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Workplace Harassment Policy

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:

i. creating a hostile, intimidating or offensive workplace;

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

iii. 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.

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