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Donations & Sponsorships Policy

Erfan Sakib on June 28, 2022

1. Introduction

All Donations and Sponsorships provided by LBS Bina Group Berhad (“LBGB”) and its subsidiaries (collectively “LBGB Group” or “Group”) must be ethical and legal under applicable laws and not with intention to influence any business decisions or cause other to perceive it as such.

2. Scope

This Policy is applicable to the Personnel of LBGB Group and Business Associates acting on behalf of LBGB Group. Joint-venture companies and associated companies are encouraged to adopt these or similar principles. This Policy should be read in conjunction with the Anti-Bribery and Corruption Policy and the Whistleblowing Policy of LBGB Group.

3. Definitions

“Business Associate” means an external party with whom LBGB Group has, or plans to establish, some form of business relationship. This may include clients, customers, joint ventures, joint venture partners, consortium partners, outsourcing providers, contractors, consultants, subcontractors, suppliers, vendors, advisers, agents, distributors, representatives, intermediaries and investors.

“Donations” means voluntary contributions in the form of monetary or non-monetary gifts to a fund or cause.

“Personnel” means Directors and all individuals directly contracted to the Company on an employment basis, including permanent, temporary employees and interns.

“Sponsorships” means partnering with external organisations to deliver mutual benefits through exchange of monies, products, services, content or other intellectual property.

4. Donations And Sponsorships

The Group makes donations to LBS Foundation, a registered non-profit organisation with the sole aim is to give back to the community through its 4 main pillars: Education, Community, Environment and Health. Other Donations and Sponsorships request will be assessed on a case-by-case basis and subject to the approval of the Executive Director.

4.1 Acceptable Donations & Sponsorships

a) Any charitable Donation or Sponsorships made or offered on behalf of the Group must:

i) not be related to, dependent on, or made in order to win, or influence, a business deal or decision;

ii) be given direct to the relevant charity or organisation; and

b) The Head of Department who handles the request for any Sponsorship or Donation shall conduct due diligence on the recipient to ensure that the recipient is a legitimate organisation, prior to obtaining approval from the Executive Director.

4.2 Non-Acceptable Donations & Sponsorships

a) The Group shall not donate to private individuals or private accounts or to individuals or organisations that could prove detrimental to the reputation of the Group.

b) The Group should not support via a sponsorship where the activities or proposals:

i) conflict with the Group’s values or objectives;

ii) will require the Group to give, or appear to presume a strong explicit endorsement of the products and services of the Recipient; or

iii) do not demonstrate a genuine readiness or capability to carry out the obligations.

5. Donations And Sponsorships Requests

All Donations or Sponsorships requests must be made in writing to the Group in reasonable period of time before the anticipated commencement of the relevant event/action.

The Executive Director shall approve the proposal upon being satisfied with result of the due diligence conducted on the recipient in accordance with the guideline of the Group.

6. Policy Violation

The procedure of reporting any violations of this Policy shall be referred reporting mechanism contained in the Whistleblowing Policy.

7. Policy Review

This Policy has been approved by the Board of Directors and shall be made available on the Group’s corporate website and internal computer networking system. All Heads of Department are responsible to inform their staff and clearly explain to them the contents of this Policy.

This Policy shall be reviewed by the Board of Directors and updated whenever necessary to ensure its effective implementation. Any subsequent amendments to this Policy should be approved by the Board of Directors.

Gift, Entertainment & Hospitality Policy

Erfan Sakib on June 28, 2022

1.0 INTRODUCTION

LBS Bina Group Berhad (“LBGB” or “Company”) and its subsidiaries (“LBGB Group” or “Group”) recognise the importance of honesty, sincerity, and transparency and are committed in achieving the highest ethical standards in its business operation through compliance with all applicable laws, regulations and/or standards in the jurisdictions, where LBGB Group operates.

2.0 OBJECTIVE

To establish guidelines on the giving or receiving of Gift, Entertainment and Hospitality to and from LBGB Group, Business Associate, Third Party and/or their representatives.

3.0 SCOPE

This Policy is applicable to the Personnel, Business Associate, Third Party and/or their representatives acting on behalf of LBGB Group. Joint-venture companies and associated companies are encouraged to adopt these or similar principles. This Policy should be read in conjunction with the Anti-Bribery and Corruption Policy and the Whistleblowing Policy of LBGB Group.

4.0 “NO GIFT & ENTERTAINMENT POLICY”

4.1 LBGB Group adopts a “No Gift, Entertainment and Hospitality Policy” whereby all members including but not limited to their Directors and Staff of LBGB Group are prohibited from giving and receiving any Gift, Entertainment or Hospitality. This Policy also extends to family members, representatives and/or Business Associate of Personnel and Third Party.

4.2 All Personnel, Business Associates, Third Party and/or their representatives shall abide to this Policy to avoid any conflict of interest or seen to be a conflict of interest, and may potentially tarnish the Group’s reputation or be in violation of anti-bribery and corruption laws.

4.3 Although LBGB Group practices a “No Gift, Entertainment and Hospitality Policy”, there may be situations whereby it may be customary or necessary to give or receive Gift, Entertainment or Hospitality during the ordinary course of business. Under such circumstances, the following exceptions to the Policy may apply:

i) meet the requirements of applicable internal policies of LBGB Group;

ii) as a legitimate, justified business courtesy;

iii) be given in a transparent manner, modest in value and for valid purposes;

and

iv) not influence or appear to influence the independence of the receiver of the said Gift, Entertainment or Hospitality.

5.0 DEFINITIONS

“Corporate Gift” normally bears the company’s name and logo and are of nominal/appropriate value.

“Entertainment and/or Hospitality” means the considerate care of guests, which may include refreshments, accommodation and entertainment. For avoidance of doubt, all forms of entertainment shall be deemed to be included under this definition as well.

“Gift” means anything of value (such as cash or cash equivalent vouchers, goods and services) given to any person or organisation without any expectation of anything in return or without any intention to influence someone to act improperly.

“Personnel” means Directors and all individuals directly contracted to LBGB Group on an employment basis, including permanent, temporary employees and interns.

“Public Official” means an individual who:

(i) holds a legislative, administrative or judicial position of any kind; or

(ii) who performs public duties or exercises a public function for or on behalf of a country or territory (or subdivision thereof) or for any public agency or enterprise.

“Third Party” means anyone who at any time performs (or who is intended to perform) services for or on behalf of any entity of LBGB Group including anyone who is engaged (by contract or otherwise) or paid to represent any entity of LBGB Group such as suppliers, distributors, business contacts, agents, representatives, intermediaries, middlemen, introducers, sponsors, consultants, contractors, advisers and potentially Public Official.

“Facilitation Payment” means typically small, unofficial payments or other provision made personally to an individual in control of a process or decision. It is given to secure or expedite a routine or administrative duty or function, to which the payer is entitled, legally or otherwise.

6.0 ACCEPTING GIFT, ENTERTAINMENT AND HOSPITALITY

6.1 LBGB Group acknowledges that Gift giving is a central part of business etiquette. Gift, Entertainment or Hospitality received shall be recorded via the LBGB Group’s online Declaration Form subject to this Policy.

6.2 The following Gift, Entertainment or Hospitality may be accepted by any Personnel without approval but online Declaration Form is required:

i) Corporate Gift; and/or

ii) Perishable Items (such as fruits, festive cookies or delicacies offered during festive seasons or ceremonial occasions).

6.3 Invitation to attend open house, opening ceremony and receiving condolence offerings may be accepted by the Personnel without approval and online Declaration Form.

6.4 Personnel and any Third Party acting for or on behalf of LBGB Group are prohibited from:

- - - requesting gifts, contributions, gratuities, services or bribes from LBGB Group’s suppliers, or clients, regardless of its worth;
    - accepting any Gift, Entertainment or Hospitality that is, or gives the appearance of, being lavish, offensive or inappropriate;
    - accepting any favours that might be regarded as placing an obligation to such person or party; or
    - accepting from, a business contact of LBGB Group any Gift, Entertainment or Hospitality in a personal capacity or through any family member or agent.

6.5 Save and except for items stated in Clause 6.3, for Gift below RM500, Entertainment and Hospitality below RM200 per person, the Personnel shall declare by executing and submitting the online Declaration Form within 3 business days. The Head of Department or Senior Management shall decide to:

i) donate the Gift to the charity;

ii) hold the Gift for departmental display;

iii) share the Gift with other employees in the department;

iv) permit it to be retained by the Personnel; or

v) assign representative(s) for the Entertainment and/or Hospitality.

6.6 In determining the above, it is expected for the Personnel and/or any Third Party acting on behalf of the LBGB Group to exercise proper care and judgement in each case, taking into account pertinent circumstances including the character of the Gift, its purpose, the position/ seniority of the person(s) providing the Gift, the business context and cultural norms.

6.7 Save and except for items stated in Clause 6.3, for Gift of RM500 and above, Entertainment and Hospitality of RM200 and above per person, the Personnel shall obtain the Executive Director’s approval and subsequently declare by executing and submitting the online Declaration Form as soon as practicable. The Executive Director or Head of Department or Senior Management of the Company shall decide whether to:

i) donate the Gift to the charity;

ii) hold the Gift for departmental display;

iii) share the Gift with other employees in the department;

iv) permit the Gift to be retained by the Personnel; or

v) assign representative(s) for the Entertainment and/or Hospitality.

6.8 Personnel and/or the Third Party acting on behalf of the LBGB Group are advised to exercise their own judgement and self-assessment to estimate or determine the value of the Gift, Entertainment and Hospitality received.

7.0 DECLINING GIFT, ENTERTAINMENT AND HOSPITALITY

7.1 If any Gift, Entertainment or Hospitality received are not permitted by this Policy, all Personnel are required to either:

a) to politely decline and explain LBGB Group’s Gift, Entertainment and Hospitality

Policy to the offeror; or

b) where it would be offensive or embarrassing to the offeror, the Personnel shall consult the Executive Director or Head of Department or Senior Management to obtain approval on the treatment of such Gift, Entertainment or Hospitality and thereafter declare and submit the online Declaration Form.

8.0 GIVING GIFT, ENTERTAINMENT AND HOSPITALITY

8.1 Subject to the terms of this Policy, Personnel may give Gift, Entertainment or Hospitality to any Third Party.

8.2 It is the responsibility of the Personnel involved in giving of any such Gift, Entertainment or Hospitality to make reasonable efforts to enquire about the recipient’s policies on Gift, Entertainment and Hospitality and to ensure that the giving of Gift, Entertainment or Hospitality complies with the recipient’s policies as well as this Policy.

8.3 Prior to giving any Gift, Entertainment or Hospitality, the Personnel shall obtain approval from the Executive Director and thereafter declare and submit the online Declaration Form as soon as practicable.

9.0 FACILITATION PAYMENT

9.1 LBGB Group adopts a strict policy of disallowing the use of facilitation payments in its business. Facilitation payment as defined in this policy need not necessarily involve cash or other asset, and can include any sort of advantage to influence Personnel, Business Associate, Third Party and/or representatives in their duties.

9.2 Facilitation Payment is deemed to constitute bribery. Where the Personnel are requested to make such payments, the Personnel shall decline to make the payment and report the same to the Compliance Team. Where a payment has been made and the Personnel who made the said payment is unsure of its nature, the Compliance Team must be notified immediately, and the payment shall be recorded accordingly.

9.3 Pursuant to Clause 9.2, the Compliance Team shall refer to the Executive Director as to any further action to be taken under this Policy and/or Anti-Bribery and Corruption Policy.

10.0 PUBLIC OFFICIAL

10.1 Any Gift, Entertainment and Hospitality given to any Public Official will expose LBGB Group to higher risks under anti-bribery and anti-corruption laws. All Personnel are expected to be mindful and shall comply with all the rules that apply to the interactions with Public Officials.

10.2 Personnel may offer or give Gift, Entertainment or Hospitality subject to the following exception whereby the Gift, Entertainment or Hospitality:

10.2.1 Personal Capacity: is given to the Public Official outside the course of such official’s public duties. It is advised that the quantum of RM500 be used as a general guide.

10.2.2 Public Duty: provided that it is not in breach of any guidelines or codes applicable to Public Officials, is given to the Public Official as a token of appreciation in the course of public duty where such Public Official is officiating or attending an event, ceremony or other function hosted or organised by LBGB Group.

10.3 At an event, ceremony or function hosted or organised by government authority or ministry, Personnel acting as a representative of LBGB Group, may receive Gift, Entertainment or Hospitality from a Public Official.

10.4 If a Gift, Entertainment or Hospitality is intended to be given or offered to a Public Official in the course of his public duties as permitted by this Policy, it must be approved in advance by the Executive Director.

11.0 REVIEW OF THE POLICY

This Policy has been approved by the Board of Directors and is available on the Group’s corporate website and internal computer networking system. All Heads of Department are responsible to inform and explain the contents of this Policy to their staff.

This Policy shall be reviewed by the Board of Directors and updated whenever necessary to ensure its effective implementation. Any subsequent amendments to this Policy shall be approved by the Board of Directors.

Workplace Harassment Policy

Erfan Sakib on June 28, 2022

1. Introduction

LBS Bina Group Berhad (“LBGB or Company”) is fully committed to provide a safe, healthy and harassment-free work environment for all employees and believes that every employee should be treated with dignity, decency and respect. As a step towards ensuring a secure and comfortable workplace for the employees, this Policy has been developed to reflect the Company’s zero-tolerance approach against all forms of unlawful discrimination or harassment in the workplace.

2. Objective

a) To prevent harassment of employees in the workplace and to provide an effective mechanism to eliminate such harassment; and

b) To educate all employees to recognise the importance that workplace harassment is a seriously demeaning practice that constitutes a profound affront to the dignity of persons.

3. Scope

This Policy applies to all employees (including employees on contract terms, temporary or short-term employees and employees on secondment) or third parties who have become aware of or genuinely suspect on a reasonable belief that an employee of the Company and/or its subsidiary (“LBGB Group” or “Group”) has engaged, is engaged, is preparing to engage or is encouraging others to engage in any Improper Conduct, as hereinafter defined.

4. Harassment

Harassment in this context is, any verbal, written or physical conduct that is known or ought reasonably to have been known to be unwelcome, inappropriate or otherwise offensive to a person having the purpose or effect of:

a) creating a hostile, intimidating or offensive workplace;

b) interfering with the performance of an employee’s functions, duties and responsibilities; or

c) affecting one’s employment opportunities or compensation.

For the purposes of this Policy, harassment in the workplace includes any employment-related harassment occurring outside the workplace as a result of one’s employment responsibilities or employment relationships. Situation under which such employment-related harassment may take place includes, but is not limited to:-

a) Work related social functions, conferences or training sessions, travel and work assignments outside the workplace.

b) Work related conversations made over the telephone or communications via electronic media.

The following examples of harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

a) Verbal harassment which includes comments that are offensive or unwelcoming regarding the individual characteristics which include among others the national origin, race, religion, age, sex, pregnancy, appearance, disability, gender and marital status.

b) Nonverbal harassment which includes distribution, display or discussion of any written or graphic material that ridicules, denigrates, insults, belittles or shows hostility, aversion or disrespect toward an individual or group characteristics which include among others the national origin, race, religion, age, gender, pregnancy, appearance, disability and marital status.

c) Workplace Sexual harassment which is defined as any unwanted conduct of a sexual nature that happens in the course of one’s employment, having the effects of verbal, visual, psychological or physical harassment against a person of the same or opposite gender:

i. that might on reasonable grounds, be perceived by the recipient as placing a condition of a sexual nature on his/her employment; or

ii. that might on reasonable grounds, be perceived by the recipient as an offence or humiliation, or a threat to his/her wellbeing, but has no direct link to his/her employment.

5. Reporting of Violations of the Policy

Any employee who knows of, or reasonably suspects, a violation of this Policy, is encouraged to whistle blow or report such concerns through the Whistle Blowing Policy of LBGB.

For further details, the Whistle Blowing Policy of the Group is available on the Company’s corporate website, www.lbs.com.my

6. Complaint Handling

The Company reiterates that harassment of any nature that happens in the workplace is strictly prohibited and will not be tolerated or condoned. Upon receiving any reports/complaints regarding violation of this Policy, the Management will conduct a thorough investigation on all such reports/complaints fairly and objectively, and appropriate action(s) will be taken against the employee(s) concerned, based on all available evidence.

The Company treats harassment as misconduct and shall be subject to the Company’s Disciplinary Procedures. If the investigation reveals evidence that supports the complaint and is eventually upheld, the harasser will be dealt with in accordance with the Disciplinary Procedures.

Although the Company encourages any form of harassment to be reported, any false accusations, fabricated allegations or otherwise complaints made in bad faith are considered as misconduct and accordingly, disciplinary action may be taken against the complainant.

7. Review of Policy

The policy shall be reviewed by the Board of Directors and updated whenever necessary in order to ensure its effective implementation. Any subsequent amendments to this Policy shall be approved by the Board of Directors.

Human Rights Policy

Erfan Sakib on June 27, 2022

1. Introduction

LBS Bina Group Berhad and its subsidiaries (“LBGB or Company”) endeavours to provide a conducive working environment that is characterized by mutual respect. The Company is committed in respecting and abiding internationally recognized human rights standards and fair labour practices according to local statutory laws within the company operations (“Human Rights Laws”).

We recognize the importance of fair labour practices and a good relationship of mutual respect between employer and employee as we believe this will lead to fostering high employee morale and improve employee engagement within the Company. Accordingly, we will not condone any practices, events, and activities that are in violation of the above-mentioned Human Rights Laws.

2. Objective

The objectives of this Human Rights Policy are to amongst others;

a) To ensure all employment in the Company are in accordance with relevant employment laws including but not limited to the Employment Act 1955.

b) To identify any risks relating to current labour practices in the Company and to determine an effectively method to prevent and eliminate these risks.

c) To provide a fair, respectable and safe workplace for all employees in the Company.

d) To foster a pleasant, cordial, and harmonious relationship between employer and employees for smooth operations, and to promote stability as well as prosperity.

3. Scope

This Policy applies to all employees (including employees on contract terms, temporary or short-term employees and employees on secondment) or third parties who have become aware of or are genuinely suspected on a reasonable belief to be an employee of the Company that has engaged, is engaged, is preparing to engage or is encouraging others to engage in any conduct as stated below.

4. Commitment

a) Non-discrimination
We have a zero-tolerance policy against discrimination in any form and our employees are provided with equal and merit-based career opportunities regardless of race, religion, and/or gender.

b) Fair Employment Conditions
We operate in full compliance to applicable wage, work hours, overtime and benefits laws. We provide recognition based on performance and contribution of the employee towards the Company’s success.

c) Health and Safety
We provide a safe and healthy workplace environment for employees. We comply with applicable health and safety laws, regulations and requirements. We are dedicated in maintaining a productive workplace and strive to take every measure to prevent job-related injuries and illnesses.

d) Workplace Security
We strive to provide a safe and mutually respectful workplace environment that is free from violence, harassment, humiliation and intimidation of any nature.

e) Child Labour
The Company does not recruit child labour and is committed in strict compliance with applicable child labour laws as legislated in the Children and Young Persons (Employment) Act 1966, if it ever decides to employ a child. The Company condemns all forms of child exploitation and slavery.

f) Forced Labour
The Company recognizes that forced labour, modern slavery, debt bondage, and human trafficking may stem from coercive tactics and undue influence from people in position of higher authority towards people in lower positions of authority which may include violence or threats of violence, or more subtle means such as accumulated debt, retention of identity papers or threats of denunciation to authorities. The Company supports the elimination of forced labour, modern slavery, debt bondage and human trafficking. The Company takes the stand that all mentioned in the foregoing constitutes a severe violation of human rights and restriction of human freedom.

g) Freedom of Association & Collective Bargaining
The Company respects freedom of association as part of our commitment to support fair and equitable treatment of our employees regardless of gender, race, caste, nationality, religion, age, physical condition, marital status, union membership/affiliation/activity, employment status or political affiliation. Any form of discrimination based on factors aforementioned is prohibited, and any union membership/activity will not lead to disciplinary measures or punitive actions.

h) Equal Opportunities
The Company is committed to inculcating diversity and equal opportunity in our workplace which allows us to gain a competitive edge through embracing workforce diversity as well as providing fair treatment to all our employees to promote improved morale and loyalty towards the Company. The Company shall ensure that all employees receive equal and fair treatment based solely on merits and competency regardless of any form, whether based on age, gender, race, nationality, religion, disability and social status throughout the organization.

i) Excessive Working Hours
The Company’s working hours are regulated under the employment contract with the employee, Malaysia Employment Act 1955 and/or the Employment (Limitation of Overtime Work) Regulations 1980. The Company is committed that all employees are ensured proper rest days to recuperate for the operational efficiency of the Company’s operations.

j) Minimum Living Wage
The Company recognizes that a minimum wage has been set by the Malaysian authorities with the aim of protecting employees against unduly low pay. The Company is committed to comply with the local statutory laws on minimum wages and ensures that all wages are paid in a timely manner.

5. Reporting of Violations of the Policy

Any employee who knows of, or reasonably suspects, of a violation of this Policy, is encouraged to whistle blow or report such concerns through the Whistle Blowing Policy of LBGB. For further details, the Whistle Blowing Policy of the Group is available on the Company’s corporate website, www.lbs.com.my

6. Review of Policy

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