TIMBERWELL BERHAD

Registration No. 199601014835 ( 387185-W )

PROHIBITION OF CHILD LABOUR AND YOUNG WORKER POLICY


1.0 PURPOSE

To set a standard that outlines definition and approach to provide labour protection to children and young employee in Timberwell Berhad and its Group of Companies “TWB Group”.

2.0 SCOPE

This SOP is applicable to all employees in TWB Group .

3.0 DEFINITION

3.1 Prohibition of Child Labour

Refers to any work or economic activity performed by a child that deprives them of their childhood, potential, dignity, education, or development, and that is harmful to their physical, mental, social, or moral well-being.


3.2 Young Employee (Young Worker)

A young employee refers to an individual who has reached the minimum legal working age but is below eighteen (18) years of age, and who is employed in accordance with applicable laws and regulations.

3.3 Minimum Age

Minimum age refers to the minimum age for admission to employment or work as established by applicable laws and regulations or by the Company's employment requirements. For the purposes of this Policy, no person under the age of eighteen (18) shall be employed by the Company, unless otherwise permitted by law.

3.4 Employment

Employment refers to a contractual working relationship in which an individual performs work or services for the Company in exchange for remuneration, wages, salary, or other forms of compensation.

3.5 Pre-Employment

Pre-employment refers to all activities, assessments, verifications, and procedures undertaken prior to the commencement of employment, including recruitment, screening, selection, and hiring processes.


4.0 REQUIREMENTS, PROCESS, PROCEDURE AND RESPONSIBILITIES

4.1 Communication and Awareness

4.1.1 The Company shall communicate this Child Labour Policy and its related procedures to all relevant employees, particularly those involved in recruitment, hiring, and the management of young employees.

4.1.2 Appropriate training shall be provided to personnel responsible for recruitment and hiring to ensure a clear understanding of the prohibition of child labour and compliance with applicable legal and regulatory requirements.

4.2 Scope

4.2.1 This policy applies to all pre-employment and employment activities undertaken by the Company.

4.2.2 The Company strictly prohibits the employment of child labour within its operations. Furthermore, the Company does not permit the use of child labour by its subcontractors, suppliers, or business partners.

4.2.3 Where subcontractors or suppliers employ young workers, they must ensure full compliance with all applicable laws, regulations, and employment requirements governing young persons.

4.3 Recruitment and Employment Practices

4.3.1 The Company shall not employ any individual below the minimum legal working age as defined by applicable laws and regulations

4.3.2 As part of the recruitment process, the Company shall:

  1. Verify the age of all prospective employees by reviewing original proof-of-age documentation, such as a birth certificate, national identification card, passport, school certificate, or other legally recognised documents.
  2. Exercise reasonable due diligence to assess the authenticity and validity of age-related documentation.
  3. Retain copies of official proof-of-age documents for all prospective employees prior to employment.

4.3.3 Where required by applicable law, young employees shall undergo a pre-employment medical examination to assess their fitness for work and to minimise risks associated with the tasks they are assigned. During the course of employment, young employees shall also undergo periodic or annual medical examinations where mandated by law.

4.3.4 Where required by applicable legislation, the employment of young employees shall be registered with the relevant labour authorities and/or supported by written consent from a parent or legal guardian through the execution of the employment contract.

4.4 Identification and Remediation of Child Labour

4.4.1 If an incident of child labour is identified, the Company shall immediately implement its Child Labour and Young Workers Remediation Procedure to ensure the welfare, protection, and legal rights of the affected child are safeguarded.

4.4.2 The remediation process shall include the following actions:

4.5 Working Conditions for Young Employees

4.5.1 Where young employees are employed by the Company or its suppliers, the Company shall implement appropriate measures to ensure their rights, health, safety, well-being, and development are protected at all times.

4.5.2 The Company shall ensure that young employees:

  1. Are employed only outside of compulsory school hours where they are subject to mandatory education requirements.
  2. Are not assigned to perform heavy, hazardous, or physically demanding work that may exceed their capabilities.
  3. Work in a safe and healthy environment and are not exposed to conditions that may be dangerous or harmful to their physical, mental, moral, or social development.
  4. Are not permitted to operate or come into contact with hazardous machinery, equipment, substances, or processes unless permitted by law and under appropriate supervision and safeguards
  5. Do not work more than eight (8) hours per day and only within the limits prescribed by applicable laws and regulations.
  6. Are not required to work during night shifts or during prohibited working hours as defined by local legislation.
  7. Receive adequate rest periods and breaks in accordance with applicable legal requirements

4.5.3 The Company shall ensure that the combined time spent by young employees on education, work, and commuting does not adversely affect their health, well-being, or educational development. Young employees shall be provided with sufficient opportunity to attend school and complete their education without disruption from work-related commitments.

4.5.4 All tasks assigned to young employees shall be appropriate to their age, experience, physical capacity, and level of maturity. Prior to commencing work, young employees shall receive all necessary training, supervision, and guidance to enable them to perform their duties safely and effectively.

4.5.5 The Company shall regularly monitor the working conditions, welfare, and working hours of young employees to ensure ongoing compliance with legal requirements and this policy.

4.5.6 Young employees shall receive wages, benefits, and employment protections that meet or exceed the minimum standards prescribed by applicable labour laws and regulations.

4.6 Internship and Vocational Training Programmes

4.6.1 The Company supports internship and vocational training programmes as a means of enhancing education and skills development. Such programmes shall comply with all applicable legal and regulatory requirements.

4.6.2 Internships and vocational training placements shall be structured primarily for educational and developmental purposes and shall not be used to replace regular employees or to provide temporary, supplementary, or low-cost labour. Participants shall receive appropriate supervision, learning opportunities, and workplace protections throughout the duration of the programme.

4.7 Record Keeping

4.7.1 The Human Resources Department shall maintain accurate, complete, and up-to-date records relating to the implementation of this policy.

4.7.2 Any identified cases of child labour, including the actions taken under the Child Labour and Young Workers Remediation Procedure, shall be properly documented, retained, and maintained in a secure and confidential manner for monitoring, compliance, and audit purposes.

4.7.3 The Human Resources Department shall also maintain an updated register of all young employees, including, where applicable:

  1. Full name;
  2. Date of birth;
  3. Date of hire;
  4. Department or work location;
  5. Job title or position;
  6. Work schedule and working hours; and
  7. Any other information required by applicable laws and regulations.

4.7.4 All records shall be maintained in accordance with the Company's record retention requirements and applicable legal and regulatory obligations.




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