TIMBERWELL BERHAD

Registration No. 199601014835 ( 387185-W )

SEXUAL HARRASMENT POLICY


1.0 Purpose

1.1 Timberwell Berhad and its Group of Companies ("TWB Group") is committed to providing a safe, respectful, inclusive and professional workplace that upholds the dignity and human rights of every individual.

1.2 TWB Group adopts a zero-tolerance approach towards all forms of sexual harassment and is committed to preventing, addressing and eliminating inappropriate behaviour within the workplace and in all work-related activities.

1.3 This Policy forms part of the Group’s commitment to respecting internationally recognised human rights and promoting a workplace free from discrimination, intimidation, abuse and harassment.


2.0 Scope

2.1 This Policy applies to:

  • All directors;
  • Permanent, contract and temporary employees;
  • Probationary employees;
  • Interns and trainees;
  • Consultants;
  • Contractors and subcontractors;
  • Suppliers and service providers while conducting business with the Company; and
  • Any individual engaged in work-related activities involving the Company.

    • 2.2 The Policy applies to conduct occurring:

  • At Company premises;
  • At project sites and operational locations;
  • During business travel;
  • At meetings, conferences and training programmes;
  • At Company-sponsored events; and
  • Through electronic communication, including emails, messaging applications, telephone calls and social media where related to work.

    • 3.0 Policy Statement

    3.1 TWB Group strictly prohibits sexual harassment in any form.

    3.2 Every individual has the right to work in an environment that is safe, respectful and free from unwanted sexual conduct.

    3.3 No person shall be subjected to sexual harassment, intimidation or retaliation for making a complaint or participating in an investigation.

    4.0 Definition of Sexual Harassment

    4.1 Sexual harassment refers to any unwanted conduct of a sexual nature, whether verbal, non-verbal, physical, visual or digital, that:

  • violates a person's dignity;
  • creates an intimidating, hostile, degrading, humiliating or offensive environment; or
  • interferes with an individual's work performance or employment opportunities.

    • 4.2 Sexual harassment may occur regardless of gender, age, position or employment status

    5. Examples of Sexual Harassment

    5.1 Examples include, but are not limited to:

    Verbal

  • Sexual jokes or comments;
  • Unwelcome compliments regarding appearance;
  • Sexual propositions or requests;
  • Inappropriate remarks about a person's body;
  • Repeated requests for dates after refusal.

    • Physical

  • Unwanted touching;
  • Hugging or kissing without consent;
  • Patting, pinching or brushing against another person;
  • Blocking someone's movement.

    • Non-Verbal

  • Leering or inappropriate staring;
  • Sexual gestures;
  • Displaying sexually explicit materials;
  • Sending inappropriate gifts.

    • Digital

  • Sending sexually explicit messages or images;
  • Sharing offensive videos or photographs;
  • Persistent inappropriate messaging through electronic platforms

    • 6. Responsibilities

    6.1 Management

  • foster a respectful workplace culture;
  • promote awareness of this Policy;
  • investigate complaints fairly and promptly;
  • maintain confidentiality where practicable; and
  • take appropriate corrective or disciplinary action

    • 6.2 Employees

  • treat everyone with dignity and respect;
  • refrain from any form of sexual harassment;
  • report incidents promptly; and
  • cooperate during investigations.

    • 7. Reporting Procedure

    7.1 Any employee who experiences or witnesses sexual harassment is encouraged to report the matter as soon as practicable through any of the following channels:

  • Immediate Supervisor;
  • Head of Department;
  • Human Resources;
  • Corporate Services Department; or
  • Any designated Management representative

    • 7.2 Complaints may be made verbally or in writing. Where appropriate, anonymous reports may also be submitted

    8. Investigation

    8.1 The Company shall:

  • acknowledge receipt of the complaint;
  • conduct an impartial and confidential investigation;
  • provide both parties with an opportunity to be heard;
  • review all available evidence; and
  • determine appropriate actions based on the findings.

    • 8.2 All investigations shall be conducted fairly, objectively and without bias.

    9. Investigation

    9.1 All complaints, investigations and related records shall be treated with the highest degree of confidentiality, subject to legal and procedural requirements.

    9.2 Information shall only be disclosed on a need-to-know basis.

    10. Protection Against Retaliation

    10.1 The Company prohibits retaliation against any person who:

  • reports sexual harassment in good faith;
  • assists in an investigation;
  • provides evidence; or
  • supports another individual making a complaint

    • 10.2 Any act of retaliation constitutes misconduct and may result in disciplinary action.

    11. False or Malicious Complaints

    11.1 Complaints made in good faith will not result in any adverse consequences, even where allegations cannot be substantiated.

    11.2 However, deliberately false or malicious allegations may constitute misconduct and may be subject to disciplinary action.

    12. Disciplinary Action

    12.1 Where sexual harassment is substantiated, the Company may impose disciplinary action, including but not limited to:

  • counselling;
  • formal warning;
  • mandatory training;
  • suspension;
  • transfer;
  • demotion;
  • termination of employment or engagement; or
  • referral to the relevant authorities where required by law.

    • 12.2 The disciplinary action shall be proportionate to the seriousness of the misconduct.

    13. Human Rights Commitment

    13.1 TWB Group recognises that freedom from harassment is a fundamental human right.

    13.2 This Policy supports the Company's commitment to

  • respect internationally recognised human rights;
  • provide equal employment opportunities;
  • promote diversity, equity and inclusion;
  • prohibit discrimination and harassment;
  • protect workers' dignity;
  • maintain safe and healthy workplaces; and
  • uphold ethical business conduct throughout its operations

    • 14. Human Rights Commitment

    14.1 TWB Group will periodically communicate this Policy and may provide awareness programmes or training to promote respectful workplace behaviour.

    14.2 Employees are expected to familiarise themselves with and comply with this Policy.

    15. Review of Policy

    This Policy shall be reviewed periodically and updated as necessary to ensure continued compliance with applicable laws, regulatory requirements and the Company's human rights commitments

    16. Approval

    This Sexual Harassment Policy was approved by the Board of Directors of Timberwell Berhad and shall take effect from 20 August 2026.



    © 2026 Timberwell Berhad