February 27, 2019

Corporate Social Responsibility

Labor and Human Rights Policy

As a company who places corporate social responsibility at the core of its operations and committed to fair and transparent labor practices, the terms of this policy serves to enshrine and enforce the key values of Wanco Manpower Pte Ltd, as well as allow for internal and external supervision.

The content of this Policy is inspired by the fundamental compacts governing international labor practices, whose letter and spirit Wanco Manpower Pte Ltd have upheld and will continue to uphold. These include, but are not limited to: the UN Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the Code of Conduct of the Responsible Business Alliance (RBA).

Wanco Manpower Pte Ltd is committed to, to the fullest extent possible, ensuring that the principles and terms laid out in this Policy are upheld by itself as well as all suppliers and contracting parties. As a member of the manpower industry, we strive to honor the recognized local and international standards of fairness, transparency and human welfare, and we welcome supervision from our partners, relevant agencies, and the public.

Free to Choose

Wanco ManpowerPte Ltddoes not tolerate any form of involuntary labor, such as forced, bonded (including debt bondage), coerced, or indentured labor, as well as involuntary and/or unethical prison labor and trafficked persons. We do not allow or deal with, in any form, slavery, or human trafficking. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services.

All labor – including our employees, contractors, as well as personnel we recruit or process – must be free and voluntary, and not subject to any physical, mental, or financial intimidation or pressure. All workers must be free to terminate their employment at any time.

We do not allow the employment of child labor, as defined as persons under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest, in accordance with the Part VIII of the Employment Act and the Employment of Children and Young Persons Regulations, as well as the Code of Conduct of the Responsible Business Alliance (RBA). We support legitimate workplace learning programs, as long as they comply with all relevant laws and regulations. However, workers under the age of 18 will not be allowed to participate in work that will likely jeopardize their health and/or safety, such as, but not limited to, night shifts or overtime.

We will ensure proper ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. We will ensure that appropriate support and training are provided for all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices will be at least the same wage rate as other entry-level workers performing equal or similar tasks.

Identity Documents and Freedom of Movement

Wanco Manpower Pte Ltd, as well as its suppliers and contractors, will not hold or otherwise destroy, conceal, confiscate, or deny access by workers to their original identity or immigration documents, such as government-issued identification, passports, or work permits, unless the holding of work permits is required by law.

Wanco Manpower Pte Ltd, as well as its suppliers and contractors, will not restrict the freedom of movement of all workers and employees. We place no unreasonable restrictions, formal or informal, on the ability of workers to freely enter or exit company-provided facilities, as well as within these facilities.

Freedom of Association

Wanco Manpower Pte Ltd, in accordance with local laws, will respect the right of all workers and employees to organize and join trade unions, take part in collective bargaining, and engage in peaceful assemblies of their own choosing. We will also respect the rights of workers and employees who freely choose to refrain from participating in such activities. We are committed to open dialogue between employees and employers regarding any and all working conditions and management practices, without fear of retribution or discrimination.

Non-Discrimination and Non-Harassment

Wanco ManpowerPte Ltd is committed to the principles of diversity and mutual respect in our workplaces and operations. We do not and will not engage in discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in recruitment, hiring, and employment practices such as wages, promotions, rewards, and access to training. We will provide workers, including candidates, with reasonable accommodation for religious practices. In addition, workers, including candidates, will not be subjected to medical tests or physical exams that could be used in a discriminatory way.

Wanco ManpowerPte Ltd is committed to ensuring that our employees, recruited workers, and candidates are free from harassment as well as discrimination. Employees, recruited workers, and candidates shall not be subject to discrimination, reprisal, intimidation, or harassment for any and all legal activities, including raising concerns about company practices and individual treatment.

Personal Data and Confidential Information

Wanco Manpower Pte Ltd is committed to safeguarding privileged personal data and confidential information that workers, including candidates, as well as suppliers, contractors, customers, and any other parties, place in its care. We will not divulge, transfer, or make available sensitive personal data and confidential information, except with explicit authorization from the relevant party or in compliance with relevant laws and regulations.

Wanco Manpower Pte Ltd conducts training for all of its employees and contractors on protocol for managing privileged personal data and confidential information, and holds them to the highest standard for doing so. Internally, such data and information are managed on a strictly need-to-know basis. With regards to our employees, as well as suppliers, contractors, and sub-agents, this is enforced through Non-Disclosure Agreements that prohibit the unauthorized release of such information.

Fees and Payments

Wanco Manpower Pte Ltd, including suppliers and contractors, does not require workers, including candidates, to make any payment in the form of an agent fee or any other aggregate fees. Any fees or costs charged to the workers must be disclosed, and any improper or unauthorized payments will be returned to the workers promptly.

Transparency

Wanco Manpower Pte Ltd informs all workers of all aggregate fees and costs that they are required to pay, if any, as well as the rights they enjoy as migrant workers under Singapore law and relevant labor protections. We will ensure that, prior to customer placement, all workers are informed of these rights, and that they can seek redress for any grievances through Wanco Manpower Pte Ltd or from the Ministry of Manpower, Singapore.

Enforcement

Wanco Manpower Pte Ltd practices an Open Door policy. If employees, partners, or contracting parties face any inappropriate treatment at work, or suspect any improper, unethical, or illegal practice either covered or not covered by this Policy, they are encouraged to use any internal reporting avenue they desire to raise up the matter, including talking directly to their supervisor, liaison, or the Directors. They are encouraged to stay anonymous if they feel doing so openly would cause any harm, physical, financial, or otherwise, to themselves or other relevant parties. The public is also welcome to raise issues via the company’s official contact channels.

Wanco Manpower Pte Ltd views any breach of its Code of Conduct, this Policy, or any local or international laws and regulations as an extremely serious matter. Reports of improper, unethical, or illegal behavior will be investigated thoroughly by an assigned management representative, in cooperation with relevant parties, and confidentiality would be maintained to the greatest extent possible.

Wanco Manpower Pte Ltd adheres strictly to a policy of non-retaliation. The company prohibits any attempts at reprisal or retaliation against employees, partners, or contracting parties who filed a report or raised up a matter, in good faith, regarding potential violations or unethical behavior. Any such attempt, as well as attempts to impede or interfere with an ongoing investigation or harass a relevant party, would be dealt with severely as laid out below.

Employees, partners, and contracting parties implicated in wrongdoings would be dealt with in accordance with this Policy and relevant laws and regulations, including internal disciplinary measures, nullification/non-renewal of contract, as well as legal avenues.

Compliance

Wanco Manpower Pte Ltd conducts regular audits of suppliers and contractors to ensure compliance with the Policy and the company Code of Conduct, as well as relevant laws and regulations. We maintain strong oversight for our suppliers and contractors to ensure that no case of non-compliance occurs; should any ethical issue or non-compliance take place, we expect the supplier/contractor to take appropriate action to rectify the issue without delay, in consultation with Wanco Manpower Pte Ltd.

Wanco Manpower Pte Ltd will actively work to safeguard the rights of all personnel it works with. Any worker who has experienced improper or unethical treatment, in breach of this Policy or otherwise, is welcome to raise the issue with us, and we will work with the relevant parties to resolve the issue. No reprisal or retaliation will be taken against anyone for raising issues under this Policy in good faith.