TIMBERWELL BERHAD

Registration No. 199601014835 ( 387185-W )

PROHIBITION OF FORCED LABOUR POLICY


1.0 PURPOSE

Timberwell Berhad and its Group of Companies “TWB Group” are committed not employing in any form of involuntary labour, including but not limited to prison labours, debt-bondage labour or forced labour. New recruits will not be forced in any way into working for TWB Group or after having been hired as employees have unnecessarily limited freedom of movement.

2.0 SCOPE

This procedure is applicable to all employees in TWB Group .

3.0 DEFINITION

Forced labour refers to all work or service that is extracted from a person under the threat of any penalty, including monetary sanctions, loss of rights and privileges, restrictions on movement, or employers’ holding.

4.0 REQUIREMENTS, PROCESS, PROCEDURE AND RESPONSIBILITIES

4.1 Responsibilities

4.1.1 HR Manager or any assigned person within the HR function is responsible to ensure all recruitment, hiring and compensation processes are properly defined to avoid any forced labour practices and activities within The Company.

4.2 Procedures

4.2.1 The Company will not source or hire any forced labours and will not support the use of forced labour by subcontractors or suppliers.

4.2.2 The Company will require its labour suppliers or subcontractors’ commitment for prohibition of forced labour which is not supplying labours that is involuntary or forced.

4.2.3 In the event a labour sourcing supplier is unwilling or unable to comply with this procedure, or in the instance a labour sourcing supplier demonstrates malpractices that could generate risks of forced labour use, The Company shall terminate any business relationship with the supplier in question.

4.2.4 The Company will not retain foreign employee’s passport or ID but will ensure employees are aware when they need to return their passport for work permit renewal purposes.

4.2.5 Compensation will be issued directly to employees, or to an account specified in writing by the employee. If possible, compensation will not be paid through a third party, but when this is necessary, The Company will take reasonable measures to ensure that employees receive full compensation in a timely manner.

4.2.6 Employees should have the freedom of movement in working area for their access to basic liberties such as movement in canteen, during breaks, using toilets, accessing water, to access necessary medical attention, to leave at the end of their working shift, etc.

4.2.7 Employees should have the freedom of movement in hostel/dormitory area, workers' freedom to come and go from the dormitories during non-working hours.

4.2.8 Security guards will limit security tasks to normal security matters such as the protection of property or personnel security. Security guards will in no way be directed to force employees to work or to unnecessarily limit employees’ freedom of movement.

4.2.9 All employees have the right to decline overtime work when offered, and will not be forced to work overtime involuntarily.

4.2.10 The Company will not restrict employees who want to resign from the company for any reason. The Company should ensure employees will not be prevented from submitting their resignation and the resignation process shall not be hindered in any way.

4.2.11 A qualified person will be assigned with the responsibility for communicating, deploying, and monitoring the practice of effectively prohibiting involuntary or forced labour.

4.3 Communication and Awareness

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

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





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