Declaration of Interests and External Commitments 2

As part of Markono Group Pte Ltd and all of its subsidiaries, affiliates, and related entities (collectively referred to as the “Group”), the Group is committed to good corporate governance, transparency, and the responsible management of conflicts of interest.  As part of the onboarding requirements, you are required to make a full declaration of any relevant interests and external commitments.  This includes the holding of directorships, material indebtedness, and involvement in any external engagements (“External Gigs”) which may affect or be perceived to affect your duties to the Group. 

This declaration enables the Group to assess and manage any actual, potential, or perceived conflicts of interest, ensure compliance with applicable laws and regulations and uphold its internal policies.

All information disclosed will be treated with appropriate confidentiality and used solely for the purpose of governance, compliance, and risk management.

You are required to complete all sections below. This declaration must be submitted to HR no later than your joining date. Should any of your circumstances change after you have joined the Group, you are required to immediately notify and update Human Resource with a revised declaration.

作为 Markono Group Pte Ltd 及其所有子公司、附属公司和关联实体（统称为“集团”）的一员，集团致力于良好的企业治理、透明度以及对利益冲突的负责任管理。作为入职要求的一部分，您需全面申报所有相关利益及外部承诺。这包括但不限于担任董事职务、重大债务关系，以及参与任何可能影响或被认为会影响您对集团职责的外部活动（“外部兼职/工作”）。

此申报旨在使集团能够评估和管理任何实际、潜在或被认为存在的利益冲突，确保遵守适用的法律法规，并维护集团的内部政策。

所有申报的信息将受到适当的保密处理，仅用于公司治理、合规及风险管理的目的。

您须填写以下所有部分。本申报表须在您入职日期前提交予人力资源部。若您在加入集团后个人情况有所变更，必须立即通知人力资源部并提交更新后的申报表。

4.  Acknowledgement and Signature 确认与签署

• I confirm that the information provided in this declaration is true, accurate, and complete to the best of my knowledge and belief. 

• I undertake to immediately notify the Group of any changes to the above declarations during the course of the year and to submit an updated declaration for approval where necessary.

• I understand that failure to declare or making false declaration is a serious breach and may result in the withdrawal of my job offer.  

• By signing below, I acknowledge that I have read and understood the requirements of this declaration and undertake to comply with all related obligations under the policies of the Group.

• 本人确认，本申报中所提供的所有信息在本人所知范围内均为真实、准确且完整。

• 本人承诺，如在任职期间上述申报事项有任何变动，将立即通知集团，并在必要时提交更新后的申报以供批准。

• 本人明白，未如实申报或作出虚假申报属于严重违纪行为，可能导致录用资格被取消。

• 本人在下方签名，即表示已阅读并理解本申报的相关要求，并承诺遵守集团相关政策下的所有义务。 
   

通过在下方签名，本人确认已阅读并理解本申报表的相关要求，并承诺遵守集团政策中与此相关的所有义务。

1) Smoking

a) Smoking is strictly prohibited within the M-Cube compound.

b) Smoking Breaks- All Non-Exempt Staff (production operators/warehouse associates) are only allowed to smoke during official break times such as tea break, lunch break and dinner break.

c) All employees are responsible for advising and informing third parties (visitors, sub-contractors, suppliers and customers) of this policy should the need arise.

2) Handphone

a) All Non-Exempt Staff (production operators/warehouse associates) are not allowed to carry/use their Hand phone during official working hours.  Strictly no hand phone at the production/warehouse areas, hence please keep your personal hand phone in the locker at all times.

b) In case of emergency, please ask your family/friend to call the following to convey the message to you.

i- HR Department :  6263 0645/6263 0642 or immediate superior during office hour

ii- Guard House : 6263 0698 during non-office hour

3) Personal Protective Equipment (PPE)

a) Staff working at production/warehouse areas who are facing potential hazards on the job are required to wear appropriate PPE such as safety shoes, gloves, earplugs and etc.  Especially foot protection, strictly no slippers are allowed at production/warehouse areas; minimally cover shoes are required for office staffs when access to production/warehouse areas.  

All Department heads and employees are responsible for ensuring that this policy is strictly adhered to.

Any violation of the above  policies  will result in corrective action which will include disciplinary measures up to and including termination of the employment of the employee.

 

ACCEPTANCE

I acknowledge that I have read and fully understand the policies set out above, and agree and undertake to abide by the terms and conditions, as amended from time to time, during the terms of my employment with the Markono Group.

Markono Group Pte Ltd (“Markono”) has a zero-tolerance policy regarding the use,
possession, purchase, sale, or distribution of e-vaporisers (vapes) and related
components. This policy applies to all Markono employees, as well as all suppliers,
subcontractors, visitors, and any other individuals present on Markono’s premises. All persons on Markono premises are required to comply fully with applicable law
enforcement requirements and directives. Any violation is a serious criminal offence
in Singapore and a breach of this policy will result in immediate disciplinary action and may include reporting to the authorities.

1.0 PURPOSE

1.1 This policy:

1. sets out Markono’s position against vaping; and
2. ensures full compliance with Singapore laws, protect the health and safety of
   all individuals on company premises, and maintain an orderly and
   professional work environment.

2.0 LEGAL BASIS AND PENALTIES IN SINGAPORE

2.1 In Singapore, the Tobacco (Control of Advertisements and Sale) Act strictly prohibits the following acts related to e-vaporisers:

• Importation, distribution, and sale of e-vaporisers and their components
• Purchase, use, and possession of e-vaporisers and their components

2.2 Legal penalties for vaping offenses in Singapore are severe and include:

• Possession, use, or purchase: Fines of up to $2,000 for each offense
• Importation, sale, or distribution: Fines of up to $10,000 or imprisonment for
  up to six months (for first-time offenders), with increased penalties for repeat
  offenses
• Additional penalties may apply if the vape contains harmful substances like
  etomidate, which is a controlled drug

3.0 PROHIBITED ACTIONS

3.1 The following actions are strictly prohibited on Markono premises and for anyone representing Markono:

• Using an e-vaporiser or any similar electronic smoking device
• Purchasing, possessing, or storing an e-vaporiser or its related components
• Selling, importing, or distributing e-vaporisers to others
• Possessing an e-vaporiser, regardless of whether it contains nicotine

4.0 SCOPE OF POLICY

This policy covers all Markono locations, including:

1. All offices, warehouses, and other indoor spaces
2. Company-owned or leased vehicles
3. All common areas, including canteens, lobbies, and outdoor spaces
4. Remote working arrangements during work hours

5.0 DISCIPLINARY ACTIONS FOR EMPLOYEES

5.1 Violations of this policy will lead to immediate and severe disciplinary action,
which may include:

1. Suspension with or without pay
2. Formal warning letters
3. Demotion
4. Termination of employment for gross misconduct
   • The company reserves the right to report all vaping-related offenses to the relevant authorities, such as the Health Sciences Authority (HSA), in addition to internal disciplinary measures.

6.0 CONSEQUENCES FOR SUPPLIERS AND SUBCONTRACTORS

6.1 This policy is a condition for all contractors and suppliers working on Markono premises. Any violation by a supplier's or subcontractor's personnel will result in:

• Immediate removal of the individual from Markono premises
• Issuance of a formal warning to the vendor
• Potential termination of the contract with the supplier or subcontractor
• Markono reserves the right to report offenses to the authorities and assist in any official investigation

7.0 REPORTING PROCEDURES

7.1 All personnel on Markono premises, including employees, suppliers, and subcontractors, have a responsibility to report suspected violations of this policy.

1. Internal reporting procedure (for Markono employees):
   1. Report any suspected violation immediately and confidentially to your
      direct supervisor or the Human Resources (HR) Department.
   2. Provide details such as the time, date, location, individuals involved, and
      a description of the suspected device.
   3. Your identity will be kept private to the extent possible, and there will be no retaliation for good-faith reporting.                                                  
2. External reporting procedure (for anyone): 
   Vaping offenses are a legal matter in Singapore. Anyone can report violations directly to the Health Sciences Authority (HSA).

1. Online: Use the official online reporting form at go.gov.sg/reportvape.
2. Phone: Call the HSA Tobacco Regulation Branch at 6684 2036 or 6684
   2037 (daily, 9 am to 9 pm).

8.0 RESOURCES FOR HELP

Markono encourages anyone seeking help to quit vaping or smoking to use the
available resources. For support, contact the Health Promotion Board's QuitLine at
1800 438 2000 or visit the QuitVape programme website.

9.0 DOCUMENT FILING

All findings and letters will be filed in the respective employee’s personnel file.

10.0 RESPONSIBILITY

The HR Department is overall responsible for the implementation of this policy.

Objectives:

1. To establish awareness and identify possibility of threats to Company’s operations (Assets) and Staff.
2. To have a reporting guideline to all staff when there are possible threats to the Company.

Possible Threats:

Possible threats may come in different forms. They can be explosives or incendiary (cause fire) items which are delivered, terrorist, sabotage or criminal acts against assets and operations of the Company. Threats to the Company can be categorized into three general categories namely Persons, Events and Items.

Guidelines on Identification of Suspicious Characters:

Suspicious persons can be detected by observing their appearance behavior. The following are some descriptions of how a suspicious person may appear or behave:

1. Entering the premises without prior notification or on the pretext of being engaged to perform some form of work within the premises. Not being able to provide reasonable explanation or are uncooperative when asked for their purpose of visit. 
2. Persons loitering at the premises (parking lots, reception, emergency exists etc) of the Company without purpose or for an extended period of time.
3. Persons wandering within premises not displaying a valid authorized pass (Visitor Pass/Contractor Pass). 
4. Persons (non-staff) or terminated staffs or ex-staff wandering inside the Company unaccompanied by a staff.
5. Persons taking photos, examining buildings, and facilities inside or outside Company without authorization. 
6. Making an unexpected delivery of a package or place an item within or at immediate areas outside the premises and departing from the area.
7. Asking specific questions concerning the security of the premises or questions about personal movement of a specific or prominent individual. 
8. Wearing oversized or inappropriate attire that may conceal a hidden object. (e.g. wearing a long jacket in warm weather).

Guidelines on Identification of Suspicious Events and Items:

1. Suspicious items (e.g. parcel, goods) placed in the Company or immediate areas surrounding the premises without any identification. The item may have excessive use of securing material such as string and adhesive tape or it is a rigid and oddly-shaped parcel.
2. Staff vehicles or other unauthorized vehicles parking at receiving and shipping areas. The suspicious vehicle may look overly weighted especially where no indication of bulk is visible.
3. Unidentified vehicles park at the Company carpark or immediate areas surrounding the Company premises without any purpose for extended period of time. Do observe if there is presence of foreign objects attached under the vehicle or beside the wheels.
4. Any unauthorized activities happening at immediate areas surrounding the Company premises.

Guidelines to Reporting Threats:

Staff should report any suspected persons, events or items to the following for immediate action:

1. Immediate Superiors / Department Heads
2. HR Department Manager
3. Security Guards 

The Manager and Security Guards are to report to the Police if they deem that the suspicious persons, events or items constitute a real threat to the Company.

If staff suspects something is amiss, identify the ‘suspicious’ person, parcel or vehicle by noting their characteristics: 

1. For persons – example their gender, height, attire, faces, built, suspicious behaviors and what they are carrying or doing.
2. For parcels – their shape, size, packaging, markings or any sound emitted from it.
3. For vehicles – their colour, make, model, registration number, special markings, odor or sound emitted from it.

All documents will be retained for 4 years.

FOR GOOD CONSIDERATION, and in consideration of being employed by Markono Group, the undersigned employee hereby agrees and acknowledges:

1. That during the course of my employ there may be disclosed to me certain trade secrets of the Company; said trade secrets consisting but not necessarily limited to: 

1. Technical & information: Methods, processes, formulae, compositions, systems, techniques, inventions, machines, computer programs and research projects,
2. Business information: Any business information or data not limiting to customer lists, pricing data, sources of supply, financial data and marketing, production, or merchandising systems or plans

2. I agree that I shall not during, or at any time after the termination of my employment with the Company, use for myself or others, or disclose or divulge to others including future employees, any trade secrets, confidential information, or any other proprietary data belonging to company and/or it’s customer in violation of this agreement.

3. That upon the termination of my employment from the Company:

1. I shall return to the Company all documents and property of the Company, including but not necessarily limited to: drawings, blueprints, reports, manuals, correspondence, customer lists, computer programs, and all other materials and all copies thereof relating in any way to the Company's business, or in any way obtained by me during the course of employ. I further agree that I shall not retain copies, notes or abstracts of the foregoing.
2. The Company may notify any future or prospective employer or third party of the existence of this agreement, and shall be entitled to full injunctive relief for any breach.
3. This agreement shall be binding upon me and my personal representatives and successors in interest, and shall inure to the benefit of the Company, its successors and assigns.
4. The obligations of this Agreement shall be continuing until the confidential information disclosed to me is no longer confidential. 

4. I agree that the Company reserves its right to inspect all Company property for ensuring compliance with the aforementioned rules and regulations without prior notice or in my absence.

5. I understand the Company may avail itself of all legal or equitable remedies to prevent impermissible use of confidential information or to recover damages incurred as a result of such violations.

Although the Markono Group respects the privacy of its employees, you should not have any expectation of privacy with respect to work-related conduct or the use of Company owned equipment and supplies. Voicemail, e-mail, computer (hardware and software), internet and telecommunications systems are purchased, licensed and maintained by the Markono Group in order to facilitate the conduct of our business.  Employee usage of these systems is subject to the following:

1) All messages and information and the rights contained therein, whether personal or business related, which are stored, composed, sent and/or received on these systems are the property of the Markono Group and may be accessed, inspected, used or reproduced by the Group at any time.

2) Employees must not use others' passwords or bypass password protections. Sharing passwords or storing them in easily accessible places, such as writing them down in visible locations or on their desktops and laptops, is strictly prohibited, as these actions jeopardize our system security. Adherence to these guidelines is crucial for maintaining the integrity of our systems. Violations may result in disciplinary action.

3) The systems may not be used (1) to access, display, store or transmit offensive images or text (such as pornography), or (2) in violation of any law or the rights of third parties, or (3) in violation of Markono’s software or confidentiality policies.

4) The installation of unlicensed software applications (including games) in the systems is strictly prohibited.  Only company approved software applications are permitted to be installed in the systems and installation must be performed by MIS department staff.

 

5) E-mails are to be used for business related purposes only.  E-mails must never be used to initiate or forward “junk mail” messages, mass mailings or chain letters.  Additionally, disseminating material via e-mail that is harassing, offensive, threatening, abusive, embarrassing, defamatory or sexually explicit it strictly prohibited.

6) Security measures are taken to prevent virus attacks with the implementation of our ERP system.  Certain external websites will be strictly prohibited due to the susceptibility to virus.

7) Any forms of on-line chatting e.g. Facebook messenger, Instagram messenger, Google Hangouts, Skype,Telegram, Tiktok direct messages, WeChat etc. are banned from use as this is not an official form of communication with clients/suppliers. Furthermore employee should not chat or play computer games during working hours.

8) Be aware that even when information or messages are deleted, it may still be possible to retrieve them from a backup system.  You should therefore not rely on deletion to maintain your privacy.

9) Any material breach of the policies relating to employee use of company-owned voicemail, e-mail, computer and telecommunications systems may result in disciplinary action ranging from revocation of access to these systems, to dismissal from employment with the Company and legal proceedings against you.

10) To maintain compliance with our IT security standards, all staff must complete the mandatory IT security training as scheduled by the IT team. Any employee who fails to complete the training within the given timeline will have their user account disabled immediately, preventing them from using company laptops, accessing company data, or interacting with any company-related systems until the training is completed.

ACCEPTANCE

I acknowledge that I have read and fully understand the policies set out above, and agree and undertake to abide by the terms and conditions, as amended from time to time, during the terms of my employment with the Markono Group.

Markono Group Pte Ltd (“the Company”) shall fulfill the responsibilities for the
protection of personal data in accordance with the Personal Data Protection Act 20121 (“PDPA”).

1.0 PURPOSE 

This policy states the Company's approach to the handling of personal data collected from its employees. In this policy, the terms “we”, “us” and “our” refer to the Companywhich is collecting personal data from you or about you

2.0 SCOPE

The policy covers all employees.

3.0 WHAT PERSONAL DATA WE COLLECT

Personal data is data that can be used to identify a natural person. We collect personal data about you and other persons, such as your family members.

Examples of personal data include your name, nationality, date of birth, sex, contact details (address, email address, telephone numbers), NRIC, FIN or passport number, photograph, marital status, current occupation, health or medical records, character references and testimonials, and your image(s) on CCTV and in photographs.

If you provide the personal data of anyone else (such as your family members), it
means that you have obtained his/her consent to our collection, use and disclosure of his/her personal data for the purposes set out in this policy or that you validly give us such consent on their behalf.

4.0 OUR PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4.1 The personal data that we collect from you or about you is or may be used for the following purposes:

1. assessing and processing your job application and employment;
2. contacting you or your kin in the event of an emergency;
3. validating all references provided, conducting screening and background
   checks;
4. complying with our internal policies, procedures and directives;
5. reviewing and improving our recruitment policies and processes;
6. research, planning, statistical analysis and policy development relating to human resource management;
7. if applicable, preparing for and arranging your relocation to Singapore in
   anticipation of employment, including making travel and accommodation
   arrangements and applying for an employment pass or work permit; and/or
8. any other purposes relating to or arising out of the above
    

4.2 We may disclose the personal data collected from you or about you to third parties, whether located in Singapore or elsewhere, in order to achieve the purposes stated in this policy. Such third parties include:

1. other Markono entities;
2. our service providers, contractors and agents, including those which provide
   administrative, data processing, computer or other services to us;
3. third parties that introduced or referred you to us or that you submit your job application to, including employment agencies, referral agencies, business introducers, online job portals or similar service providers;
4. regulatory authorities, any statutory bodies or public agencies for the
   purposes of complying with their respective requirements, policies and
   directives or to seek information about you; and/or
5. medical clinics that conduct pre-employment medical examinations on you.

4.3 In addition to the data you provide, we may obtain from third parties (including referees) further data relating to you which is relevant to your employment with us. In doing so, we may disclose your personal data to such third parties.

4.4 We may take photographs and make videos and/or sound recordings in and
around our premises from time to time. You may be captured in such photographs and recordings. We may use such photographs and/or recordings in our publications, websites and other communication channels, as well as in third party media, or display them in and around our premises and/or the premises of the Markono.

4.5 CCTV may be in operation in and around our premises as necessary in the
interests of security.

4.6 We may also collect, use and disclose personal data where required or permitted by law for any purpose.

4.7 In order to achieve any of the purposes referred to above, we may need to
transfer personal data outside Singapore. If we do so, we will ensure that such
personal data is protected to a standard comparable to the protection accorded to
personal data under the Personal Data Protection Act 2012 (No. 26 of 2012) of
Singapore. In summary, this means:

1. the collection, use and/or disclosure of your personal data would be for the
   purpose(s) for which you have given consent;
2. steps would be taken to ensure accuracy and completeness of your
   personal data when your personal data is used or disclosed to third parties;
3. security arrangements would be made to protect your personal data;
4. your personal data would be retained only if necessary for legal and
   business purposes; and/or
5. anyone who receives your personal data from us is either in a jurisdiction
   which has comparable data protection laws or is otherwise bound to protect
   your personal data

5.0 RETENTION OF PERSONAL DATA

We will retain personal data for a reasonable period in accordance with our legal and business purposes.

6.0 ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to correct or have access to your personal data, please contact us.

7.0 HOW TO CONTACT US

If you have questions or concerns regarding your personal data or any aspect of this policy, please contact us at hr@markono.com.

8.0 AMENDMENTS AND UPDATES

We may amend this policy from time to time and will make available the updated policy on Markono’s intranet site.

9.0 RESPONSIBILITY

The HR Department is overall responsible for the implementation of this policy.

1.0 OBJECTIVE

Markono Group Pte Ltd (“Markono”) was founded in 1967 and had started out as a
small size company operating in the space of business card printing and stationery.
Markono today is a leading full-service publishing manufacturing and supply chain
solutions provider for the world's largest publishers who entrust their content with us, their key Asian partner. Our mission is to seamlessly deliver valued content to our customers.

At Markono Group, we believe that an organization cannot truly be sustainable and
successful and yet indulge in unethical practices. Markono is committed to the
prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. We enforce integrity, transparency and accountability among all employees and suppliers. Our approach towards unethical practices is one of “zero-tolerance”. Building on Markono’s Anti-bribery and Corruption Policy, Conflict of Interest Policy and Whistleblowing Policy, this policy document calls out our targets towards tackling corruption, mishandling data, money laundering, fraud and conflict of interest.

2.0 SCOPE OF APPLICATION

This policy documents applies to all employees engaged with Markono.

3.0 OUR COMMITMENT

Markono Group operates in line with the commitments that have been formulated with respect to the following topics:

3.1 Corruption

Our Anti-bribery and Corruption Policy clearly calls out the minimum standards that
Markono is committed to ensure throughout our organization, suppliers and
contractors. At Markono, we believe that corruption adversely impacts the business
and takes away from it its advantage in the market. We understand that the areas with a risk potential are developing constantly which is why we are consistently on a lookout for them to keep the system clear of it. Our employees are not allowed to give, offer or solicit anything of value to or from any third party.

 
Targets:

1. 100% Exempt employees to receive awareness training on corruption and
   bribery by 2023
2. To maintain 0 cases of corruption
3. To conduct annual risk assessments at 100% of our operational sites to identify potential areas of corruption and bribery starting 2024
    

3.2 Knowledge Management

When data or information is mismanaged, it not only affects the financials of an
organization but also impacts how the customers and consumers perceive it as unsafe. It is therefore imperative that organizations respect the confidentiality of data that is important to business and also be mindful of their customer data. Markono has a similar outlook towards knowledge management. It is important to note that mismanagement of knowledge can put the organization in a vulnerable position where our unique selling proposition (USP) or trade secrets may be leaked. All important data, information and knowledge must be encrypted and safeguarded from third party interference.

Targets:

1. 100% employees to receive awareness training on knowledge management
   by 2024
2. To conduct information security due diligence on 100% of third parties the
   company works with by 2025
3. To maintain 0 cases of information security breaches
4. To conduct annual risk assessments at 100% of our operational sites to identify potential areas information mismanagement starting 2023

3.3 Fraud

Frauds that are financial in nature often pose a great threat to businesses. Such frauds may occur within an organization or in alliance with a third party. Our constant aim is to ensure that the organization or our employees do not indulge in any financial deceit. We aspire to educate all employees about fraud and how indulging in them will result in penalties and loss of business for the organization. The expectations against fraud and the company’s stance are communicated to employees, contractors and suppliers. Any suspicious activity must be reported through proper channels and to senior management.

Targets:

1. 100% Exempt employees to undergo awareness training on fraud by 2023
   To maintain 0 cases of fraud

3.4 Money Laundering

At Markono, we ensure that we do not indulge in any practices that conceal the origin or use of money in financial transactions. Channels through which financial
transactions take place must be regularly audited to recognize and eliminate any risk areas. All employees must be encouraged to report any activities that arouse their suspicion of money laundering through proper channels. Any employee caught
indulging in acts related to money laundering with be prosecuted by local and global standards.

Targets:

1. 100% Exempt employees to receive awareness training on money laundering by 2024
2. To maintain 0 cases of money laundering

3.5 Conflict of Interest

When an employee is in a situation where his/her choice of actions puts him/her in a position to make gains in their personal interest and going against the betterment of the organization, he/she is said to be in a position of conflicting interests. At Markono, we aim to educate all employees to not put themselves in such positions of moral conflicts or dilemmas nor should they be swayed at the prospect of such an offer from a third party. If an employee is caught in such a situation or indulging with such people, then they will be prosecuted by the organization and by set norms and standards. All employees must be encouraged to report any activities that arouse their suspicion of conflicting interests through proper channels. Conflict of interest includes (but is not limited to) sharing trade secrets with competitors or joining a competitor organization and using the organization’s expertise and practices there in return for a favourable outcome for themselves.

Targets:

1. 100% Exempt employees to undergo awareness training on conflict of
   interest by 2023
2. To conduct annual declaration exercise for 100% of employees holding
   positions of Assistant Manager and above in January each year
    

4.0 RESPONSIBILITIES

All Markono employees are responsible for abiding by this policy. The policy must be easy to locate, understand and implement. The senior management of the
organization will be responsible for enforcing this organization-wide.

5.0 REVIEW

To measure the impact that this document has had on the organization, an annual
review about the extent to which this policy document is being enforced and followed by the organization and its employees is conducted by senior management.

6.0 COMMUNICATION

Markono will rely on the following channels of communication to share information
about this policy:

• New employees will receive this policy document as part of their onboarding
• Any significant development with regard to the policies will be shared via email with all employees
• A post-review email to be sent out to all employees giving details of the review
   

7.0 SANCTIONS

Employees that are not compliant with the policy document are held accountable for their actions by the organization and will be penalised as prescribed by local and global norms. While employees of the organization are tasked with the responsibility of reporting any incident that they may come across and that may be in violation of this policy document, the senior management is responsible for scouting risk areas and rectifying them so as to avoid any violation. It is important to note here that the identity of any employee who reports any incident of actual or potential violation of policy, will be kept confidential and they are also protected by a non-retaliation clause. We rely upon all our employees to report any suspected violations of this policy by writing to whistleblower@markono.com. The confidentiality and anonymity of all employees reporting any suspected neglect of this policy will be protected by the company.

 

Employee Acknowledgement

By signing either an electronic copy or physical copy of this acknowledgement form, I confirm that I have read through Markono Group Pte Ltd’s Ethics Policy and understood the company’s stance towards ethical obligations concerning anti bribery and corruption, fraud, money laundering, conflict of interest, as well as security and management.

In any case where I have any doubts or questions on any information presented in this policy, I have approached my supervisor or human resources to clarify.

I, as an employee of Markono Group Pte Ltd, undertake not to violate the company’s ethical code of conduct. If reported, I will be subject to internal investigations and may be prosecuted by the law.

I also undertake to report any potential violations of this policy. I understand that whistleblowers will be protected from retaliation and all information will be kept confidential unless required by law.

1. Introduction

Markono Group Pte Ltd (“Markono”) is the leading book and journal printer in Asia, providing offset and print-on-demand solutions to the world’s leading publishers of high-value content.

We are firmly guided by our Code of Conduct (Appendix A) as we strive to deliver world-class quality products and services which exceed customer expectations. This Social Compliance Policy defines the minimum standards that Markono is committed to ensure throughout our organisation and its external partners including suppliers, contractors, subcontractors, agencies of services etc.

We are committed to the highest standards of:

• Openness, integrity and accountability
• Promoting a workplace that is safe, free of discrimination, and encourages individual growth
   

This policy has the full support and commitment of the Managing Director.

2. Scope of Policy

Markono’s management define this policy as relevant to the organisation itself and its external partners engaged through the supply chain and business processes.

3. General Provisions

This policy communicates our values and expectations as well as emphasises the importance of responsible workplace policies and practices, which generally comply at a minimum, with applicable occupational health and safety, environmental and labour laws and regulations. The standards outlined below reflect the values we uphold in our own policies, and we expect our external partners to follow these standards and requirements:

3.1   Free Employment

• There shall not be forced and bonded employment.
• Use of involuntary labour will not be tolerated by Markono. 

3.2   Working Hours / Rest Days / Overtime

• Markono shall comply with local labour laws and regulations 

3.3   Child Labour

• Markono does not engage nor condone the use of child labour.
• No person shall be employed at an age younger than the legal minimum age. 

3.4   Human Trafficking

• Markono is committed to maintaining a work environment that is free from human trafficking.
• Markono will not tolerate employment practices that include the recruitment, transportation, transfer, harbouring or receipt of persons through the use of force or threat of force for the purpose of exploitation. 

3.5   Freedom of Association

• The rights of employees to choose to associate with any lawful organisations, including trade unions and labour organisations, is respected.
• Employees who have associations will not be discriminated against. 

3.6   Compensation & Benefits

• Fair wages and benefits in accordance to the local labour laws and regulations shall be provided.
• Overtime wages will be calculated and provided in accordance to local labour laws and regulations. 

3.7   Health and Safety

• A safe and heathy working environment will be provided for all employees.
• Adequate measures will be undertaken to minimise and prevent accidents and injuries during the course of work.
• Markono will adhere to the local legal health and safety requirements.
• Markono will put in place processes in accordance to the standards of ISO 45001. 

3.8   Environmental

• Markono conducts its business in compliance with all applicable environmental laws, rules and regulations.
• Markono will put in place processes in accordance to the standards of ISO 14001 and fulfil the commitments set out in the Environmental and Sustainable Procurement policies in relation to: 
  • Energy consumption and conservation as well as reduction of GHG emissions
  • Water pollution and conservation
  • Air pollution
  • Waste, chemical and hazardous / prohibited substances management
  • Environmental services and advocacy
  • Product lifecycle

3.9   Business Integrity

• Markono is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices.
• Markono employees are prohibited from soliciting or accepting any gifts without approval.
• Please see Anti-Bribery and Corruption Policy (Appendix B).

3.10  Competition

• Markono believes in operating in a free and open market, and we are committed to comply with the competition laws applicable in the countries in which we operate in.
• We will not engage in commercial strategies which could violate competition laws regarding monopolisation, or abuse a dominant position in any market.

3.11 Discrimination

• Markono believes in being respectful, inclusive and non-discriminatory towards all employees and suppliers.  
• We do not discriminate against our employees (current or potential) on the basis of age, sex, marital status, race, sexual orientation, disability, ethnic origin etc.  All of these are unacceptable in an organization that wants to be sustainable and abide by ESG norms and expectations. 
• All employees are entitled to dignity at work. 
• The company adopts an equal opportunities policy to ensure that there we are in accordance with the law.  The characteristics of equal opportunities should be applicable to all individuals interacting with the organization, from individuals coming in for an interview, to those that are employees, suppliers or even customers.
• Everybody interacting with Markono has the right to dignity.

4. Implementation of Policy

Markono is committed to integrating the policy into its processes and management systems, and also will also work collaboratively with its external partners to drive full compliance of this policy throughout the supply chain and business processes. Markono employees may raise concerns about malpractices or impropriety through whistleblower@markono.com.  Please see Whistleblowing Policy (Appendix D). 

5. Continuous Improvement and Review

Markono commits to review the policy periodically so as to ensure continuous improvements, adequacy and effectiveness of the policy.  The review will be routinely conducted at the monthly Corporate Management Meeting (CMM).

6. Queries on Policy

If you have any questions or require any clarifications on the policy, please email hr@markono.com

I confirm that I understand and agree to work towards full compliance with Markono’s Social Compliance Policy.

The core values of Markono affirmed the five principles of conduct to guide our behaviour.

Markono expects all employees to abide by this Code of Conduct in carrying out their duties and functions so as to preserve public trust and to ensure Markono’s sustainable growth and development.

1) Passion

Markono employees are expected to proactively take action without waiting for instructions and go the extra mile for both customers and colleagues.

2) Respect

Markono employees are expected to treat people, customers, partners and suppliers with dignity and respect. We strive to foster a positive, open environment with avenues for honest constructive feedback and coaching.

3) Integrity

Markono employees are to maintain professional ethics and integrity in all work dealings. Employees will take proper measures to ensure that there is no conflict between their personal interests and their responsibility to Markono and all its stakeholders.

4) Nimble

Markono employees are to embrace innovation and change across all aspects of our business as we look to seize every opportunity to respond to the changing needs of our customers.

5) Teamwork

Markono employees are expected to collaborate, share knowledge and experiences with others so as to help one another succeed. We respect and value diversity, and know that by working as a team, we can produce better results than any of us can achieve alone.

1. Purpose

1.1 Markono Group Pte Ltd (“Markono”) is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices.

1. The purpose of this policy:
   A. sets out Markono’s position agai st bribery and corruption; and
   B. provides guidance to all Markono employees, wherever they are located, on recognising and dealing with bribery and corruption issues.

2. Our Policy

2.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption.

2.2 All employees may not, directly or indirectly, offer, give, accept, or solicit anything of value to or from any third party in order to secure or reward an improper benefit or improper performance of a function or activity.

2.3 Prohibited payments or offers are impermissible at all times, whether or not they are given to a Government Official or an employee of a non-governmental business or entity, and regardless of whether they are given by another person or entity on behalf of Markono.

2.4 This policy extends to all of Markono’s domestic and foreign operations, without exception, including operations conducted by any of Markono’s subsidiaries, affiliates, or other representatives and to the operations of any joint venture in which Markono is a participant.

2.5 This policy should be read in conjunction with Markono’s Employee Handbook.

3. Gifts and Entertainment

3.1 Giving and receiving gifts, as well as entertaining and being entertained, are accepted practices in many countries when negotiating or conducting business with third parties. However, if the value of the gift or entertainment becomes too large, it can affect, or be seen to affect, business judgment. It can also create expectations of special treatment.

3.2 All gifts and entertainment given or received must be of a reasonable value and appropriate to the business relationship in question. All gifts must be declared to HR. Employees can keep the gift only after an assessment by HR that the value of the gift does not exceed SGD150.

4. Guidance on Identifying Bribery

4.1 This is a list of potential red flag scenarios which may raise concerns under anti-bribery and anti-corruption laws. Note that this list is intended to serve as examples and is not exhaustive.

1. A Third Party insists on receiving a commission or fee payment before committing to sign up to a contract with Markono, or carrying out a government function or process for Markono.
2. A Third Party requests payment in cash and/or refuses to sign a formal contract or to provide an invoice or receipt for a payment made.
3. A Third Party requests that payment is made to a country or geographic location different from where the Third Party resides or conducts business.
4. A Third Party requests an unexpected additional fee or commission to “facilitate” a service or a
   Request for Proposal (RFP).
5. A Third Party demands lavish entertainment, hospitality or gifts before commencing or continuing contractual negotiations or provision of services.
6. A Third Party requests that a side payment (not a Service Level Agreement (SLA) credit for a SLA violation) be made to “overlook” potential legal violations
7. A Third Party requests that employment or some other advantage be provided to a friend or relative.

5. Record-keeping

5.1 Employees must ensure that all expenses claims relating to hospitality, gifts or entertainment are submitted to Finance in a timely and accurate manner. The reason for the expenditure must also be stated clearly.

5.2 All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts will be kept “off-book” to facilitate or conceal improper payments.

6. Reporting

6.1 Any employee who is asked to provide or is offered anything of value in a manner that is prohibited by this policy or suspects that another Markono employee, associated person or anyone else is engaging in conduct that this policy prohibits, must report it to a manager as soon as possible.

6.2 You may also email whistleblower@markono.com to raise your concerns.

7. Protection

7.1 Those who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

7.2 Markono is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corrupt activities or because of reporting their suspicions in good faith that an actual or potential bribery or other corruption offence has taken place or may take place in the future.

7.3 If you believe that you have suffered any such treatment, please inform your manager or the Whistleblower Committee at whistleblower@markono.com.

8. Monitoring and Review

8.1 Markono will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness. Improvements identified will be made as soon as possible.

8.2 Employees are invited to comment on this policy and suggest ways in which it might be improved through hr@Markono.com.

Markono Group Pte Ltd (“Markono”) is committed to the highest standards of openness, integrity and accountability.

An important aspect of corporate governance is a mechanism to enable employees and other members of the company to voice concerns in a responsible and effective manner.  When an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation, then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of line management (although in relatively minor instances the line manager would be the appropriate person to be told).

It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety.  It is not designed to question financial or business decisions taken by Markono nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or other procedures.  Once the "whistleblowing” procedures are in place, it is reasonable to expect employees to use them rather than air their complaints outside Markono.

1.0  PURPOSE

This policy provides employees with information and procedures on whistleblowing. 

2.0 SCOPE

This policy is designed to enable employees of Markono to raise concerns internally and at a high level as well as to disclose information which the individual believes shows malpractice or impropriety.  These concerns could include

• Discrimination
• Harassment
• Child and forced labour
• IT security breaches
• Financial malpractice or impropriety or fraud
• Failure to comply with a legal obligation or statutes
• Dangers to Health and Safety or the environment
• Criminal activity
• Improper conduct or unethical behaviour
• Attempts to conceal any of these

3.0     SAFEGUARDS

3.1 Protection

This policy is designed to offer protection to those employees of Markono who disclose such concerns provided the disclosure is made:

• In good faith
• In the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person (see below).  It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure.   

3.2 Confidentiality

Markono will treat all such disclosures in a confidential and sensitive manner.  The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation.  However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

3.3 Anonymous Allegations

This policy encourages individuals to put their names to any disclosures they make.  Concerns expressed anonymously are much less credible, but they may be considered at the discretion of Markono.

In exercising this discretion, the factors to be taken into account will include:

• The seriousness of the issues raised
• The credibility of the concern
• The likelihood of confirming the allegation from attributable sources 

3.4  Untrue Allegations

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual.  In making a disclosure the individual should exercise due care to ensure the accuracy of the information.  If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual. 

4.0 PROCEDURES FOR MAKING A DISCLOSURE 

4.1 Markono takes whistleblowing seriously.  Whistleblowers may raise any concerns or make any disclosures about improper practices listed in paragraph 2.0 via the dedicated email address whistleblower@markono.com. 

4.2 All reports must be made formally in writing via email with full details and background information of the allegations.

4.3 The following information should be provided, if available:

1. Brief description of the fraud / corruption / wrongdoing committed
2. The date, location and how the alleged fraud / corruption / wrongdoing was committed
3. Identity of the alleged party
4. Particulars of witnesses, if any
5. Supporting evidence or documentation
6. Other details deemed to be useful for review or investigation 

4.4 Where possible, the whistleblower is encouraged to disclose his/her personal details (i.e. name and contact details) as the reporting party or Investigating Officer may be required to make a statement or provide evidence as part of the investigative process or in reporting the matter to any relevant law enforcement authority.  

5.0 HOW MARKONO WILL RESPOND 

On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated Investigating Officer (IO) as follows: 

If there is evidence of criminal activity then the IO should inform the police. Markono will ensure that any internal investigation does not hinder a formal police investigation.

6.0     TIMELINES

Due to the varied nature of these sorts of complaints, which may involve internal investigators and / or the police, it is not possible to lay down precise timelines for such investigations.  The IO should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

The IO, should as soon as practically possible, send a written acknowledgement of the concern to the complainant and thereafter report back to them in writing the outcome of the investigation and on the action that is proposed.  If the investigation is a prolonged one, the IO should keep the complainant informed, in writing, as to the progress of the investigation and as to when it is likely to be concluded.

All responses to the complainant should be in writing and sent to their home address.

7.0     INVESTIGATING PROCEDURE

The IO should follow these steps:

• Full details and clarifications of the complaint should be obtained.
• The IO should inform the member of staff against whom the complaint is made as soon as is practically possible.  The member of staff will be informed of their right to be accompanied by a trade union or other representative at any future interview or hearing held under the provision of these procedures.
• The IO should consider the involvement of the Company Auditors and the police at this stage and should consult with the Chairman / Managing Director.
• The allegations should be fully investigated by the IO with the assistance where appropriate, of other individuals / bodies.
• A judgement concerning the complaint and validity of the complaint will be made by the IO. This judgement will be detailed in a written report containing the findings of the investigations and reasons for the judgement.  The report will be passed to the Managing Director as appropriate.
• The Managing Director will decide on the action to take.  If the complaint is shown to be justified, disciplinary or other appropriate company procedures may be invoked.
• The complainant should be kept informed of the progress of the investigations and, if appropriate, of the final outcome.
• If appropriate, a copy of the outcomes will be passed to the Company Auditors to enable a review of the procedures. 

If the complainant is not satisfied that their concern is being properly dealt with by the IO, they have the right to raise it in confidence with the Managing Director. 

8.0 DOCUMENT FILING

All findings and letters will be filed in the respective employee’s personnel file. 

9.0 RESPONSIBILITY

The HR Department is overall responsible for the implementation of this policy.

 

Markono is committed to maintaining a work environment that is safe from harassment for its employees.  Every employee shall be treated with respect and dignity.  No employee shall be subject to any physical, psychological, verbal or sexual abuse.  Employees should be culturally sensitive, tolerant and respectful towards each other, taking into consideration the workplace environment and Singapore’s multi-culturalism. 

This policy extends to dealing with incidents involving external customers/stakeholders who conduct themselves in a manner that constitutes harassment of the employees, within and beyond company premises.

Definitions of Workplace Harassment
Workplace harassment can occur when one party at the workplace demonstrates behaviours that cause or is likely to cause harassment, alarm or distress to another party.  Such behaviour can violate a person’s dignity or create an unfavourable work environment for him/her, which poses a risk to the person’s safety and health.

Workplace harassment can take different forms. Examples of behaviour that may be considered harassment include but are not limited to:

• Threatening, abusive or insulting language, comments or other non-verbal gestures
• Physical violence
• Bullying, including cyber-bullying
• Sexual harassment
• Stalking

Workplace harassment can also take place through different modes of communications, such as email, text messaging or social media. It can occur outside of the office space, such as on business trips, clients’ premises or other work-related occasions.

Workplace harassment can be directed at and/or carried out by:

• Co-workers
• Managers
• Other people at the workplace e.g. customers, contractors, interns and volunteers

Workplace harassment cases may also be addressed under the Prevention of Harassment Act (POHA) – an Act to protect persons against harassment and unlawful stalking and to create offences, and provide civil remedies related thereto or in relation to false statements of fact.

Early Prevention
Markono has a set of Core Values, our code of conduct, to guide behaviours, that will be communicated to and complied with by all employees.  Managers, supervisors and employees at all levels need to be professional in their own behaviour and ensure that appropriate standards of behaviour are maintained in the workplace.  Managers and supervisors should identify potential acts of harassment either within Markono or by external customers/stakeholders against employees through regular communications with their employees.

Once an incident is raised, the manager/supervisor must talk with the parties concerned and ensure that appropriate action is taken to manage the issue at the onset. The manager/supervisor should also advise the affected person to make a police report if the case contravenes the POHA.  A safe environment should be provided for the employee to speak up about their discomfort and concerns to allow for early intervention.

For the reporting procedure, please refer to the Employee Handbook.