to upholding high standards of ethics, integrity and fairness. We believe that conducting business openly and responsibly creates greater value for our stakeholders.

This Code is applicable to suppliers, contractors and subcontractors (collectively: the Suppliers) of KYH and its subsidiaries (collectively: the Group), and covers the following areas:

Legal Compliance and Commitment

• Suppliers should comply with or exceed all applicable legal requirements, as well as environmental and social standards, in the respective jurisdictions of their operations.

Governance

• Suppliers are encouraged to have sustainable procurement policies in place and to develop their own policies and code of conduct to ensure robust control and governance of their suppliers and operations.

Business Ethics

• Suppliers should strictly prohibit any corruption, anti-competition, fraud, false declaration or other malpractices, abide by all the relevant laws and regulations of anti-bribery, anti-corruption and anti-competition, and establish anti-corruption policies and programmes.

• Suppliers should report any suspicious activity of corruption, anti-competition, fraud, false declaration or other malpractices to the Group following the related whistleblowing procedure.

Environmental Protection

• Suppliers should identify the environmental impact associated with their operations and take measures to control any negative impacts. Adequate resources and training should be provided for their employees.

• Suppliers should minimize their environmental impact by carefully managing their greenhouse gas emissions, energy, waste and resource efficiency and strive to prevent pollution. Suppliers should also seek to preserve biodiversity, avoid deforestation and conserve land where possible.

• Suppliers should use sustainable timber as much as possible, and for example, we will ensure that all timber used in temporary works at construction sites in Singapore is sustainable. Suppliers should require all these timber suppliers to provide certification issued by the Forest Stewardship Council (FSC) or other eco-certified sources. Besides sustainable timber, Suppliers should proactively promote using sustainable materials in their service and business.

Occupational Health and Safety

• Suppliers should commit to providing their employees with a safe and healthy work environment. Adequate resources and training should be provided to ensure employees’ safety, health and wellness.

• Onsite contractors should be subject to regular safety compliance checks and reviews by the Group’s site-safety professionals and bi-annual compliance audits by external professionals where applicable.

Human Rights and Equal Opportunities

• Suppliers should respect their employees' human rights and freedom of association. Suppliers are required to bargain in good faith with association representatives.

• Suppliers should not tolerate discrimination of any kind, including, but not limited to, gender, age, religion, race, pregnancy, family status, marital status and disability.

Labour Practices

• Suppliers should not employ child labour or persons under the legal working age unless employed via recognized apprenticeship programmes.

• Suppliers should not tolerate forced labour situations, including, but not limited to, threats, debt bondage, withholding of wages, or retention of identity documents.

• Suppliers should ensure a discrimination and harassment-free workplace.

• Suppliers should recognize and abide by local statutory requirements for minimum wage, minimum benefits and working hour limits and provide a decent working environment with good working conditions.

Confidential Information and Privacy

• Suppliers should not disclose confidential information regarding the Group’s business without the Group’s prior written consent. They are required to formulate their policies to prevent leakage of confidential information.

• Suppliers should take good care of the Group’s assets and ensure the economical use of the Group’s resources. They should follow the Group’s procedures and practices regarding the use of the Group’s assets and resources.

• Suppliers should protect the privacy of their employees and customers and comply with the relevant laws when collecting, handling, storing or using personal data in Singapore.

• Suppliers are encouraged to report any concern about any malpractice or impropriety involving any staff of the Group that they become aware of by informing the head of the department concerned, the Chairman and Managing Director of KYH or the Audit Committee. Examples of malpractice or impropriety and details of how investigations are conducted are set out in the Whistleblowing Policy of KYH.

Intellectual Property Rights

• Suppliers should recognize and respect the intellectual property rights of the Group and other owners with respect to their trademarks, service marks, logos, copyrights, designs, inventions and patents.

Communication

• Business units of the Group should make sure that all their Suppliers understand this Code and ensure that it is enforced throughout the Group’s operations.

• Relevant departments and the Sustainability Steering Committee will review this Code periodically to ensure its adequacy and effectiveness, as appropriate.

For questions or concerns about this Code, including its application to specific circumstances in connection with your organisation’s performance of work for KYH, or to report any suspected violations of this Code, please contact our corresponding KYH representative.