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CODE OF BUSINESS CONDUCT

Company Statement

Kenyon Pte Ltd (“Kenyon” or “the Company”) is committed to conduct its business to the highest standards of corporate integrity, observing its social and environmental responsibilities, in a consistently legal and ethical manner.

This Code is written for all employees and provides a set of standards and values expected from all. The Company believes in being honest and fair to our employees, and in professional and honest in our business conduct, respecting all parties and being accountable in its dealings.

Our code of conduct and ethical requirements includes:

Human Rights

It is Kenyon’s policy to treat everyone in Kenyon and everyone with whom we come into contact with, with respect, fairness and dignity.

Laws and Regulations

The Company conducts business in compliance with all applicable local laws and regulations.

Business Integrity

All employees are expected to act with integrity at all times. They have to deal honestly with clients, consultants, suppliers and contractors. No employee shall submit a quotation, proposal, invoice or statement which he/she knows or ought to know to be false, incomplete or misleading.

Financial Integrity and Responsibility

The Company ensures that its financial records are complete and accurate.

Anti-corruption, Bribery, Extortion and Embezzlement

All employees must comply with anti-corruption laws. Such laws prohibit the receipt/payment of bribes and kickbacks (monetary or otherwise) as well as promises for such to occur whether it is with another individual or entity or public officials.

Extortion is also unacceptable to the Company.

Any embezzlement shall be treated seriously and reported to authorities.

Gifts and Entertainment

An employee shall not accept or offer any gift or be involved in any entertainment that may place him under an obligation to influence business transactions. (Gifts include but are not limited to cash, gift cards, presents, entertainment and non-business activities.)

If any infringement on this rule is found, it will be investigated and reported to the management and if necessary be made known to the management of the person making/receiving the gift.

If an employee needs any clarification for the policy above, he/she should consult the respective Head of Department or Management staff.

Conflicts of Interest

Employees are to avoid situations where personal interests conflict or even appear to conflict with the interests of the Company. A conflict of interest arises when an employee’s interests are not consistent with those of the Company and hence create conflicting loyalties.

Employees must not use their positions for personal gains or to benefit relatives and friends.

Anti-Discrimination and Anti-Harassment

The Company is committed to providing a work environment that is conducive, safe and free from discrimination and harassment. Kenyon respects the diversity of our employees, and will not discriminate against any employee on the basis of age, race, color, marital status, religion, gender, sexual orientation, union membership or political affiliation.

Kenyon does not tolerate any acts of harassment in our workplace. All complaints will be investigated in a fair and timely manner, according to the procedure outlined in the Company’s whistle blower policy. The name(s) of the person(s) making the report shall be kept confidential. (Harassments include but are not limited to verbal, psychological and physical abuse and sexual harassment.)

Prevention of Underage Labor and Forced Labor

Kenyon commits to not employing underage or young persons and children, as defined in the laws of the respective countries that we perform work. In Singapore, we ensure that all employees are at least 18 years of age at time of employment.

The Company does not use involuntary labor or require payment of fees or the surrendering of passports as a condition of employment. The Company also does not impose unreasonable restrictions on movements of employees in the Company’s premises or at worksites.

Third Party Employment Agencies

The Company at times engages Third Party Employment Agencies for recruitment. These companies are checked that they do not have any links or records for infringement with authorities and that they comply with the local law and are align with this Code.

Working Hours

Work schedules and overtime hours will be kept consistent with the Singapore’s Employment Act, (“Employment Act”).

All overtime work will be voluntary.

Wages and Benefits

The Company will pay employees their wages in a timely manner and payment will include overtime pay at the rates as provided by the Employment Act, including benefits that meet or exceed the minimum required by law and/or contract.

The pay period and pay structure will be explained to the employees when they join Kenyon.

Wage deductions will not be used as a disciplinary measure.

Freedom of Association

Employees shall have the right of freedom of association and collective bargaining.

Grievance Procedure

Employees who have grievances may reach out to their direct supervisor or to their Head of Department or to file a report by writing to report@kenyon.com.sg.

If the grievance involves another employee, that employee has the right to receive a copy of the allegation against him/her.

All grievances shall be investigated and a resolution shall be recommended.

Intellectual Property

The Company is fully aware that intellectual property is a valuable asset and shall make every effort to safeguard clients’ information.

The Company also respects third-party intellectual property and utilizes them only after securing the necessary rights to their use.

Protection for Whistle Blower

Kenyon does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by employee in the course of their work.

Any one employee can raise his/her concerns to his/her immediate supervisor, manager, Head of Department or by submitting a report to report@kenyon.com.sg

The Company shall protect the whistle blower’s identity and prohibit discrimination, harassment and retaliation. The matter shall be investigated promptly and the outcome communicated.

If the employee made an allegation in good faith, but it is not confirmed by the investigation, no action will be taken against him/her. However, if an employee makes an allegation knowing it to be false, disciplinary action may be taken against him/her.

This promotes a culture of openness, accountability and integrity.

Workplace Health and Safety

Kenyon is committed to provide a healthy and safe working environment for all employees. All employees in turn are obligated to carry out their work in a safe manner without causing harm to themselves or to others. All employees are also empowered to stop any work that will put their health and safety at risk and to report such potentially unsafe or unhealthy situation immediately.

The Company has adopted an Integrated Management System as a framework for our project management, and has obtained certifications for ISO 9001, ISO 14001 and OHSAS 18001. The Company commits to maintaining and continually improving our Quality, Health and Safety Management in the core areas of safety, quality and environment protection.

Working and Living Conditions

Foreign employees are provided with clean and safe living spaces that exceed the requirements of the Urban Redevelopment Authority.

Risk Assessment and Management

Kenyon manages risks in accordance to Singapore’s Workplace Safety and Health Regulations. Dedicated risk assessment team and plans are developed for each work site/projects to identify safety and health hazards at respective workplace, and taking measures to eliminate or reduce the risks.

A 3-steps risk assessment generally consists of:

• Hazard Identification
• Risk Evaluation
• Risk Control

Risk management are also supplemented by daily toolbox meetings and Job Safety Analysis as a tool to provide a common communication platform with our workers and timely updates on changes in site conditions.

Training

Kenyon maintains a training plan and record for all workers. Training consists of basic mandatory certifications (e.g. CSOC, WAH), MOM-recognised courses, and other skill-set based certification (e.g. 6G welder, pipe fitters, electrician, confined space worker etc.) depending on projects requirement. The company also provides appropriate on-the-job training to workers who showed ability to progress.

Communication

Kenyon supports an open communication channels within the company. Key events, business performance and policies updates are disseminated via emails and/or bulletins. These will be highlighted and briefed at mass toolbox meetings for all employees so that timely and accurate information can be shared.

The Company encourages both employees and management staff to take a combine and active share in clear, prompt, and open communication environment.