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UNDERSTANDING ALL EMPLOYMENT

ISSUES AT WIN THEIN & SONS CO., LTD

REVISED ON [24-Nov-18]

Table of Content

1. Organization Description

1.1 Introductory Statement

1.2 Customer Relations

1.3 Products and Services Provided

1.4 Facilities and Location(s)

1.5 The History of Win Thein & Sons Co., Ltd

1.6 Management Philosophy

1.7 Vision/Mission/Core Values

1.9 Employment-At-Will

1.10 Sexual Harassment

1.11 Safety

1.12 Safety Rules

1.13 Hazardous Wastes

1.14 Weapons in the Workplace

1.15 Drug Free Workplace

1.16 Prohibitions

1.17 Disciplinary Actions

2. The Employment

2.1 Nature of Employment

2.2 Employee Relations

2.3 Equal Employment Opportunity

2.4 Business Ethics and Conduct

2.5 Personal Relationships in the Workplace

2.6 Conflicts of Interest

2.7 Outside Employment

2.8 Non-Disclosure

2.9 Disability Accommodation

2.10 Job Posting and Employee Referrals

2.11 Accident and First Aid

3. Employment Status and Records

3.1 Personnel Administration

3.1.1 Employment Categories

3.2 Access to Personnel Files

3.2.1 Contents of Personnel Files

3.3 Personnel Data Changes

3.4 Probation Period

3.5 Employment Applications

3.6 Performance Evaluation

3.7 Job Descriptions

3.8 Salary Administration

3.9 Professional Development

3.9.1 Promotions

3.9.2 Transfer of Employees

3.9.3 Separation of Employment

3.9.4 Work Force Reductions

3.9.5 New Employees

3.9.6 Application for Employment

3.9.7 Confirmation of Previous Employment

3.9.8 Compliance Information

3.9.9 Physical Examination Prior to Employment

3.10 Screening and Testing

3.10.1 Motor Vehicle Record

3.10.2 Process Improvement

3.10.3 Employee-Management Forums

3.10.4 Employee Suggestion Program

4. Employee Benefit Programs

4.0 Benefit Eligibility

4.1 Employee Benefits

4.1.1 Attendance & Leave

4.2 Vacation Benefits

4.2.1 Vacation Eligibility

4.2.2 Vacation Schedules

4.2.3 Vacation Pay

4.3 Military Service Leave

4.4 Religious Observance

4.5 Holidays

4.6 Workers Insurance

4.7 Medical Leave Benefits

4.8 Bereavement Leave

4.9 Relocation Benefits

4.10 Educational Assistance

4.11 Health Insurance

4.12 Life Insurance

4.13 Long Term Disability

4.14 Marriage, Maternity and Parental Leave

4.15 Civic Leave or Jury Duty

4.16 Voting

4.17 Leave of Absence

4.2 Miscellaneous Benefits

4.2.1 Break Room

4.2.2 Employee Discounts

4.2.3 Company Sponsored Events

5. Timekeeping / Payroll

5.1 Timekeeping

5.1.1 Payroll Information

5.2 Paydays

5.2.1 Salary Compensation for Partial Pay Period

5.2.2 Pay Rate Schedule – Hourly Paid Employees

5.2.3 Payroll Deduction

5.2.4 Overtime

5.2.4 Payroll Errors

5.2.5 Authorized Check Pickup

5.2.6 Pay at Time of Separation

5.3 Employment Termination

6. Work Conditions and Hours

6.1 Work Schedules

6.1.0 Working Hours

6.1.1 Salary Employees

6.1.2 Hourly Employees

6.2 Use of Phone and Mail Systems

6.3 Smoking

6.4 Meal Periods

6.5 Overtime

6.6 Use of Equipment

6.7 Emergency Closing

6.8 Business Travel Expenses

6.8.1 Transportation & Travel

6.8.2 Company Owned Vehicle

6.8.3 Personal Vehicle

6.8.4 Expense Records

6.8.5 Travel Advances

6.8.6 Expense Reimbursement – Third Party

6.8.7 Expense Policies – Violations

6.8.8 Company Credit Cards

6.8.9 Appearance & Belongings

6.8.10 Personal Appearance

6.8.11 Business Attire

6.8.12 Casual Attire

6.8.13 Inappropriate Attire

6.8.14 Personal Belongings

6.8.15 Alcohol and Drugs

6.8.16 Medication

6.9 Visitors in the Workplace

6.9.1 Parking

6.10 Computer and Email Usage

6.11 Internet Usage

6.12 Workplace Monitoring

6.13 Workplace Violence Prevention

6.14 Equipment & Facilities

6.15 Motor Vehicle and Workplace Equipment Operation

6.16 Safety Equipment

6.17 Company Tools

6.18 Waste Prevention

6.19 Solicitation and/or Distribution

6.20 Bulletin Board

7. Employee Conduct & Disciplinary Action

7.1 Employee Conduct and Work Rules

7.2 Sexual and Other Unlawful Harassment

7.3 Attendance and Punctuality

7.4 Personal Appearance

7.5 Return of Property

7.6 Resignation and Retirement

7.7 Security Inspections

7.8 Progressive Discipline

7.9 Problem Resolution

7.10 Workplace Etiquette

7.10.1 Legal & Ethical Conduct

7.11 Suggestion Program

8. Forms

8.1 Acknowledgement of Receipt and Understanding

8.2 Statement of Legal and Ethical Business Conduct

8.3 Social Media Policy & Acknowledgement

8.4 Job Related Incidents

Welcome to Win Thein & Sons Co., Ltd!

On behalf of your colleagues, we welcome you to Win Thein & Sons Co., Ltd and wish you every success here.

At Win Thein & Sons Co., Ltd, we believe that each employee contributes directly to the growth and success of the company, and we hope you will take pride in being a member of our team.

This handbook was developed to describe some of the expectations of our employees and to outline the policies, programs, and benefits available to eligible employees. Employees should become familiar with the contents of the employee handbook as soon as possible, for it will answer many questions about employment with Win Thein & Sons Co., Ltd.

We believe that professional relationships are easier when all employees are aware of the culture and values of the organization. This guide will help you to better understand our vision for the future of our business and the challenges that are ahead. We hope that your experience here will be challenging, enjoyable, and rewarding.

Again, welcome!

U Win Thein

President & CEO

1. Organization Description

1.1 Introductory Statement

This handbook is designed to acquaint you with Win Thein & Sons Co., Ltd and provide you with information about working conditions, employee benefits, and some of the policies affecting your employment. You should read, understand, and comply with all provisions of the handbook. It describes many of your responsibilities as an employee and outlines the programs developed by Win Thein & Sons Co., Ltd to benefit employees. One of our objectives is to provide a work environment that is conducive to both personal and professional growth.

No employee handbook can anticipate every circumstance or question about policy. As Win Thein & Sons Co., Ltd continues to grow, the need may arise and Win Thein & Sons Co., Ltd reserves the right to revise, supplement, or rescind any policies or portion of the handbook from time to time as it deems appropriate, in its sole and absolute discretion. Employees will be notified of such changes to the handbook as they occur.

1.2 Customer Relations

Customers are among our organization's most valuable assets. Every employee represents Win Thein & Sons Co., Ltd to our customers and the public. The way we do our jobs presents an image of our entire organization. Customers judge all of us by how they are treated with each employee contact. Therefore, one of our first business priorities is to assist any customer or potential customer. Nothing is more important than being courteous, friendly, helpful, and prompt in the attention you give to customers.

Win Thein & Sons Co., Ltd will provide customer relations and services training to all employees with extensive customer contact. Customers who wish to lodge specific comments or complaints should be directed to the relevant manager for appropriate action. Our personal contact with the public, our manners on the telephone, and the communications we send to customers are a reflection not only of ourselves, but also of the professionalism of Win Thein & Sons Co., Ltd. Positive customer relations not only enhance the public's perception or image of Win Thein & Sons Co., Ltd, but also pay off in greater customer loyalty and increased sales and profit.

1.3 Products and Services Provided

You will find more information about our products and services by reading the Win Thein & Sons Co., Ltd Corporate Brochures.

1.4 Facilities and Location(s)

Head Office: No. (79/81), Room #705~706, Central Tower, Anawrahta Road, 39th & 40th Street, kyauktada Tsp Yangon, Yangon 11182 Myanmar

1.5 The History of Win Thein & Sons Co., Ltd

The Win Thein & Sons Group is one of the prominent and illustrious business group in Myanmar. We are specialized and professional in auto parts and steel business sector as well as providing a diverse range of services including logistics & transportation.

Headquartered in Yangon, Myanmar, Win Thein & Sons Company has more than 17 years of operating experience and played a pivotal role in respective markets.

Royal Rose Trading, our subsidiary in Singapore, is well established, leading in import and export business, constantly raising the bar in providing quality products and services towards our devoted customers.

We are also strategically invested in our subsidiaries across Myanmar, comprising of auto parts, steel and logistics, tailoring toward excellence and distinguished in delivering services that our customers want, each subsidiary operates dependently under the guidance and supervision of WTSC board of directors.

We work closely and amicably with our suppliers, leveraging our scale in particular markets, customer reach and extensive operational experience to lead and be successful in respective industries. Together, the Group serves substantial number of customers across Myanmar.

Win Thein & Sons Group is one of the widely-known company in Yangon, Myanmar, renowned for its distinctive or quality products and services. The Group has a vast network of offices throughout Myanmar and employs more than 100 staffs.

1.6 Management Philosophy

Win Thein & Sons Co., Ltd management philosophy is based on responsibility and mutual respect. Our wishes are to maintain a work environment that fosters on personal and professional growth for all employees. Maintaining such an environment is the responsibility of every staff person. Because of their role, managers and supervisors have the additional responsibility to lead in a manner which fosters an environment of respect for each person.

People who come to Win Thein & Sons Co., Ltd want to work here because we have created an environment that encourages creativity and achievement. Win Thein & Sons Co., Ltd aims to become a leader in general trading which encompass selling of automotive spare parts, steel products and providing logistics services across the nation. The mainstay of our strategy will be to offer a level of client focus that is superior to that offered by our competitors.

To help achieve this objective, Win Thein & Sons Co., Ltd seeks to attract highly motivated individuals that want to work as a team and share in the commitment, responsibility, risk taking, and discipline required to achieve our vision. Part of attracting these special individuals will be to build a culture that promotes both uniqueness and a bias for action. While we will be realistic in setting goals and expectations, Win Thein & Sons Co., Ltd will also be aggressive in reaching its objectives. This success will in turn enable Win Thein & Sons Co., Ltd to give its employees above average compensation and innovative benefits or rewards, key elements in helping us maintain our leadership position in the worldwide marketplace.

This Employee Handbook is a guide to our Company practices. It is not a contract for employment, either expressed or implied, nor does it guarantee any terms or conditions of employment. The Company is an “At-Will” employer and the Company or employees have the right to terminate employment at any time, with or without notice and with or without cause except for fixed-term contract.

The Company should maintain a pleasant working environment in order to provide each employee the opportunity to excel in their work. General conditions such as safety, cleanliness, and employee accommodations should be evaluated periodically for improvement with good industry practice. Management should meet monthly with team leaders to discuss suggested improvements in working conditions.

The Company expects the employee’s and management staff to abide by the policies set forth in this Employee Handbook. Overall, the Company expects employee’s to devote their best efforts to expanding business opportunities in a work atmosphere for all to prevail.

1.7 Vision/Mission/Core Values

Vision

To be the leader in respective markets that we conduct businesses, distinguished by innovativeness and dedication to our customers.

Mission

We provide reliable and superiority services to our customers, as well as supplying authentic and bona fide products. We consider truthful and have confidence that creating and delivering value to our customers, employees and others is radical to our business.

Core Values

Win Thein & Sons’s Core Values underpin our desire to create a uniformity of purpose across the Group. They reflect our common expectation to foster a performance-based culture that is distinctive and reliable, and that promotes mutual trust and engagement.

Customer Focus

Our success is based upon our customer focus. We listen to, and connect with, customers and treat them with dignity and respect. By understanding and anticipating their needs, we make it easy for our customers to do business with us. We aim to offer them value and quality services to enrich lives and enhance business success.

Cooperate Governance

Win Thein & Sons aspires to the highest standards of corporate governance as we believe that good governance supports long-term value creation. To this end, Win Thein & Sons group has in place a set of well-defined policies and processes to enhance corporate performance and accountability, as well as protect the interests of stakeholders. The Board of Directors is responsible for Win Thein & Sons corporate governance standards and policies, and stresses their importance across the Group.

The Group Structure

Consumer

Our Consumer operations focus on setting new benchmarks in customer experience to cement the Group's position as the leading provider of quality products and services to consumers across Myanmar. We serve consumers in Yangon, Mandalay, Naypyidaw and emerging markets through our regional offices. Like Win Auto Parts and Win Iron & Steel, Nay Zin Min Logistics and Royal Rose Trading are all established brands in their respective markets and share our commitment to continually invest in our brands, networks, processes to deliver a superior customer experience.

Group Enterprise

Group Enterprise consists of several business sectors yet one prominent service that provides companies, shops and others, the integrated customized logistics service is Nay Zin Min, with a strong focus on compliance, quality, health and safety and the environment. With comprehensive and integrated logistics solutions that cover every aspect of logistics business, we are committed to reliability and affordable cost.

As a part of prominent figure in logistics field, our suite of logistics solutions is backed up by an extensive real-time management and infrastructure that spans across key business cities and markets in the region.

Challenger Spirit

The reliability and expertise of our people set us apart. We look for better ways of doing business and share a passion for making a difference. When faced with challenges and opportunities, we do not say “No” but say “We can do this”. We are tenacious and we compete fairly.

Teamwork

By working as one team with shared goals, we believe we can achieve great things. We value ideas and contributions from everyone. We recognize, respect and value diversity in the team. We develop strong bonds by communicating and sharing knowledge. We encourage open discussion and commit to an agreed position. All of us have a part to play.

Integrity

Our reputation is based upon our ability to fulfill promises to customers and employees. We do so by being honest in our dealings, taking responsibility and being accountable for our actions. We treat everyone the way we would like to be treated. We are proactive in identifying issues and coming up with solutions. We ensure that the highest ethical standards guide us in making decisions.

Personal Excellence

Leadership and superior performance are achieved through the pursuit of personal excellence. We are committed to doing and being the best. We seek continuous improvement and take pride in what we do. We do things to the highest possible standards. We acknowledge the potential of the individual and create opportunities for all to grow and excel. Together, we celebrate our success and achievements.

1.9 Employment-At-Will

The Company may dismiss at any time an employee who was hired for an indefinite period, for any reason or no reason, without incurring any liability to the employee. This general rule is often referred to as “employment at will.”

All employment and compensation with The Company is “at will.” Neither the Company, any of its managers nor any other employee can guarantee a specific duration of employment. The Company recognizes that circumstances change with the passage of time and that some employees may seek opportunities elsewhere or choose to leave the Company for other reasons.

Others may not fulfill the operational needs of the Company or changed circumstances may reduce available employment opportunities, which may result in involuntary terminations. Employees may leave employment at any time with or without a reason. Likewise, the Company reserves the right to terminate any employee at any time within the provisions of Federal and State laws. The exception is for those hired under fixed-term contract. Employment shall be terminated by either party with penalties or compensations expressed in the employment contract.

1.10 Sexual Harassment

In accordance with guidelines issued by the Equal Employment Opportunity Commission on discrimination because of sex, sexual harassment of employees is a prohibited personnel practice and the Company strongly disapproves of such conduct. Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of sexual nature constitute sexual harassment when:

  • Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment.
  • Submission to or rejection of such conduct by an individual is used as the basis for an adverse employment decision(s) affecting the individual.
  • Such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment.

No supervisor, co-employee, or non-employee shall threaten or suggest that an employee’s refusal to submit to sexual advances should adversely affect the employee’s employment, wages, advancement, assigned duties, shifts, or any other condition of employment.

Other types of prohibited conduct by supervisor, co-employees, or non-employees include sexual advances, propositions, verbal abuse of a sexual nature, suggestive touching, suggestive gestures and comments, graphic verbal descriptions of an individual’s body, and the display in the work place of sexually suggestive objects or pictures.

If an employee believes that he or she is being subjected to sexual harassment, the employee should personally and immediately notify a manager.

An investigation should be undertaken and appropriate sanctions and corrective measures should be instituted if the employee’s allegations warrant such action. Persons who commit acts of intimidation and harassment should be admonished to discontinue such conduct and should be disciplined. Appropriate discipline may include actions up to and including termination of employment. Employees are assured that this procedure has been established for their benefit. No employee should be penalized for registering a harassment complaint. The firm is dedicated to removing all forms of sexual harassment and is committed to a prompt and impartial investigation and resolution of any complaints.

The Company accepts no responsibility or liability for harassment of one employee by another. Any employee involved in the sexual harassment of another is personally responsible for any legal or financial cost resulting from a legal complaint filed against them and is personally liable for their individual actions. Please direct any questions or comments regarding this matter to the general manager.

1.11 Safety

The Company is committed to the safety of its employees and its property and equipment. To this end, we should utilize a safety program in our daily activities. Disregard of any Company safety rule and regulation may result in disciplinary action including termination of employment.

It is necessary that the Company establish safety rules and regulations to be observed by all employees at all times. With regard to these rules, the following should be considered standard procedure for all employees:

All questions concerning the reason for doing something in a certain manner may be asked of any member of management at any time. The employee should inform the Human Resource Department in the event that a safety regulation is modified that may compromise an employee’s safety.

Employee’s decisions should always be guided by the Company’s commitment to safety. Should a hazardous situation or condition exist and a decision has to be made on safety or production, safety concerns should always take precedence over production.

It is the responsibility of each manager and supervisor to see that every employee at the Company is provided with safe working conditions, all safety regulations are observed and employees use good common sense to protect themselves as well as others.

Management and supervisors should periodically inspect working conditions and may suspend all work activity until an unsafe condition is corrected.

The most important part of safety is the employee himself. It is the responsibility of each employee to abide by the safety rules; these rules are made for your protection. Employees are expected to report any personal injury immediately, however minor and to all dangerous conditions and practices to the personnel department.

1.12 Safety Rules

Besides the following listed safety rules, each employee should make himself familiar with the work place and check if there are any additional special safety rules in the designated work area.

  • First aid supply kits are provided in the work area. It is the responsibility of the supervisors to see that the kits remain well stocked.
  • Know where the fire extinguishers are located and how to use them.
  • All defective materials or tools must be brought to the attention of the supervisor and not remain on the job.
  • The Company if necessary should provide safety glasses. They should be used at all times while working in the production areas of the plant.
  • The Company should provide hearing protection for jobs that require such devices.
  • Wear clothes suited for the job. Do not wear open toed shoes.
  • Practice good housekeeping. Keep work area clean and free from stumbling hazards, grease, etc.
  • Learn to lift the correct way. Bend knees. Keep back erect. Get help for heavy loads.
  • No scuffling or horseplay on the job.
  • Do not run within the work area.
  • Do not allow raw material, finished goods, or trash to be in aisles or stairways.
  • Employees must be sure that their actions do not endanger other employees or damage Company or personal property.
  • Keep guards and protective devices in place at all times.
  • Use tools only for their intended purposes. Do not use broken or dangerously dull tools.
  • Do not attempt to operate special machinery or equipment without permission and instructions.
  • Do not repair or adjust machinery while it is in operation and never oil moving parts except on equipment fitted with safeguards for this purpose.

1.13 Hazardous Wastes

The Environmental Protection Agency has classified certain chemicals and chemical groups into categories, which have been classified as toxic. This means that in concentrated forms or by accumulating and combining with other chemicals (even with air) these chemicals can be hazardous to human health if exposure occurs.

As a Company, we are committed to preventing the creation or disposal of hazardous wastes, which may contaminate the environment. We should choose materials, which have been judged as non-hazardous whenever this is possible, and properly dispose of hazardous materials if used. We also should not knowingly dump any wastes into the environment at any time.

We should inform employees how to control hazardous wastes and what to do if they are exposed to hazardous wastes. If any employee suspects that the wastes they may encounter as an employee are hazardous they should inform management immediately.

1.14 Weapons in the Workplace

Weapons are not permitted in the workplace regardless of the fatal or non-fatal.

All personnel entering Company property are prohibited from carrying knives, handguns, firearms, or other prohibited weapons of any kind, with the exception of security personnel who may be acting within the scope of their responsibility of an official capacity.

A violation of the Weapons Policy may result in disciplinary action, up to and including termination of employment, at the Company’s sole discretion.

1.15 Drug Free Workplace

In response to federal requirements for drug-free workplaces, and in keeping with the Company concern for the health and safety of its work force, the Company has instituted the following Drug-Free Workplace Policy:

• This policy certifies the Company’s intent to maintain a drug-free workplace. The first section describes the prohibitions of this policy such as the manufacture, distribution, sale, possession, or use of a controlled substance in the workplace.

• The last section of this policy lists the disciplinary actions that employees should face for any violation of the Company’s Drug-Free Workplace Policy. Finally, an employee acknowledgement must be signed and dated by each employee who receives a copy of this policy.

The Drug-Free Workplace Act specifically requires the Company to notify each employee that, as a condition of employment, each employee must:

• Comply with the Company's Drug-Free Workplace Policy.

• Notify The Company of any conviction for drug-related offense committed in the workplace within three (3) days of conviction.

• Any employee who violates this Company policy should be subject to disciplinary action including termination of employment.

1.16 Prohibitions

The Company’s Drug-Free Workplace prohibits employees from engaging in any of the following activities:

  • Use, possession, manufacture, distribution, dispensation, or sale of illegal drugs on Company premises or Company business, in Company supplied vehicles, or during working hours.
  • Unauthorized use or possession, or any manufacture, distribution, dispensation, or sale of a controlled substance on Company premises or while on Company business or while in Company supplied vehicles.
  • Storing in a locker, desk, automobile, or other repository on Company premises any controlled substances whose use is unauthorized.
  • Being under the influence of a controlled substance on Company premises or while on Company business, or while in Company supplied vehicles.
  • Any possession, use, manufacture, distribution, dispensation, or sale of illegal drugs off Company premises that adversely affects the individual's work performance, their own or the safety of others at work, or the Company’s regard or reputation in the community.
  • Failure to adhere to the requirements of any drug treatment or counseling program in which the employee is enrolled.
  • Failure to notify The Company of any conviction under criminal drug statutes for a workplace offense within three days of the conviction;
  • Refusal to sign a statement to abide by The Company’s Drug-Free Workplace policy.
  • Unauthorized Use of Prescribed Medicine. An employee undergoing prescribed medical treatment with a drug, which may alter their physical or mental ability, must report this treatment to the Company’s HR Department. The HR Manager should determine whether a temporary change in the employee’s job assignment is warranted during the period of treatment.

1.17 Disciplinary Actions

A violation of the Company’s Drug-Free Workplace Policy may result in disciplinary action, up to and including termination of employment, at the Company’s sole discretion.

In addition to any disciplinary action, the Company may, in its sole discretion, refer the employee to a treatment and counseling program for drug abuse. Employees referred to such a program by the Company must immediately cease any drug use, may be subject to periodic unannounced testing for a period of twenty-four month, and must comply with all other conditions of the treatment and counseling program.

The Company shall determine whether an employee if referred for drug treatment and counseling should be temporarily reassigned to another position for safety reasons. The Company should promptly terminate any employee who tests positive for drugs while undergoing treatment and counseling for drug abuse.

2. The Employment

2.1 Nature of Employment

Employment with Win Thein & Sons Co., Ltd is voluntarily entered and the employee is free to resign at any time, with or without cause. Similarly, Win Thein & Sons Co., Ltd may terminate the employment relationship at will at any time, with or without notice or cause, so long as there is no violation of applicable Myanmar Employment law. There are some exceptions for those hired under fixed-term contract. An employee should refer to the relevant employment contract.

Policies set forth in this handbook are not intended to create a contract, nor are they to be construed to constitute contractual obligations of any kind or a contract of employment between Win Thein & Sons Co., Ltd and any of its employees. The provisions of the handbook have been developed at the discretion of management and, except for its policy of employment-at-will, may be amended or cancelled at any time, at Win Thein & Sons Co., Ltd sole discretion.

These provisions supersede all existing policies and practices and may not be amended or added to without the express written approval of the managing director.

2.2 Employee Relations

Win Thein & Sons Co., Ltd believes that the work conditions, wages, and benefits it offers to its employees are competitive with those offered by other employers in this area and in this industry. If employees have concerns about work conditions or compensation, they are strongly encouraged to voice these concerns openly and directly to their supervisors.

Our experience has shown that when employees deal openly and directly with supervisors, the work environment can be excellent, communications can be clear, and attitudes can be positive. We believe that Win Thein & Sons Co., Ltd amply demonstrates its commitment to employees by responding effectively to employee concerns.

To protect and maintain direct employer/employee communications, we will do anything we can to protect the right of employees to speak for themselves.

2.3 Equal Employment Opportunity

The Company is built upon teamwork, equal opportunity, and is committed to developing and implementing a program of nondiscrimination and affirmative action. The Company subscribes to the principles of an equal opportunity employer and should recruit, interview, hire, classify, train, promote, demote, discipline, transfer, terminate, and set rates of pay or other compensation on the basis of merit and qualification without regard to race, religion, creed, color, national origin, physical disability, sex, or age.

The Company also subscribes to an equal employment practice for the mentally or physically handicapped as long as the handicap does not prevent or hinder continual satisfactory work performance, or unless a stated bona fide occupational qualification exists.

Any violations of the Company “Equal Employment Opportunity Policy” by an employee must be reported immediately to management. Further, management and supervisory personnel should be responsible for maintaining a work environment that is free of racial, sexual, or any other form of harassment.

The Company should cooperate with federal, state or local government agencies that have the responsibility to ensure our compliance with various laws relating to employment. Management should furnish such reports, records and other matters as requested in order to foster the program of equal opportunity for all persons regardless of race, creed, religion, color, sex, age, national origin, disabled, or physical or mental handicap according to the policies stated in the previous paragraphs.

Management, individually and collectively, has the overall responsibility of carrying out the Company’s Equal Employment Opportunity Policy in their respective work areas.

2.4 Business Ethics and Conduct

The successful business operation and reputation of Win Thein & Sons Co., Ltd is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity.

The continued success of Win Thein & Sons Co., Ltd is dependent upon our customers' trust and we are dedicated to preserving that trust. Employees owe a duty to Win Thein & Sons Co., Ltd, its customers, and shareholders to act in a way that will merit the continued trust and confidence of the public.

Win Thein & Sons Co., Ltd will comply with all applicable laws and regulations and expects its directors, officers, and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct.

In general, the use of good judgment, based on high ethical principles, will guide you with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed openly with your immediate supervisor and, if necessary, with the President, U Win Thein, for advice and consultation.

Compliance with this policy of business ethics and conduct is the responsibility of every Win Thein & Sons Co., Ltd employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including possible termination of employment.

2.5 Personal Relationships in the Workplace

The employment of relatives or individuals involved in a dating relationship in the same area of an organization may cause serious conflicts and problems with favoritism and employee morale. In addition to claims of partiality in treatment at work, personal conflicts from outside the work environment can be carried over into day-to-day working relationships.

For purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage. A dating relationship is defined as a relationship that may be reasonably expected to lead to the formation of a consensual "romantic" or sexual relationship. This policy applies to all employees without regard to the gender or sexual orientation of the individuals involved.

Although Win Thein & Sons Co., Ltd has no prohibition against employing relatives of current employees or individuals involved in a dating relationship with current employees, we are committed to monitoring situations in which such relationships exist in the same area. In case of actual or potential problems, Win Thein & Sons Co., Ltd will take prompt action, and this can include reassignment. Employees in a close personal relationship should refrain from public workplace displays of affection or excessive personal conversation.

2.6 Conflicts of Interest

Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Win Thein & Sons Co., Ltd wishes the business to operate. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation. Contact the President for more information or questions about conflicts of interest.

Transactions with outside firms must be conducted within a framework established and controlled by the executive level of Win Thein & Sons Co., Ltd. Business dealings with outside firms should not result in unusual gains for those firms. Unusual gain refers to bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, the employee, or both. Promotional plans that could be interpreted to involve unusual gain require specific executive-level approval.

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative because of Win Thein & Sons Co., Ltd business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage.

No "presumption of guilt" is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to an officer of Win Thein & Sons Co., Ltd as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.

Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which Win Thein & Sons Co., Ltd does business, but also when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Win Thein & Sons Co., Ltd.

Should you be in doubt as to whether an activity involves a conflict, you should discuss the situation with your manager.

2.7 Outside Employment

Employees may hold outside jobs as long as they meet the performance standards of their job with Win Thein & Sons Co., Ltd. All employees will be judged by the same performance standards and will be subject to Win Thein & Sons Co., Ltd scheduling demands, regardless of any existing outside work requirements.

If Win Thein & Sons Co., Ltd determines that an employee's outside work interferes with performance or the ability to meet the requirements of Win Thein & Sons Co., Ltd as they are modified from time to time, the employee may be asked to terminate the outside employment if he or she wishes to remain with Win Thein & Sons Co., Ltd.

Outside employment that constitutes a conflict of interest is prohibited. Employees may not receive any income or material gain from individuals outside Win Thein & Sons Co., Ltd for materials produced or services rendered while performing their jobs.

2.8 Non-Disclosure

The protection of confidential business information and trade secrets is vital to the interests and the success of Win Thein & Sons Co., Ltd. Such confidential information includes, but is not limited to, the following examples:

  • compensation data
  • Pending projects and proposals
  • Computer processes
  • Proprietary production processes
  • Computer programs and codes
  • Research & development strategies
  • Customer lists
  • Scientific data
  • Customer preferences
  • Scientific formulae
  • Financial information
  • Scientific prototypes

All employees are required to sign a non-disclosure agreement as a condition of employment. Employees who improperly use or disclose trade secrets or confidential business information will be subject to disciplinary action, up to and including termination of employment and legal action, even if they do not actually benefit from the disclosed information.

2.9 Disability Accommodation

Win Thein & Sons Co., Ltd is ensuring equal opportunity in employment for qualified persons with disabilities. All employment practices and activities are conducted on a non-discriminatory basis.

Hiring procedures have been reviewed and provide persons with disabilities meaningful employment opportunities. Upon request, job applications are available in alternative, accessible formats, as is assistance in completing the application. Pre-employment inquiries are made only regarding an applicant's ability to perform the duties of the position.

Reasonable accommodation is available to all disabled employees, where their disability affects the performance of job functions. All employment decisions are based on the merits of the situation in accordance with defined criteria, not the disability of the individual.

Qualified individuals with disabilities are entitled to equal pay and other forms of compensation (or changes in compensation) as well as in job assignments, classifications, organizational structures, position descriptions, lines of progression and seniority lists. Leave of all types will be available to all employees on an equal basis.

Win Thein & Sons Co., Ltd is also committed to not discriminating against any qualified employees or applicants because they are related to or associated with a person with a disability. Win Thein & Sons Co., Ltd will follow any provincial or local law that provides individuals with disabilities greater protection.

This policy is neither exhaustive nor exclusive. Win Thein & Sons Co., Ltd is committed to taking all other actions necessary to ensure equal employment opportunity for persons with disabilities in accordance with all applicable federal, provincial, and local laws.

2.10 Job Posting and Employee Referrals

Win Thein & Sons Co., Ltd provides employees an opportunity to indicate their interest in open positions and advance within the organization according to their skills and experience. In general, notices of all regular, full-time job openings are posted, although Win Thein & Sons Co., Ltd reserves its discretionary right to not post a particular opening.

Job openings will be posted on the employee bulletin board and/or in the email system as well as on company website, and normally remain open for 15 days. Each job posting notice will include the dates of the posting period, job title, department, location, grade level, job summary, essential duties, and qualifications (required skills and abilities).

To be eligible to apply for a posted job, employees must have performed competently for at least 90 calendar days in their current position. Employees who have a written warning on file or are on probation or suspension are not eligible to apply for posted jobs. Eligible employees can only apply for those posted jobs for which they possess the required skills, competencies, and qualifications.

To apply for an open position, employees should submit a job posting application to the HUMAN RESOURCES DEPARTMENT listing job-related skills and accomplishments. It should also describe how their current experience with Win Thein & Sons Co., Ltd and prior work experience and/or education qualifies them for the position.

Win Thein & Sons Co., Ltd recognizes the benefit of developmental experiences and encourages employees to talk with their supervisors about their career plans. Supervisors are encouraged to support employees' efforts to gain experience and advance within the organization.

An applicant's supervisor may be contacted to verify performance, skills, and attendance. Any staffing limitations or other circumstances that might affect a prospective transfer may also be discussed.

Job posting is a way to inform employees of openings and to identify qualified and interested applicants who might not otherwise be known to the hiring manager. Other recruiting sources may also be used to fill open positions in the best interest of the organization.

Win Thein & Sons Co., Ltd also encourages employees to identify friends or acquaintances that are interested in employment opportunities and refer qualified outside applicants for posted jobs. Employees should obtain permission from the individual before making a referral, share their knowledge of the organization, and not make commitments or oral promises of employment.

An employee should submit the referral's resume and/or completed application form to the HUMAN RESOURCES DEPARTMENT for a posted job. If the referral is interviewed, the referring employee will be notified of the initial interview and the final selection decision.

2.11 Accident and First Aid

Employees must advise management of all accidents, injuries, or illnesses that occur while at work. All accidents, injuries, or illnesses that occur while at work must be reported immediately no matter how slight they may appear.

The Company should provide the proper forms for reporting job related accidents, injuries and illnesses. Failure to report these occurrences may be cause for disciplinary action.

In the event of a vehicular accident involving a Company owned vehicle or while on Company business, employees should report all information immediately to management. In no instance should responsibility for an accident be expressed to anyone until the proper person in the Company has been notified and permission has been obtained to make statements.

3. Employment Status and Records

3.1 Personnel Administration

The Company has established a Human Resources (HR) Manager or point-of-contact, which is responsible for personnel administration. Questions regarding your employment and this Employee Handbook should be addressed to the Manager of Human Resources.

3.1.1 Employment Categories

It is the intent of Win Thein & Sons Co., Ltd to clarify the definitions of employment classifications so that employees understand their employment status and benefit eligibility.

Each employee is designated as either NONEXEMPT or EXEMPT from federal and provincial wage and hour laws. NONEXEMPT employees are entitled to overtime pay under the specific provisions of federal and provincial laws. EXEMPT employees are excluded from specific provisions of federal and provincial wage and hour laws. An employee's EXEMPT or NONEXEMPT classification may be changed only upon written notification by Win Thein & Sons Co., Ltd management.

In addition to the above categories, each employee will belong to one other employment category:

REGULAR FULL-TIME employees are those who are not in a temporary or probation status and who are regularly scheduled to work Win Thein & Sons Co., Ltd full-time schedule. Generally, they are eligible for Win Thein & Sons Co., Ltd benefit package, subject to the terms, conditions, and limitations of each benefit program.

REGULAR PART-TIME employees are those who are not assigned to a temporary or probation status and who are regularly scheduled to work less than 28 hours per week. While they do receive all legally mandated benefits, they are ineligible for all of Win Thein & Sons Co., Ltd other benefit programs.

PROBATION is those whose performance is being evaluated to determine whether further employment in a specific position or with Win Thein & Sons Co., Ltd is appropriate. Employees who satisfactorily complete the probation period will be notified of their new employment classification.

CONTRACTUAL employees are those who are hired as interim replacements, to temporarily supplement the work force, or to assist in the completion of a specific project.

Employment assignments in this category are of a limited duration. Employment beyond any initially stated period does not in any way imply a change in employment status. Temporary employees retain that status unless and until notified of a change. While temporary employees receive all legally mandated benefits, they are ineligible for all of Win Thein & Sons Co., Ltd other benefit programs.

CASUAL employees are those who have established an employment relationship with Win Thein & Sons Co., Ltd but who are assigned to work on an intermittent and/or unpredictable basis. While they receive all legally mandated benefits, they are ineligible for all of Win Thein & Sons Co., Ltd other benefit programs.

3.2 Access to Personnel Files

Win Thein & Sons Co., Ltd maintains a personnel file on each employee. The personnel file includes such information as the employee's job application, resume, records of training, documentation of performance appraisals and salary increases, and other employment records.

Personnel files are the property of Win Thein & Sons Co., Ltd, and access to the information they contain is restricted. Generally, only supervisors and management personnel of Win Thein & Sons Co., Ltd who have a legitimate reason to review information in a file are allowed to do so.

Employees who wish to review their own file should contact the HUMAN RESOURCES DEPARTMENT. With reasonable advance notice, employees may review their own personnel files in Win Thein & Sons Co., Ltd offices and in the presence of an individual appointed by Win Thein & Sons Co., Ltd to maintain the files.

The personnel file of an employee terminating employment should be maintained for a minimum of five years.

3.2.1 Contents of Personnel Files

Employee personnel records should include the following (but may be filed separately):

• Original Employment Application

• Performance Appraisal Reports

• Disciplinary action

• Special commendations

• Education achievement

• Status changes affecting employee's work and salary history

• Employee’s resume

• Other relevant documents as determined by management.

3.3 Personnel Data Changes

It is the responsibility of each employee to promptly notify Win Thein & Sons Co., Ltd of any changes in personnel data. Personal mailing addresses, telephone numbers, number and names of dependents, individuals to be contacted in the event of emergency, educational accomplishments, and other such status reports should be accurate and current at all times. If any personnel data has changed, notify the HUMAN RESOURCES DEPARTMENT

3.4 Probation Period

The probation period is intended to give new employees the opportunity to demonstrate their ability to achieve a satisfactory level of performance and to determine whether the new position meets their expectations. Win Thein & Sons Co., Ltd uses this period to evaluate employee capabilities, work habits, and overall performance.

All new and rehired employees work on a probation basis for the first 30 calendar days after their date of hire. Any significant absence will automatically extend the probation period by the length of the absence. If Win Thein & Sons Co., Ltd determines that the designated probation period does not allow sufficient time to thoroughly evaluate the employee's performance, the probation period may be extended for a specified period.

During the probation period, both parties may assess suitability for employment with the Employer. This also provides management an opportunity to assess skill levels and address areas of potential concern. During the first 30 days of the probationary period, employment may be terminated by either party for any reason whatsoever, with or without cause, and without notice or payment in lieu of notice.

Please take note that your manager’s role is to support you in developing and transferring your knowledge, skills and abilities to be successful in your job. We suggest you to take advantage of this resource.

Upon satisfactory completion of the probation period, employees enter the "regular" employment classification.

During the probation period, new employees are eligible for those benefits that are required by law. After becoming regular employees, they may also be eligible for other Win Thein & Sons Co., Ltd-provided benefits, subject to the terms and conditions of each benefits program. Employees should read the information for each specific benefits program for the details on eligibility requirements.

3.5 Employment Applications

Win Thein & Sons Co., Ltd relies upon the accuracy of information contained in the employment application, as well as the accuracy of other data presented throughout the hiring process and employment. Any misrepresentations, falsifications, or material omissions in any of this information or data may result in the exclusion of the individual from further consideration for employment or, if the person has been hired, termination of employment.

3.6 Performance Evaluation

Supervisors and employees are strongly encouraged to discuss job performance and goals on an informal, day-to-day basis. Additional formal performance evaluations are conducted to provide both supervisors and employees the opportunity to discuss job tasks, identify and correct weaknesses, encourage and recognize strengths, and discuss positive, purposeful approaches for meeting goals.

At the time of the performance appraisal, the employer and employee will review the objectives and the results achieved. Throughout the year, the employee and employer may refer to this document to track progress made toward objectives, highlight areas of concern and indicate challenges identified along the way. The annual salary review of all employees is based on performance and is evaluated beginning the month of December and effective January 1st of the current year.

3.7 Job Descriptions

Win Thein & Sons Co., Ltd makes every effort to create and maintain accurate job descriptions for all positions within the organization. Each description includes a job information section, a job summary section (giving a general overview of the job's purpose), an essential duties and responsibilities section, a supervisory responsibilities section, a qualifications section (including education and/or experience, language skills, mathematical skills, reasoning ability, and any certification required), a physical demands section, and a work environment section.

Win Thein & Sons Co., Ltd maintains job descriptions to aid in orienting new employees to their jobs, identifying the requirements of each position, establishing hiring criteria, setting standards for employee performance evaluations, and establishing a basis for making reasonable accommodations for individuals with disabilities.

The HUMAN RESOURCES DEPARTMENT and the hiring manager prepare job descriptions when new positions are created. Existing job descriptions are also reviewed and revised to ensure that they are up to date. Job descriptions may also be rewritten periodically to reflect any changes in the position's duties and responsibilities. All employees will be expected to help ensure that their job descriptions are accurate and current, reflecting the work being done.

Employees should remember that job descriptions do not necessarily cover every task or duty that might be assigned, and that additional responsibilities may be assigned as necessary. Contact the HUMAN RESOURCES DEPARTMENT if you have any questions or concerns about your job description.

3.8 Salary Administration

The salary administration program at Win Thein & Sons Co., Ltd was created to achieve consistent pay practices, comply with federal and provincial laws, mirror our commitment to Equal Employment Opportunity, and offer competitive salaries within our labor market. Because recruiting and retaining talented employees is critical to our success, Win Thein & Sons Co., Ltd is committed to paying its employees equitable wages that reflect the requirements and responsibilities of their positions and are comparable to the pay received by similarly situated employees in other organizations in the area.

Compensation for every position is determined by several factors, including job analysis and evaluation, the essential duties and responsibilities of the job, and salary survey data on pay practices of other employers. Win Thein & Sons Co., Ltd periodically reviews its salary administration program and restructures it as necessary. Merit-based pay adjustments may be awarded in conjunction with superior employee performance documented by the performance evaluation process. Incentive bonuses may be awarded depending on the overall profitability of Win Thein & Sons Co., Ltd and based on each employee's individual contributions to the organization.

Employees should bring their pay-related questions or concerns to the attention of their immediate supervisors, who are responsible for the fair administration of departmental pay practices. The accounting department is also available to answer specific questions about the salary administration program.

3.9 Professional Development

At the discretion of your manager/supervisor, employees may be able to attend conferences, courses, seminars and meetings, identified through annual work plans and performance reviews, which may be beneficial to the employee’s professional development. When these opportunities are directly related to the employee’s position, or are suggested by the manager/supervisor, then Win Thein & Sons Co., Ltd will cover the cost of registration, course materials and some travel expenses.

If Win Thein & Sons Co., Ltd has agreed to pay for a course, the fees will be paid on evidence of successful completion. If THE ORGANIZATION sponsors a course (or courses) and the employee departs THE ORGANIZATION within a year of completion, the course fees will become repayable in full.

3.9.1 Promotions

Promotions within the Company should be based on such factors as quality of work, prior job performance, experience, educational background, attendance, safety record, and the ability to work well with others.

Our Company policy is to promote from within when we have personnel fully qualified to perform the duties of the position.

3.9.2 Transfer of Employees

Transfer of employees for the Company’s convenience may be made to meet Company requirements. Requests for transfer by employees should be made in writing and given to HR management for consideration before interviewing with a Hiring Manager for another position.

Employees should discuss their desire to transfer with their current supervisor; however, this is not a requirement. The Hiring Manager should contact the employee’s current supervisor only after receiving the employee’s written consent. A Transfer may be made if management determines it is in the best interest of the Company and the employee.

The Company provides a relocation program for its employees if they are requested to transfer within the Company. The program is designed to offset expenses associated with the move. However, it’s not intended to compensate for losses due to fluctuating market conditions, home improvements and so on.

Employees that wish to transfer or apply to an open position should be given first consideration. However, the timing of any transfer should be planned so that ongoing commitments are not jeopardized. Employees interested in transfer opportunities should contact the HR Manager.

3.9.3 Separation of Employment

Employees may be separated from employment voluntarily or involuntarily by retirement, voluntary resignation, lack of work, or termination. However, if any misconduct warranting discipline is severe enough, the management may discharge an employee immediately.

In the case of termination all Company property in the employee’s possession must be returned to the Company upon separation from employment and before the final paycheck is released.

3.9.4 Work Force Reductions

In the event that a reduction in the Company’s work force becomes necessary, the number of employees over and above those needed to perform the available work should be laid off. In determining those employees to be retained, consideration should be given to the quality of each employee’s past performance, the need for the position held by the employee and, with all other factors being equal, the length of service of each employee.

If feasible, but not as a vested right, full time employees subject to lay off should be given at least a one month notice prior to the anticipated lay off. Upon such lay off, all accrued but unused vacation leave should be paid in full and any insurance benefits required to be offered should be brought to the employee’s attention.

3.9.5 New Employees

The Company has established a Human Resources Department, which is responsible for personnel administration. Questions regarding your employment and this employee handbook should be addressed to the Manager of Human Resources.

3.9.6 Application for Employment

All candidates for employment must fully complete, date and sign the standard The Company employment application form. A resume may be accepted in lieu of an employment application. The form should be completed in detail and signed by the applicant to verify the accuracy and completeness of previous employment and personal information as well as health information.

The Company may investigate any portion of the requested information and may deny or later terminate the employment of anyone giving false or incomplete information.

It is essential that all applicants sign their employment application. The signature provides specific protection for the Company on several important terms and conditions.

The completed application or resume will be made part of the personnel file of those applicants accepted for employment.

Applications from applicants not selected for available openings shall be maintained in an active file in the Personnel Department for one year and reviewed as suitable openings occur.

3.9.7 Confirmation of Previous Employment

The Company, at its discretion, will request information from the prospective employee’s previous employers relative to their work record in connection with their application for employment. Additionally, the Company may conduct a pre-employment credit check on all applicants who are offered and accept employment.

3.9.8 Compliance Information

In order for the Company to comply with federal government regulations regarding its practice to employ people without discrimination, it is necessary for the Company to compile and maintain detailed information on each formal candidate for employment and those who are hired. This information will include the candidate's or employee’s sex, race, handicap status.

3.9.9 Physical Examination Prior to Employment

For certain positions and under certain circumstances a physical examination may be required prior to employment. A Company appointed physician at the Company’s expense will conduct this physical examination. When a physical examination prior to employment is requested, employment and assignment will be conditional pending the receipt of a satisfactory physician’s report.

3.10 Screening and Testing

There may be times when it is necessary to screen and test an employee to determine what risks the Company may assume with employment of the individual. Screening and testing for security reasons and for drug or alcohol abuse may be required. Procedures such as psychological and medical laboratory tests will always be performed under the direction of a certified professional and according to the laws, which apply.

Personnel with a disability, which would affect their ability to take a particular test, shall advise Human Resources so that a suitable accommodation can be arranged. Medical documentation may be requested from the employee concerning a special request.

3.10.1 Motor Vehicle Record

Prospective employees expected to drive Company vehicle must provide the Company with current and acceptable motor vehicle driving information. Employment and assignment will be conditional pending the receipt of a satisfactory report from an employee or other third party. Any changes to your driving record must be reported to Human Resources in a timely manner.

Employees authorized to drive a Company vehicle are completely responsible for fines resulting from traffic violations. Only The Company employees are authorized to ride in or operate a Company vehicle.

3.10.2 Process Improvement

Management-employee relations are strengthened when employees are consulted in decisions affecting them. Many organizations find it useful to establish a structured forum to encourage open communication between managers and employees on issues of common concern. This may take the form of a labor-management committee, quality of work life groups, facilitated team-building, and/or retreats or staff meetings set aside for this purpose.

3.10.3 Employee-Management Forums

Employee-management forums concentrate on analyzing and developing recommendations to resolve work-related problems and enhance organizational effectiveness. They should avoid personal attacks and discussions of individual personnel actions and formal grievances.

Employees are encouraged to participate in such open discussion with management. Managers should patiently demonstrate by their actions:

• They value employee involvement in work-related issues.

• There will be no negative repercussions (immediately or eventually) for introducing a concern or suggestion.

• Their ideas will be seriously considered and used to improve the workplace where possible, rather than gathering dust on a shelf.

Areas of productive discussion can include:

• Workplace safety issues.

• How to improve the quality of services, work products, or eliminate process redundancy.

• Methods used to determine assignments, performance appraisals, work performance standards, shift and overtime assignments, priority of leave requests, promotions, and other personnel management practices.

• Training needs.

• Morale problems.

• Equipment and other resource needs.

3.10.4 Employee Suggestion Program

The Employee Suggestion Program provides employees with an opportunity to be rewarded for innovative and creative ideas that lead to immediate, near-term Company improvement. Any employee may submit a suggestion to improve the Company. Rewards range from cash to extra days of vacation.

An individual or group of employees can submit eligible suggestions that identify practical improvements to save some part of the Company time or money, improve quality, increase customer satisfaction, or identify new sources of revenue.

Suggestions that are already within the employee’s authority or responsibility to implement, consist of issues already under consideration, involve personal grievances or complaints, result in savings of less than $100 or concern policies or procedures that are not being followed or that are not being applied properly are not the focus of the program and will not qualify for a reward.

Suggestions should be well documented and include the employee’s name and immediate supervisor, statement of the problem, proposed solution, anticipated savings in terms of time, money, or quality, an estimate of the cost to the Company to realize the savings, and provide as much other detail or specifics for evaluation. Incomplete suggestions will not qualify for a reward.

Rewards range from monetary payments or 1 day of leave at employee option. Forward all suggestions to the HR Manager.

4. Employee Benefit Programs

4.0 Benefit Eligibility

The term “eligible employee(s)” used in the following sections of this handbook refers to full time employee(s) unless otherwise designated. Employees should be advised of the status of their position when they are hired.

• Full-time employees are entitled to the benefits stated in this handbook provided they qualify for each individual benefit.

• Part-time employees are entitled to those employee benefits specifically designated.

• Temporary employees are not eligible for benefits.

In order to have a record of an employee’s benefits, a continuous service date should be maintained for each full time employee. The continuous service date should be the employee’s first day of employment and should continue uninterrupted as long as the employee remains a full-time employee.

4.1 Employee Benefits

Eligible employees at Win Thein & Sons Co., Ltd are provided a wide range of benefits. Several programs cover all employees in the manner prescribed by law.

Benefits eligibility is dependent upon a variety of factors, including employee classification. Your supervisor can identify the programs for which you are eligible. Details of many of these programs can be found elsewhere in the employee handbook.

Eligible employees are provided with the following benefits if applicable:

• Medical Insurance

• Life Insurance

• Long-Term Disability

4.1.1 Attendance & Leave

In the daily production process at the Company, the work passes from operation to operation, each step adding value to the finished product. This means that each job depends on the successful and timely completion of all other jobs that precede it. Because of this fact, absenteeism is disruptive to all operations.

If one person is absent, this may cause others to work overtime in order to accomplish work that is not completed by the absent person. Worse, a one-person absence could cause other jobs to “catch up” or run out of work. In this case, absenteeism does have an overall negative impact on the Company’s production, resulting in a loss of earnings or even the loss of customers.

Therefore, your attendance is of vital importance, not only in relation to your coworkers but also with respect to the overall Company. Providing high quality goods and services for total customer satisfaction depends on your commitment and attendance.

4.2 Vacation Benefits

The Company recognizes that employees need a scheduled time away from normal work duties for their personal well-being. The Company grants annual vacation and holidays with pay to employees who meet the eligibility requirements.

The amount of paid vacation time employees receives each year increases with the length of their employment as shown in the following schedule:

4.2.1 Vacation Eligibility

The Company grants annual vacation with pay to regular full-time employees who meet the service requirements as follows:

• After one year of full time employment each employee is entitled to ten days of paid vacation;

• From two to four years of full time employment each employee is entitled to ten days of paid vacation;

• From five to ten years of full time employment each employee is entitled to fifteen days of paid vacation.

• From ten to twenty years of full time employment each employee is entitled to twenty days of paid vacation.

• After twenty or more years of full time employment each employee is entitled to twenty-five days of paid vacation.

4.2.2 Vacation Schedules

The Company will attempt to have employees stagger vacations in an effort to avoid affecting production. Therefore granting of vacation requests will be solely at the discretion of management, the plant manager, or area supervisor who will make every effort to accommodate each employee.

Vacation may be taken at any time during the year after eligibility with the following provisions:

• Vacation requests must be made at least two weeks prior to the desired vacation time.

• Employees are expected to take their paid vacation time as a means of rest and diversion for themselves and their families.

• A maximum of three days of unused vacation time may be carried over into the next vacation year with prior approval from management and at the convenience of the Company.

• An employee must work the regularly scheduled workdays before and after the paid vacation or holiday period in order to be eligible to receive vacation or holiday pay.

• Job requirements will always take precedence over vacation schedules.

• Seniority will be considered in the event a conflict of vacation schedules arises.

A paid Company holiday that falls during the vacation period will be considered as a paid holiday and not vacation time. This day of vacation may be taken at another time as approved.

4.2.3 Vacation Pay

Pay for vacation time will be at the employee’s regular rate of pay. Paid vacation time will not be considered as time worked for the purpose of computing overtime for hourly employees.

Pay in lieu of unused vacation at any time will be provided only at the convenience of the Company when approved in advance by management, and, upon separation from employment under certain conditions.

4.3 Military Service Leave

Employees serving in the uniformed services, including the Army, Navy, Marine Corps, Air Force, Coast Guard and Public Health Service commissioned corps, as well as the reserve components of each of these services, may take unpaid military leave, as needed, to enable them to fulfill their obligations. However, those employees must provide advance written or verbal notice to their manager/supervisor. Employees should provide notice as far in advance as is reasonable under the circumstances. In addition, employees may, but are not required to, use accrued vacation or personal leave while performing military duty.

4.4 Religious Observance

Myanmar equal opportunity laws generally require employers to accommodate the religious beliefs of employees, but do not require them to provide paid leave. The Company respects your religious beliefs, however, and therefore, will provide one (1) day of paid leave to employees who, for religious reasons, must be away from the office on days of normal operation. Employees who require additional time off may use vacation and/or personal days. This leave must be requested through the department manager two weeks prior to the event.

4.5 Holidays

Win Thein & Sons Co., Ltd will grant holiday time off to all employees on the holidays listed below:

• Monday January 01 - International New Year's Day

• Thursday January 04 - Independence Day

• Monday February 12- Union Day

• Thursday March 01- Full Moon Day of Tabaung

• Friday March 02 - Peasants' Day

• Tuesday March 27- Armed Forces Day Tatmadaw Day

• Friday April 13 -Thingyan Water festival

• Saturday April 14- Thingyan Holiday

• Sunday April 15 - Thingyan Holiday

• Monday April 16- Thingyan Holiday

• Tuesday April 17 - Burmese New Year's Day

• Wednesday April 18- Burmese New Year Holiday Government holiday

• Thursday April 19 - Burmese New Year Holiday Government holiday

• Friday April 20- Burmese New Year Holiday Government holiday

• Sunday April 29- Full Moon Day of Kasong Vesak Day

• Tuesday May 01- Labour Day May Day

• Thursday July 19- Martyr's Day

• Friday July 27 -Full Moon Day of Waso Dhammasetkya Day. Beginning of Buddhist Lent

• Wednesday August -22 Eid ul-Adha Day

• Tuesday October 23 Pre-Full Moon Day of Thadingyut End of Buddhist Lent

• Wednesday October -24 Full Moon Day of Thadingyut End of Buddhist Lent

• Thursday October 25 Post-Full Moon Day of Thadingyut End of Buddhist Lent

• Tuesday November 06 -Deepavali

• Wednesday November 21 -Pre-Full Moon Day of Tazaungmone

• Thursday November 22 -Full Moon of Tazaungmone

• Sunday December 02 -National Day 10th day following the full moon of the month of Tazaungmone

• Tuesday December 25 -Christmas Day

• Monday December 31 - New Year's Eve

Win Thein & Sons Co., Ltd will grant paid holiday time off to all eligible employees immediately upon assignment to an eligible employment classification. Holiday pay will be calculated based on the employee's straight-time pay rate (as of the date of the holiday) times the number of hours the employee would otherwise have worked on that day. Eligible employee classification(s): Employees who worked a minimum of 60 days.

To be eligible for holiday pay, employees must work the last scheduled day immediately preceding and the first scheduled day immediately following the holiday.

A statutory holiday that falls on a Saturday will be observed on the preceding Friday or in the case it falls on a Sunday will be observed on the following Monday.

If a statutory holiday falls during an eligible employee's paid absence (such as vacation or sick leave), holiday pay will be provided instead of the paid time off benefit that would otherwise have applied.

If eligible non-exempt employees work on a recognized holiday, they will receive holiday pay plus wages at one and one-half times their straight-time rate for the hours worked on the holiday.

Paid time off for holidays will not be counted as hours worked for the purposes of determining overtime.

4.6 Workers Insurance

Win Thein & Sons Co., Ltd provides BASIC EMPLOYMENT INSURANCE program at no cost to eligible and certain employees. This program covers any injury or illness sustained in the course of employment that requires medical, surgical, or hospital treatment. Subject to applicable legal requirements, workers' compensation insurance provides benefits after a short waiting period or, if the employee is hospitalized, immediately.

Employees who sustain work-related injuries or illnesses should inform their supervisor immediately. No matter how minor an on-the-job injury may appear, it is important that it be reported immediately. This will enable an eligible employee to qualify for coverage as quickly as possible. Neither Win Thein & Sons Co., Ltd nor the insurance carrier will be liable for the payment of workers' compensation benefits for injuries that occur during an employee's voluntary participation in any off-duty recreational, social, or athletic activity sponsored by Win Thein & Sons Co., Ltd.

4.7 Medical Leave Benefits

Win Thein & Sons Co., Ltd provides paid medical leave benefits to all eligible employees for periods of temporary absence due to illnesses or injuries. Eligible employee classification(s):

• Regular full-time employees

Employers must give workers leave without deduction from wages for medical treatment when workers cannot work due to illness. Workers who present a medical certificate may take paid medical leave up to 30 days per year after working for at least six months. Workers who have worked less than six months may take unpaid medical leave.

Employees who are unable to report to work due to illness or injury should notify their direct supervisor before the scheduled start of their workday if possible. The direct supervisor must also be contacted on each additional day of absence. If an employee is absent for three or more consecutive days due to illness or injury, a physician's statement may need to be provided verifying the disability and its beginning and expected ending dates. Such verification may be requested for other medical/sick leave absences as well and may be required as a condition to receiving medical leave benefits.

Medical leave benefits will be calculated based on the employee's base pay rate at the time of absence and will not include any special forms of compensation, such as incentives, commissions, bonuses, or shift differentials. As an additional condition of eligibility for medical leave benefits, an employee on an extended absence must apply for any other available compensation and benefits, such as BASIC EMPLOYMENT INSURANCE. Medical leave benefits will be used to supplement any payments that an employee is eligible to receive from provincial disability insurance, workers' compensation or Win Thein & Sons Co., Ltd-provided disability insurance programs. The combination of any such disability payments and medical leave benefits cannot exceed the employee's normal weekly earnings.

Medical leave benefits are intended solely to provide income protection in the event of illness or injury and may not be used for any other absence. Unused medical leave benefits will be paid to the active employees at the end of the calendar year. Employees who quit or that are terminated are not entitled to be paid any unused medical leave days upon termination of employment.

Medical, Dental, and Optical Appointments

Routine medical, dental, and optical appointments should be scheduled outside working hours. When this is not practical, occasional absences for such reasons are to be charged to sick leave. Employees may use vacation time instead of sick leave with the special approval of the management.

Exhaustion of Accumulated Medical Leave

Employees who are still incapacitated after exhausting all accumulated medical leave and vacation time and are not enrolled in the long-term disability plan should, at their request, be placed on medical leave without pay.

The employee’s position should be held open for the employee’s return to work unless a long-term disability claim is approved. Employees enrolled in the long-term disability program should become eligible for disability benefits after 90 calendar days. If an employee has been employed for less than one year and thus not eligible for long-term disability coverage, and the medically-related disability appears to be long term, the employee may be granted a medical leave of absence without pay or the employment may be terminated.

4.8 Bereavement Leave

Employees who require taking time off due to the death of an immediate family member should notify their supervisor immediately.

Paid bereavement leave will be provided to employees having worked 60 calendar days for Win Thein & Sons Co., Ltd:

a) Five (5) working days in the case of the death of an employee's spouse, child or the employee's spouse's child.

b) Three (3) working days in the case of the death of an employee's father, mother, sister or brother.

c) One (1) working day in the case of the death of an employee’s grandfather, grandmother, uncle, aunt, nephew, niece, son-in-law, daughter-in-law, father-in-law, mother-in-law, brother-in-law, sister-in-law, grandson, grand-daughter (except the uncle, the aunt, the brother-in-law, the sister-in-law, the grandfather, the grandmother, the nephew and the niece of the spouse).

Bereavement pay is calculated based on the base pay rate at the time of absence and will not include any special forms of compensation, such as incentives, commissions, bonuses, or shift differentials. The employees on leave without balance, of maternity, disease, in preventive withdrawal, parental leave, will not be able to prevail themselves of this benefit.

Bereavement leave will normally be granted unless there are unusual business needs or staffing requirements. Employees may, with their supervisors' approval, use any available paid leave for additional time off as necessary.

4.9 Relocation Benefits

When Win Thein & Sons Co., Ltd asks employees to relocate to a new area, certain relocation benefits may be provided to facilitate the transition. Relocation may be available to any eligible transferred employee who must relocate in order to reside within 45 miles of the new place of work. For specific information regarding the terms and extent of relocation benefits, discuss with your immediate supervisor.

Employees must request relocation assistance for specific items in advance of the date the expenses are incurred. Win Thein & Sons Co., Ltd will reimburse expenses only if the employee has received advance approval, incurs reasonable expenses, and submits satisfactory proof of the expense within 30 calendar days of the date the expense was incurred.

Win Thein & Sons Co., Ltd extends these relocation benefits in an effort to contribute to the success of every employee's relocation. However, if an employee separates from Win Thein & Sons Co., Ltd service within one year of the relocation, the amount of the relocation reimbursement will be considered only a loan. Accordingly, the employee will be asked to reimburse all relocation expense.

4.10 Educational Assistance

Win Thein & Sons Co., Ltd recognizes that the skills and knowledge of its employees are critical to the success of the organization. The educational assistance program encourages personal development through formal education so that employees can maintain and improve job-related skills or enhance their ability to compete for reasonably attainable jobs within Win Thein & Sons Co., Ltd.

Win Thein & Sons Co., Ltd will provide educational assistance to all eligible employees immediately upon assignment to an eligible employment classification. To maintain eligibility employees must remain on the active payroll and be performing their job satisfactorily through completion of each course. Only Regular full-time employees are eligible for educational assistance.

Employees should contact their immediate supervisor or the HUMAN RESOURCES DEPARTMENT OR OTHER for more information or questions about educational assistance.

While educational assistance is expected to enhance employees’ performance and professional abilities, Win Thein & Sons Co., Ltd cannot guarantee that participation in formal education will entitle the employee to automatic advancement, a different job assignment, or pay increases.

4.11 Health Insurance

Win Thein & Sons Co., Ltd health insurance plan provides employees and their dependents access to medical insurance benefits. Employees in the following employment classifications are eligible to participate in the health insurance plan:

• Regular full-time employees

Eligible employees may participate in the health insurance plan subject to all terms and conditions of the agreement between Win Thein & Sons Co., Ltd and the insurance carrier.

Details of the health insurance plan are described in the employment contract if applicable. Information on cost of coverage will be provided in advance of enrollment to eligible employees. Contact the HUMAN RESOURCES DEPARTMENT OR OTHER for more information about health insurance benefits.

4.12 Life Insurance

Life insurance offers you and your family important financial protection. Win Thein & Sons Co., Ltd provides a basic life insurance plan for eligible employees.

Accidental Death and Dismemberment (AD&D) insurance provides protection in cases of serious injury or death resulting from an accident. AD&D insurance coverage is provided as part of the basic life insurance plan. Employees in the following employment classifications are eligible to participate in the life insurance plan:

Regular full-time employees

Eligible employees may participate in the life insurance plan subject to all terms and conditions of the agreement between Win Thein & Sons Co., Ltd and the insurance carrier. Details of the basic life insurance plan including benefit amounts are described in the employment contract provided to eligible employees. Contact the HUMAN RESOURCES DEPARTMENT OR OTHER for more information about life insurance benefits.

4.13 Long Term Disability

Win Thein & Sons Co., Ltd provides a long-term disability (LTD) benefits plan to help eligible employees cope with an illness or injury that results in a long-term absence from employment. LTD is designed to ensure a continuing income for employees who are disabled and unable to work.

Employees in the following employment classifications are eligible to participate in the LTD plan: Regular full-time employees

Eligible employees may participate in the LTD plan subject to all terms and conditions of the agreement between Win Thein & Sons Co., Ltd and the insurance carrier.

Details of the LTD benefits plan including benefit amounts, and limitations and restrictions are described in the employment contract provided to eligible employees. Contact the HUMAN RESOURCES DEPARTMENT OR OTHER for more information about LTD benefits.

4.14 Marriage, Maternity and Parental Leave Marriage

One (1) paid working day off is allowed for the marriage of the employee or one of his children.

An employee may take one (1) day leave of absence for the marriage of a parent, brother, sister or child of joint sound.

Maternity Leave Admissibility

According to labour law pregnant mothers are provided six weeks of prenatal leave and 8 weeks of postnatal leave, for a total of 14 weeks of maternity leave. Fathers are entitled to 15 days of paternity leave.

All employees, men and women, qualify for the parental leave program. This program grants the employee to use accrued vacation time or leave without pay for a reasonable, prearranged time period in case of adoption or other non-medical-related family affairs. Since this form of absence cannot be justified on medical-related grounds, no accrued medical-related sick leave credits can be used.

Notice:

a) The employee must provide in writing to the company, at least three weeks in advance the date of the beginning of her maternity leave and the date envisaged of her return to work. A medical certificate attesting of the date envisaged of the birth must accompany the notice.

b) The notice can be less than 3 weeks if the medical certificate attests need for the employee to cease working within a less time. If physical dangers are possible, the employee will be assigned to other tasks while preserving the rights and preferences connected to her regular position.

Complications:

If the employee or the child suffers from complications preventing the return to work at the end of the maternity leave, the employee will have to forward a medical certificate to the company. The employee will be entitled to a prolongation of her maternity leave, which can reach a 52-week maximum including the parental leave.

Return to work:

a) The employee must provide in writing to management the expected date of her return to work and this, three (3) weeks before returning from his maternity leave or parental.

b) The employee who does not present himself to work five (5) days after the expiration of his maternity leave or parental leave may be known to have resigned.

c) The direction can require of the employee who returns to work two (2) weeks after her childbirth, the production of a medical certificate attesting of its sufficient re-establishment to resume work.

d) At the end of its maternity leave, or parental leave not exceeding 12 weeks, the employee will be reinstalled in her regular function and it will be entitled to all the advantages of which it would have profited if she had remained with work.

e) If the regular job of the employee does not exist anymore on her return, the direction will recognize all the rights and preferences that she would have profited at the time from disappearance of her job if she had then been with work.

Miscarriage:

a) In the event of miscarriage, the employee as soon as possible must deliver to the direction a notice accompanied by a medical certificate attesting of the miscarriage or the urgency.

b) When a danger of miscarriage requires a stop of work, the employee is entitled to a special maternity leave of the duration prescribed by the medical certificate, which attests existing danger.

c) When occurs a miscarriage before the beginning of the twentieth (20th) week preceding the date envisaged of the childbirth, the employee is entitled to a medical leave.

d) If an employee is confined of a child dead-born after the twentieth (20th) week preceding the date envisaged of the birth, she is entitled to the maternity leave of eighteen (18) weeks.

Special maternity leave:

When there is a danger of miscarriage, or a danger to the health of the mother or of the child to come caused by pregnancy and requiring a stop of work, the employee is entitled to a special maternity leave of the duration prescribed by the medical certificate which attests existing danger and which indicates the date envisaged of the childbirth.

Preventive withdrawal:

When there is a danger of miscarriage, or a danger to the health of the mother or the child to come caused by the working conditions, the employee must ask to be assigned to tasks not involving such dangers. If the direction cannot offer other tasks, the employee can then make the request for a preventive withdrawal. The maternity leave will then begin at the date envisaged from the childbirth.

Birth of a child or adoption

Two (2) paid working days off during the birth of the employee’s child or of the adoption of a child (leave of paternity) other than those of joint sound. Moreover, the employee can prevail himself of a leave without balance of three (3) days. This leave can be split but must be taken in the 15 following days of the arrival of the child at the house.

4.15 Civic Leave or Jury Duty

When an employee is called for jury duty or as a witness, time off with unpaid will be granted. The Company shall pay the difference between the court payment and the employee’s regular pay rate. Should the employee be vital to the Company’s operation, the court may be asked to excuse the employee from jury duty.

Employees must notify management upon receipt of their summons. A document from the court showing the time and amount paid must be given to management. If the court dismisses the jury or witness early, the employee is expected to return to work as soon as possible (and complete an eight hour shift comprised of civic time and time on the job).

4.16 Voting

The Company does not provide time off for voting with or without pay. Employees should make arrangements to vote before or following normal work hours.

4.17 Leave of Absence

An employee may ask for a personal leave of absence without pay from the Company that is not covered under the Family and Medical Leave Act. The Company cannot guarantee to hold any position for more than a three (3) month maximum. Any request for a leave of absence must be made in writing and must be approved in advance by management.

Due to lack of work, the Company may require an employee to take an unpaid leave of absence. The length of a Company-initiated leave of absence may vary.

During any approved leave of absence the following provisions apply:

  • The employee is responsible for the payment of all insurance premiums for their individual coverage and dependent health insurance coverage (if applicable). This money should be paid to the Company by the first day of each month that the employee is on an approved leave of absence.

  • If the personal leave is approved the employee should retain their original employment date showing no interruption in service.

  • Credit for paid vacation leave cannot be accrued during an approved leave of absence.

  • If an employee accepts employment with another Company, all their Company benefits should be terminated.

Any personally requested leave of absence is without pay

4.2 Miscellaneous Benefits

The Company provides additional benefits from time to time. Contact the Human Resources Manager for details on specific programs

4.2.1 Break Room

The Company provides a break area for the convenience of the employees that contains free soda, coffee, bottled water, and popcorn for all employees. In addition, the Company also makes available a refrigerator, microwave, and sink.
Employees are encouraged to use the break areas for their scheduled break and lunch period. Consumption of food is only permitted in the break area and other designated areas.

4.2.2 Employee Discounts

Employees can enjoy special discounts and purchasing opportunities at a variety of local vendors. The Company maintains a list of merchants who make their goods and services available to employees at potentially reduced rates. Contact the Human Resources Manager for details.

4.2.3 Company Sponsored Events

The Company may receive invitations or tickets to sporting events, museums, theaters, amusement parks, parties, or other special events throughout the year. Tickets will be provided by your department manager. Employees are expected to act responsibly when attending such functions, as they represent the company.

5. Timekeeping / Payroll

5.1 Timekeeping

Accurately recording time worked is the responsibility of every nonexempt employee. Government regulations require Win Thein & Sons Co., Ltd to keep an accurate record of time worked in order to calculate employee pay and benefits. Time worked is all the time actually spent on the job performing assigned duties.

Altering, falsifying, tampering with time records, or recording time on another employee's time record may result in disciplinary action, up to and including termination of employment.

If corrections or modifications are made to the time record, both the employee and the supervisor must verify the accuracy of the changes by initialing the time record.

Employees are required to punch in when they report to work and punch out when they leave. Employees must punch in no earlier than five minutes before their starting time and punch out no later than fifteen minutes after their scheduled shift has ended unless approved by management.

Employees who are not recording their working time on a time clock are required to keep track of their working hours on a departmental time card or time sheet which should be provided by the Human Resources Department.

5.1.1 Payroll Information

Immediately upon accepting employment, the new employee should be given tax forms along with standard employment forms to complete. The completed forms, the employment application form, and information regarding starting pay, starting date and other pay or benefit information should be forwarded to the HR Manager.

5.2 Paydays

All employees are paid every end of the month. Each paycheck will include earnings for all work performed through the end of the previous payroll period.

In the event that a regularly scheduled payday falls on a day off such as a weekend or holiday, employees will receive pay on the last day of work before the regularly scheduled payday.

Employees may have pay directly deposited into their bank accounts if they provide advance written authorization to Win Thein & Sons Co., Ltd. Employees will receive an itemized statement of wages when Win Thein & Sons Co., Ltd makes direct deposits.

5.2.1 Salary Compensation for Partial Pay Period

Salary payments to employees who are employed for less than a full pay period because of leave without pay, resignation or employment’s at dates other than the beginning or the end of the pay period are computed on the basis of actual working days in the month. For this purpose working days are considered to be forty hours Monday through Friday unless otherwise specified.

5.2.2 Pay Rate Schedule – Hourly Paid Employees

The Company has established pay rate schedules for hourly-paid employees based upon work classifications. The length of time in a classification is a general guideline only. Being employed by the Company more than 1 or 2 years does not necessarily mean automatic promotion to the next highest level, for example.

Pay is determined by three primary factors:

• Your assigned work classification.

• Step increases for years of service.

• Individual performance.

5.2.3 Payroll Deduction

The Company should deduct but and not necessarily deduct Income Taxes, Social Security Taxes, family health coverage, for uniforms, for a Savings and Pension program, for loss or destruction of Company property from an employee’s gross pay.

• All deductions (other than statutory deductions) must be authorized in writing by the employee.

• Deductions should be itemized on the employee's paycheck stub. Questions regarding payroll deductions should be directed to the Human Resource Manager.

5.2.4 Overtime

Hourly-paid employees (non-exempt) are expected to confine their work to the normal workday and workweek unless their manager authorizes overtime in advance. If determined necessary, in case of emergency or when its in the best interests of the Company, overtime work should be authorized by management for time spent beyond an employee's standard workweek.

Hourly-paid employees should be paid one and one-half (1.5) times their normal hourly rate of pay for approved overtime hours worked in excess of forty (40) hours per week.

The hours worked by salaried/exempt employees are often irregular, begin and end beyond the normal workday.

5.2.4 Payroll Errors

Every precaution is taken to ensure that employees are paid correctly. If an employee believes there is an error in their pay, they should notify the HR Manager. The Company should make every attempt to adjust the error immediately or no later than the employee's next pay period.

5.2.5 Authorized Check Pickup

Your manager distributes paychecks. If an employee is absent on payday and instructs someone to pick up his or her paycheck, a note signed by the employee authorizing the person must be provided before the check can be released. The person picking up the paycheck must show proper identification and sign for the check. This policy protects the employee and the Company.

For the convenience of the employee, and the Company, paychecks can also be directly deposited in the employee’s bank account if the employee chooses to do so. A direct deposit request form may be obtained in the HR Department.

5.2.6 Pay at Time of Separation

Employees separated from employment shall be paid for time worked (less deductions) on the next regular pay day in accordance with the applicable laws. Any accrued vacation time shall also be paid at this time if applicable.

The Company must determine if the terminating employee has any outstanding debt owed the Company and whether the individual has in their possession any Company property (e.g. credit cards, uniforms, tools).

After a full accounting of the employee’s and the Company’s accounts (as determined by the Company) is completed, a final paycheck shall be issued to the employee in accordance with law.

The Company shall issue a check, which is designated as the final payment for all services rendered. The final check should not reflect any time not actually worked except for an employee separated from employment with the Company for any reason before they have taken part or all of their earned vacation pay at the time of separation from employment.

Upon resignation or termination, the employee should consult the Human Resource Department for possible conversion of their group insurance and to address any financial issues.

5.3 Employment Termination

Termination of employment is an inevitable part of personnel activity within any organization, and many of the reasons for termination are routine. Below are examples of some of the most common circumstances under which employment is terminated:

Termination for Cause: An Employment Contract may be terminated by the Employer at any time for cause, without notice or payment in lieu of notice, or severance pay whatsoever, except payment of outstanding wages, overtime and vacation pay to the date of termination. Cause includes, but is not limited to, any act of dishonesty, conflict of interest, breach of confidentiality, harassment, insubordination, or careless, negligent or documented poor work performance.

• Resignation - voluntary employment termination initiated by an employee.

• Discharge - involuntary employment termination initiated by the organization.

• Layoff - involuntary employment termination initiated by the organization for non-disciplinary reasons.

• Retirement - voluntary employment termination initiated by the employee meeting age, length of service, and any other criteria for retirement from the organization.

Termination Without Cause: An Employment Contract may be terminated by the Employer at any time and for any reason on a without cause basis, upon the provision of notice or payment of notice instead, and severance pay if applicable, as is minimally required by the law, as amended from time to time.

In addition to notice, and pursuant to the law, the employee shall be entitled to an additional one (1) week notice or payment in lieu of notice for every year of completed service (severance pay) with the Employer.

6. Work Conditions and Hours

6.1 Work Schedules

The normal work schedule for all employees is 8 hours a day, Monday to Friday except for Saturday working hour will be limited to 5 hours. Supervisors will advise employees of the times their schedules will normally begin and end. Staffing needs and operational demands may necessitate variations in starting and ending times, as well as variations in the total hours that may be scheduled each day and week.

Each employee is expected to complete a normal workday, workweek, and work whatever reasonable additional hours required meeting Company needs.

Flexible scheduling, or flextime, is available in some cases to allow employees to vary their starting and ending times each day within established limits. Flextime may be possible if a mutually workable schedule can be negotiated with the supervisor involved. However, such issues as staffing needs, the employee's performance, and the nature of the job will be considered before approval of flextime. Employees should consult their supervisor to request participation in the flextime program.

6.1.0 Working Hours

The Company’s regular workweek begins at 8:00 a.m. on Monday and ends at 5:00 p.m. on Friday. Regular working hours are: Office: 9:00 a.m. to 5:00 p.m. daily, with 60 minutes for lunch break. Management should inform employees of scheduled break and lunch periods. Normally lunch or meal periods should be scheduled for one hour between the fourth and the sixth hour of each workday. A fifteen minute break or rest period should be scheduled for the first half of the work shift and the second half of the work shift.
Employees are expected back at their workstation ready to start work at the end of each scheduled break and lunch break period. If overtime is required, employees should be expected to work any additional time necessary.

6.1.1 Salary Employees

The general manager should establish salaried employees’ work schedules.

6.1.2 Hourly Employees

Regular work schedules should be established according to production requirements, and employees should be notified in advance of changes in the starting time of their shifts.

The Company has adopted a work schedule of approximately eight hours per day, Monday through Friday. However, because of varying production requirements, there may be an occasional reduction in hours or you may be required to work overtime hours.

Where overtime may be required, the Company should make every reasonable effort to notify employees affected as early as practicable. In order to avoid or minimize layoffs during slack seasons, the Company may try to preserve everyone’s job by reducing total hours and balancing the work among employees.

6.2 Use of Phone and Mail Systems

Personal use of the telephone for long-distance and toll calls is not permitted. Employees should practice discretion when making local personal calls and may be required to reimburse Win Thein & Sons Co., Ltd for any charges resulting from their personal use of the telephone.

The use of Win Thein & Sons Co., Ltd paid postage for personal correspondence is not permitted.

To ensure effective telephone communications, employees should always use an approved greeting and speak in a courteous and professional manner. Please confirm information received from the caller and hang up only after the caller has done so.

6.3 Smoking

In keeping with Win Thein & Sons Co., Ltd intent to provide a safe and healthful work environment, smoking is prohibited throughout the workplace.

This policy applies equally to all employees, customers, and visitors.

6.4 Meal Periods

All employees are provided with one meal period of 60 minutes in length each workday. Supervisors will schedule meal periods to accommodate operating requirements. Employees will be relieved of all active responsibilities and restrictions during meal periods and will not be compensated for that time.

6.5 Overtime

When operating requirements or other needs cannot be met during regular working hours, employees will be given the opportunity to volunteer for overtime work assignments. All overtime work must receive the supervisor's prior authorization. Overtime assignments will be distributed as equitably as practical to all employees qualified to perform the required work.

Overtime compensation is paid to all non-exempt employees in accordance with Myanmar labour law wage and hour restrictions. Overtime pay is based on actual hours worked. Time off on medical leave, vacation leave, or any leave of absence will not be considered hours worked for purposes of performing overtime calculations. Failure to work scheduled overtime or overtime worked without prior authorization from the supervisor may result in disciplinary action, up to and including possible termination of employment.

Business travel for conferences, meetings, etc., which cause an employee to depart or arrive home on a non-work day does not constitute overtime.

6.6 Use of Equipment

Equipment essential in accomplishing job duties is often expensive and may be difficult to replace. When using property, employees are expected to exercise care, perform required maintenance, and follow all operating instructions, safety standards, and guidelines.

Please notify the supervisor if any equipment, machines, or tools appear to be damaged, defective, or in need of repair. Prompt reporting of damages, defects, and the need for repairs could prevent deterioration of equipment and possible injury to employees or others. The supervisor can answer any questions about an employee's responsibility for maintenance and care of equipment used on the job.

The improper, careless, negligent, destructive, or unsafe use or operation of equipment can result in disciplinary action, up to and including termination of employment.

6.7 Emergency Closing

At times, emergencies such as severe weather, fires or power failures, can disrupt company operations. In extreme cases, these circumstances may require the closing of a work facility.

When operations are officially closed due to emergency conditions, the time off from scheduled work will be unpaid. However, with supervisory approval, employees may use available paid leave time, such as unused vacation benefits.

In cases where an emergency closing is not authorized, employees who fail to report for work will not be paid for the time off. Employees in essential operations may be asked to work on a day when operations are officially closed. In these circumstances, employees who work will receive regular pay.

6.8 Business Travel Expenses

Win Thein & Sons Co., Ltd will reimburse employees for reasonable business travel expenses incurred while on assignments away from the normal work location. All business travel must be approved in advance by the immediate supervisor.

Employees whose travel plans have been approved should make all travel arrangements through Win Thein & Sons Co., Ltd travel department. When approved, the actual costs of travel, meals, lodging, and other expenses directly related to accomplishing business travel objectives will be reimbursed by Win Thein & Sons Co., Ltd. Employees are expected to limit expenses to reasonable amounts.

Expenses that generally will be reimbursed include the following:

• Airfare or train fare for travel in coach or economy class.

• Car rental fees, only for compact or mid-sized cars.

• Fares for shuttle or airport bus service, where available; costs of public transportation for other ground travel.

• Taxi fares, only when there is no less expensive alternative.

• Mileage costs for use of personal cars, only when less expensive transportation is not available.

• Cost of standard accommodations in low to mid-priced hotels, motels, or similar lodgings.

• Cost of meals, no more lavish than would be eaten at the employee's own expense.

• Tips, not exceeding 15% of the total cost of a meal or 10% of a taxi fare.

• Charges for telephone calls and similar services for business purposes.

• Charges for one personal telephone call each day.

• Charges for laundry and valet services, only on trips of five or more days. (Personal entertainment and personal care items are not reimbursed.)

Employees are encouraged to use their cellular telephone or calling cards when traveling, as hotel charges are excessive.

Employees who are involved in an accident while traveling on business must promptly report the incident to their immediate supervisor. Vehicles owned, leased, or rented by Win Thein & Sons Co., Ltd may not be used for personal use without prior approval.

Cash advances of ($ subjected to each trip) to cover reasonable anticipated expenses may be made to employees, after travel has been approved. Employees should submit a written request to their supervisor when travel advances are needed.

When travel is completed, employees should submit completed travel expense reports within 30 days. Reports should be accompanied by receipts for all individual expenses.

Employees should contact their supervisor for guidance and assistance on procedures related to travel arrangements, travel advances, expense reports, reimbursement for specific expenses, or any other business travel issues.

Abuse of this business travel expenses policy, including falsifying expense reports to reflect costs not incurred by the employee, can be grounds for disciplinary action, up to and including termination of employment.

6.8.1 Transportation & Travel

The Company recognizes that employees who travel far from home to represent the Company’s business interests must forego their living accommodations and may forfeit personal time. Accordingly, the Company will make efforts to provide comfortable and secure accommodations for lodging, meals, and travel for employees if applicable.

However, these items are not intended to be perquisites and the Company reserves the right to deny reimbursement of expenses that are considered lavish or extravagant. Expenses are to be within established Company guidelines and will be reimbursed with proper documentation. Employees are expected to spend the Company’s money as carefully and judiciously as they would their own.

6.8.2 Company Owned Vehicle

Management must authorize all travel in Company vehicles on other than Company business in advance. This includes vehicles that may be leased by the Company as well as those vehicles that are Company owned.

The following are specific policies related to Company owned vehicles:

• Daily logs must be kept for all mileage driven.

• Company owned vehicles should be driven only as needed for jobs during working hours.

• Company owned vehicles should be driven only for transportation to and from destinations as specified.

• Company owned vehicles should not be driven for private use unless specific financial arrangements have been made.

• Only the driver assigned to the vehicle should sign for gasoline, oil, etc.

• All charge tickets must show the name and address of the vendor, prices, gallons, vehicle ID number, license tag number, and mileage.

• No alcoholic beverages or illegal drugs or chemicals should be aboard a Company vehicle at any time.

6.8.3 Personal Vehicle

Employees may use their personal vehicles on official Company business provided prior approval has been obtained from the Company. A mileage rate based on acceptable regulations should be paid to employees who use their personal vehicles on official Company business.

Minimum insurance requirements as specified by the Company’s insurance carrier must be in effect at the time the employee’s personal vehicle is used and the employee may be required to provide the appropriate proof of insurance.

6.8.4 Expense Records

All expense records (including gasoline credit card receipts) should be turned in to the Human Resource Department on a weekly basis for timely payment. Expenses that are not turned in within 30 days of returning from travel may not be approved for payment.

6.8.5 Travel Advances

An advance for out-of-state travel may be provided upon request to the management. The corresponding expense report is expected within one week of return from travel. If this substantiation is not completed within 60 days, any unaccounted for and unreturned advance monies will be liable to employee towards the company.

6.8.6 Expense Reimbursement – Third Party

If the employee incurred expenses, which should be covered by some other party than the Company, the employee must notify the Company about this in order to avoid a double reimbursement. Any time another party covers expenses of any kind; the Company should not provide reimbursements.

If the employee has already been reimbursed by the Company for expenses and thereafter receives reimbursement from a third party, the employee must endorse all reimbursements to the Company upon receipt.

6.8.7 Expense Policies – Violations

Clear, honest, well-documented, and organized expense reports are of vital importance to The Company. Due to this importance, every employee should be familiar with all aspects of the current expense policies as described in the handbook. Any questions should be directed to the HR Department. Violations and any form of abuse in relation to these policies and standards may be disciplined and can ultimately lead to termination.

6.8.8 Company Credit Cards

Employees authorized to use a Company credit card are responsible for protecting the use of the credit card and for submitting all credit card charge tickets to the proper department for validation before payment of the credit card invoice.

6.8.9 Appearance & Belongings

Employees are expected to use their good judgment and common sense in presenting themselves as “appropriate” for their positions. Clothing, hairstyles, or personal hygiene should not pose a safety hazard or create an unacceptable appearance.

Personal appearance, proper hygiene and appropriate attire are important to the work environment. Clients may gauge the quality of the Company by the attention the Company employees show to their personal appearance and attire. Employees are expected to report to work wearing clean clothing appropriate to their position.

6.8.10 Personal Appearance

A neat, well-groomed appearance is important to the employee, their fellow workers and to the Company’s customers and suppliers. The Company does not object to male employees having long hair if it is clean and groomed, nor does it object to mustaches or beards if they are kept trimmed and do not hinder the employee’s performance or safety on the job.

6.8.11 Business Attire

Business situations such as meeting with clients or customers or representing the Company require business attire. Men: Suits with ties and polished shoes with leather soles. Women: Suit, dress, or matching skirt and blouse ensemble.

6.8.12 Casual Attire

Normal working hours that do not require client meetings allow for a more relaxed and casual appearance with some minimum standards. Men: must wear shirts with collars and buttons, socks and no jeans or gym shoes. Women: dress appropriately observing the inappropriate attire below.

“Casual Day” occurs on Friday of each week. The Company may relax the “Casual Attire” standard above to allow jeans and gym shoes while still observing the inappropriate attire below.

6.8.13 Inappropriate Attire

Articles of clothing that either exposes too much of the employee, is in state of disrepair, contains obscene references or are too casual are considered to be unprofessional and should not be worn in a business environment. Such clothes can be considered harassing, offensive, or just too casual for the office.

Items of specific religious or cultural significance may be acceptable in the office provided they are being worn for such a purpose. Examples of unacceptable attire include:

• Tank tops, halter tops, or muscle shirts that expose the shoulders.

• Bare navels or transparent blouses.

• Obscene clothing adorned with foul language or images.

• Torn clothing or clothing with holes.

• Sweat pants, sweat suits, running shorts, or “work out” clothes.

• Hats or headbands indoors.

6.8.14 Personal Belongings

The Company recognizes an employee’s desire to display mementos pertaining to their family or other personal items. While the Company can take no responsibility for the safekeeping of these items, it welcomes its employees to personalize their work areas for added comfort or pleasantness. However, several guidelines must be observed:

(1) Nothing can be displayed that (in the opinion of management) is derogatory to any person or system of beliefs.

(2) Objects (in the opinion of management) that are inappropriate or hinder work efforts should not be allowed and must be removed upon request.

(3) Safety comes first – No object should interfere with job safety as viewed by the Company management.

6.8.15 Alcohol and Drugs

Consumption of, possession of, or being under the influence of alcoholic beverages or illegal drugs on Company property, in the office, or in Company vehicles, is strictly prohibited. Violation of this policy is cause for immediate termination of employment.
The Company reserves the right to have employees tested, screened, and/or searched on Company property for drug and alcohol use, as it deems necessary as long as these procedures do not violate any existing laws.

6.8.16 Medication

An employee placed on medication by a physician should report that fact to their supervisors and present a release form from the physician indicating that the individual is able to perform their daily work routine.

6.9 Visitors in the Workplace

To provide for the safety and security of employees and the facilities at Win Thein & Sons Co., Ltd, only authorized visitors are allowed in the workplace. Restricting unauthorized visitors helps maintain safety standards, protects against theft, ensures security of equipment, protects confidential information, safeguards employee welfare, and avoids potential distractions and disturbances.

All visitors should enter Win Thein & Sons Co., Ltd at the reception area. Authorized visitors will receive directions or be escorted to their destination. Employees are responsible for the conduct and safety of their visitors.

If an unauthorized individual is observed on Win Thein & Sons Co., Ltd premises, employees should immediately notify their supervisor or, if necessary, direct the individual to the reception area.

6.9.1 Parking

An adequate parking area is provided for employees. Employees may park in any space that is not marked reserved. Please cooperate by not blocking any gate, driveway, or the dock of the shipping and receiving area. The Company assumes no responsibility for employee’s vehicles or their contents while on Company property.

6.10 Computer and Email Usage

Computers, computer files, the email system, and software furnished to employees are valuable, vital assets and Win Thein & Sons Co., Ltd property intended for business use. Employees should not use a password, access a file, or retrieve any stored communication without authorization. To ensure compliance with this policy, computer and email usage may be monitored.

Win Thein & Sons Co., Ltd has the right to monitor all of its information technology system and to access, monitor, and intercept any communications, information, and data created, received, stored, viewed, accessed or transmitted via those systems.

Win Thein & Sons Co., Ltd strives to maintain a workplace free of harassment and sensitive to the diversity of its employees. Therefore, Win Thein & Sons Co., Ltd prohibits the use of computers and the email system in ways that are disruptive, offensive to others, or harmful to morale.

For example, the display or transmission of sexually explicit images, messages, and cartoons is not allowed. Other such misuse includes, but is not limited to, ethnic slurs, racial comments, off-color jokes, or anything that may be construed as harassment or showing disrespect for others.

Email may not be used to solicit others for commercial ventures, religious or political causes, outside organizations, or other non-business matters.

6.11 Internet Usage

Internet access to global electronic information resources on the World Wide Web is provided by Win Thein & Sons Co., Ltd to assist employees in obtaining work-related data and technology. The following guidelines have been established to help ensure responsible and productive Internet usage. While Internet usage is intended for job-related activities, incidental and occasional brief personal use is permitted within reasonable limits.

All Internet data that is composed, transmitted, or received via our computer communications systems is considered to be part of the official records of Win Thein & Sons Co., Ltd and, as such, is subject to disclosure to law enforcement or other third parties. Consequently, employees should always ensure that the business information contained in Internet email messages and other transmissions is accurate, appropriate, ethical, and lawful.

The equipment, services, and technology provided to access the Internet remain at all times the property of Win Thein & Sons Co., Ltd. As such, Win Thein & Sons Co., Ltd reserves the right to monitor Internet traffic, and retrieve and read any data composed, sent, or received through our online connections and stored in our computer systems.

Data that is composed, transmitted, accessed, or received via the Internet must not contain content that could be considered discriminatory, offensive, obscene, threatening, harassing, intimidating, or disruptive to any employee or other person.

Examples of unacceptable content may include, but are not limited to, sexual comments or images, racial slurs, gender-specific comments, or any other comments or images that could reasonably offend someone on the basis of race, age, sex, religious or political beliefs, national origin, disability, sexual orientation, or any other characteristic protected by law.

The unauthorized use, installation, copying, or distribution of copyrighted, trademarked, or patented material on the Internet is expressly prohibited. As a rule, if an employee did not create the material, does not own the rights to it, or has not gotten authorization for its use, it should not be put on the Internet. Employees are also responsible for ensuring that the person sending any material over the Internet has the appropriate distribution rights.

Internet users should take the necessary anti-virus precautions before downloading or copying any file from the Internet. All downloaded files are to be checked for viruses; all compressed files are to be checked before and after decompression.

Abuse of the Internet access provided by Win Thein & Sons Co., Ltd in violation of law or Win Thein & Sons Co., Ltd policies will result in disciplinary action, up to and including termination of employment. Employees may also be held personally liable for any violations of this policy.

The following behaviors are examples of previously stated or additional actions and activities that are prohibited and can result in disciplinary action:

• Airfare or train fare for travel in coach or economy class.

• Car rental fees, only for compact or mid-sized cars.

• Fares for shuttle or airport bus service, where available; costs of public transportation for other ground travel.

• Taxi fares, only when there is no less expensive alternative.

• Mileage costs for use of personal cars, only when less expensive transportation is not available.

• Cost of standard accommodations in low to mid-priced hotels, motels, or similar lodgings.

• Cost of meals, no more lavish than would be eaten at the employee's own expense.

• Tips, not exceeding 15% of the total cost of a meal or 10% of a taxi fare.

• Charges for telephone calls and similar services for business purposes.

• Charges for one personal telephone call each day.

• Charges for laundry and valet services, only on trips of five or more days. (Personal entertainment and personal care items are not reimbursed.)

6.12 Workplace Monitoring

Workplace monitoring may be conducted by Win Thein & Sons Co., Ltd to ensure quality control, employee safety, security, and customer satisfaction.

Employees who regularly communicate with customers may have their telephone conversations monitored or recorded. Telephone monitoring is used to identify and correct performance problems through targeted training. Improved job performance enhances our customers' image of Win Thein & Sons Co., Ltd as well as their satisfaction with our service.

Computers furnished to employees are the property of Win Thein & Sons Co., Ltd. As such, computer usage and files may be monitored or accessed.

Employees can request access to information gathered through workplace monitoring that may impact employment decisions. Access will be granted unless there is a legitimate business reason to protect confidentiality or an ongoing investigation.

Because Win Thein & Sons Co., Ltd is sensitive to the legitimate privacy rights of employees, every effort will be made to guarantee that workplace monitoring is done in an ethical and respectful manner.

6.13 Workplace Violence Prevention

Win Thein & Sons Co., Ltd is committed to preventing workplace violence and to maintaining a safe work environment. Win Thein & Sons Co., Ltd has adopted the following guidelines to deal with intimidation, harassment, or other threats of (or actual) violence that may occur during business hours or on its premises.

All employees, including supervisors and temporary employees, should be treated with courtesy and respect at all times. Employees are expected to refrain from fighting, "horseplay," or other conduct that may be dangerous to others.

Conduct that threatens, intimidates, or coerces another employee, a customer, or a member of the public at any time, including off-duty periods, will not be tolerated. This prohibition includes all acts of harassment, including harassment that is based on an individual's sex, race, age, or any characteristic protected by law.

All threats of (or actual) violence, both direct and indirect, should be reported as soon as possible to your immediate supervisor or any other member of management. This includes threats by employees, as well as threats by customers, vendors, solicitors, or other members of the public. When reporting a threat of violence, you should be as specific and detailed as possible.

All suspicious individuals or activities should also be reported as soon as possible to a supervisor. Do not place yourself in peril. If you see or hear a commotion or disturbance near your workstation, do not try to intercede or see what is happening.

Win Thein & Sons Co., Ltd will promptly and thoroughly investigate all reports of threats of (or actual) violence and of suspicious individuals or activities. The identity of the individual making a report will be protected as much as is practical. In order to maintain workplace safety and the integrity of its investigation, Win Thein & Sons Co., Ltd may suspend employees, either with or without pay, pending investigation.

Anyone determined to be responsible for threats of (or actual) violence or other conduct that is in violation of these guidelines will be subject to prompt disciplinary action up to and including termination of employment.

Win Thein & Sons Co., Ltd encourages employees to bring their disputes or differences with other employees to the attention of their supervisors or the HUMAN RESOURCES DEPARTMENT OR OTHER before the situation escalates into potential violence. Win Thein & Sons Co., Ltd is eager to assist in the resolution of employee disputes and will not discipline employees for raising such concerns.

6.14 Equipment & Facilities

All employees should be concerned with the care and safe use of Company-owned equipment and facilities. Good housekeeping is expected from everyone.

6.15 Motor Vehicle and Workplace Equipment Operation

Employees authorized to drive a Company vehicle are completely responsible for fines resulting from traffic violations. Only Company employees are authorized to ride in or operate a Company vehicle. Any changes to your driving record must be reported to Human Resources in a timely manner.

6.16 Safety Equipment

The Company shall provide employees with safety equipment where needed. This safety equipment (e.g. safety glasses) must be worn on the job, as safety requires. This equipment should be signed for by the employee and replaced at their expense if lost, stolen, or broken due to carelessness or misuse. Replacements shall be provided by the company if the equipment is shown to be defective through no fault of the user (e.g., manufacturer’s defect) or where safety equipment is degraded due to normal wear and tear.

6.17 Company Tools

The Company should furnish all necessary tools and equipment to complete job assignments. Each employee is reminded that all items purchased by the Company remain the property of the Company and represent a very valuable asset of the Company.

It is the responsibility of the employee to whom tools and equipment are assigned to maintain and safeguard these assets as if they were their personal property. It is the policy of this Company to hold the individual responsible for small tools and equipment lost, stolen, or damaged though negligence.

A periodic inventory of tools and equipment should be made. When leaving a work area, it is recommended that all tools that cannot be secured in locked storage be removed from the work area.

6.18 Waste Prevention

Waste of energy and materials is costly to the Company and ultimately results in losses, which must be paid for by other cost reduction actions. Please conserve energy at every opportunity by keeping thermostats in moderate ranges. Drive within speed limits. Turn lights and other electrical equipment off when not in use. All scrap materials and parts remain the property of the Company. An employee may discuss personal use of scrap materials and parts with the supervisors. Management should make the final decision.

6.19 Solicitation and/or Distribution

Solicitations and/or distributions, as well as gambling and athletic pools, are prohibited on Company property or communications equipment. All employees are expected to use discretion in the soliciting of friends and co-workers for personal activities, clubs, charities, and other social organizations in order to limit the disruptions for non-Company business while on Company time.

Several types of solicitation and distribution activities are specifically prohibited including the soliciting for or engaging in gambling activities, athletic pools, or any other illegal activities.

Additionally, Company computer and communications resources may only be used for conducting Company business. Games such as “fantasy football” or unauthorized “bulletin board” activity involving computer and communication resources are prohibited.

6.20 Bulletin Board

The Company maintains a bulletin board to keep employees informed of current items of general interest. Employees should check the bulletin board regularly. Posting and removal of notices must have the approval of management.

7. Employee Conduct & Disciplinary Action

7.1 Employee Conduct and Work Rules

To ensure orderly operations and provide the best possible work environment, Win Thein & Sons Co., Ltd expects employees to follow rules of conduct that will protect the interests and safety of all employees and the organization.

It is not possible to list all the forms of behavior that are considered unacceptable in the workplace. The following are examples of infractions of rules of conduct that may result in disciplinary action, up to and including termination of employment:

• Theft or inappropriate removal or possession of property

• Falsification of timekeeping records

• Working under the influence of alcohol or illegal drugs

• Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace, while on duty, or while operating employer-owned vehicles or equipment

• Fighting or threatening violence in the workplace

• Boisterous or disruptive activity in the workplace

• Negligence or improper conduct leading to damage of employer-owned or customer-owned property

• Insubordination or other disrespectful conduct

• Violation of safety or health rules

• Sexual or other unlawful or unwelcome harassment

• Possession of dangerous or unauthorized materials, such as explosives or firearms, in the workplace

• Excessive absenteeism or any absence without notice

• Unauthorized use of telephones, mail system, or other employer-owned equipment

• Unauthorized disclosure of business "secrets" or confidential information

• Violation of personnel policies

• Unsatisfactory performance or conduct

7.2 Sexual and Other Unlawful Harassment

Win Thein & Sons Co., Ltd is committed to providing a work environment that is free from all forms of discrimination and conduct that can be considered harassing, coercive, or disruptive, including sexual harassment. Actions, words, jokes, or comments based on an individual's sex, race, color, national origin, age, religion, disability, or any other legally protected characteristic will not be tolerated.

Sexual harassment is defined as unwanted sexual advances, or visual, verbal, or physical conduct of a sexual nature. This definition includes many forms of offensive behavior and includes gender-based harassment of a person of the same sex as the harasser. The following is a partial list of sexual harassment examples:

• Unwanted sexual advances.

• Offering employment benefits in exchange for sexual favors.

• Making or threatening reprisals after a negative response to sexual advances.

• Visual conduct that includes leering, making sexual gestures, or displaying of sexually suggestive objects or pictures, cartoons or posters.

• Verbal conduct that includes making or using derogatory comments, epithets, slurs, or jokes.

• Verbal sexual advances or propositions.

• Verbal abuse of a sexual nature, graphic verbal commentaries about an individual's body, sexually degrading words, or suggestive or obscene letters or invitations.

Unwelcome sexual advances (either verbal or physical), requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute sexual harassment when:

(1) submission to such conduct is made either explicitly or implicitly a term or condition of employment;

(2) submission or rejection of the conduct is used as a basis for making employment decisions; or,

(3) the conduct has the purpose or effect of interfering with work performance or creating an intimidating, hostile, or offensive work environment.

If you experience or witness sexual or other unlawful harassment in the workplace, report it immediately to your supervisor. If the supervisor is unavailable or you believe it would be inappropriate to contact that person, you should immediately contact the HUMAN RESOURCES DEPARTMENT or any other member of management. You can raise concerns and make reports without fear of reprisal or retaliation.

All allegations of sexual harassment will be quickly and discreetly investigated. To the extent possible, your confidentiality and that of any witnesses and the alleged harasser will be protected against unnecessary disclosure. When the investigation is completed, you will be informed of the outcome of the investigation.

Any supervisor or manager who becomes aware of possible sexual or other unlawful harassment must immediately advise the HUMAN RESOURCES DEPARTMENT or any member of management, so it can be investigated in a timely and confidential manner. Anyone engaging in sexual or other unlawful harassment will be subject to disciplinary action, up to and including termination of employment.

7.3 Attendance and Punctuality

To maintain a safe and productive work environment, Win Thein & Sons Co., Ltd expects employees to be reliable and to be punctual in reporting for scheduled work. Absenteeism and tardiness place a burden on other employees and on Win Thein & Sons Co., Ltd. In the rare instances when employees cannot avoid being late to work or are unable to work as scheduled, they should notify their supervisor as soon as possible in advance of the anticipated tardiness or absence. Poor attendance and excessive tardiness are disruptive. Either may lead to disciplinary action, up to and including termination of employment.

7.4 Personal Appearance

Dress, grooming, and personal cleanliness standards contribute to the morale of all employees and affect the business image Win Thein & Sons Co., Ltd presents to customers and visitors.

During business hours or when representing Win Thein & Sons Co., Ltd, you are expected to present a clean, neat, and tasteful appearance. You should dress and groom yourself according to the requirements of your position and accepted social standards. This is particularly true if your job involves dealing with customers or visitors in person.

Your supervisor or department head is responsible for establishing a reasonable dress code appropriate to the job you perform. Consult your supervisor if you have questions as to what constitutes appropriate appearance. Where necessary, reasonable accommodation may be made to a person with a disability.

Without unduly restricting individual tastes, the following personal appearance guidelines should be followed:

• Jeans, Bermuda, T-shirt and shorts do not present appropriate professional attire.

• Unnaturally colored hair and extreme hairstyles, such as spiked hair and shaved heads, do not present an appropriate professional appearance.

• Offensive body odor and poor personal hygiene is not professionally acceptable.

• Facial jewelry, such as eyebrow rings, nose rings, lip rings, and tongue studs, is not professionally appropriate and must not be worn during business hours.

• Multiple ear piercings (more than one ring in each ear) are not professionally appropriate and must not be worn during business hours.

• Visible excessive tattoos and similar body art must be covered during business hours.

7.5 Return of Property

Employees are responsible for all Win Thein & Sons Co., Ltd property, materials, or written information issued to them or in their possession or control. Employees must return all Win Thein & Sons Co., Ltd property immediately upon request or upon termination of employment. Where permitted by applicable laws, Win Thein & Sons Co., Ltd may withhold from the employee's check or final paycheck the cost of any items that are not returned when required. Win Thein & Sons Co., Ltd may also take all action deemed appropriate to recover or protect its property.

7.6 Resignation and Retirement

Resignation is a voluntary act initiated by the employee to terminate employment with Win Thein & Sons Co., Ltd. Advance notice is required, Win Thein & Sons Co., Ltd requests at least 2 month’s written notice of resignation from employees.

Prior to an employee's departure, an exit interview may be scheduled to discuss the reasons for resignation and the effect of the resignation on benefits.

In line with actual legislation Win Thein & Sons Co., Ltd does not have an age where it expects employees to retire. It is however our policy to have discussions with all our staff where they can discuss their future aims and aspirations. Staff and their managers can also use this opportunity to discuss retirement planning should the employee wish to do so.

You should ensure that you inform your line manager at least 2 months before you plan to retire to ensure that all appropriate arrangements are made (ex: sourcing a replacement etc.).

7.7 Security Inspections

Win Thein & Sons Co., Ltd wishes to maintain a work environment that is free of illegal drugs, alcohol, firearms, explosives, or other improper materials. To this end, Win Thein & Sons Co., Ltd prohibits the possession, transfer, sale, or use of such materials on its premises. Win Thein & Sons Co., Ltd requires the cooperation of all employees in administering this policy.

Desks, lockers, and other storage devices may be provided for the convenience of employees but remains the sole property of Win Thein & Sons Co., Ltd. Accordingly, they, as well as any articles found within them, can be inspected by any agent or representative of Win Thein & Sons Co., Ltd at any time, either with or without prior notice.

7.8 Progressive Discipline

It is the policy of the Company to expect all employees to abide by certain work rules of general conduct and performance at all times. Management, supervisors, and all employees are expected to monitor and enforce these work rules equally. The purpose of this policy is to state Win Thein & Sons Co., Ltd position on administering equitable and consistent discipline for unsatisfactory conduct in the workplace. The best disciplinary measure is the one that does not have to be enforced comes from good leadership and fair supervision at all employment levels.

Win Thein & Sons Co., Ltd own best interest lies in ensuring fair treatment of all employees and in making certain that disciplinary actions are prompt, uniform, and impartial. The major purpose of any disciplinary action is to correct the problem, prevent recurrence, and prepare the employee for satisfactory service in the future.

Win Thein & Sons Co., Ltd recognizes that there are certain types of employee problems that are serious enough to justify either a suspension, or, in extreme situations, termination of employment, without going through the usual progressive discipline steps.

By using progressive discipline, we hope that most employee problems can be corrected at an early stage, benefiting both the employee and Win Thein & Sons Co., Ltd.

Generally, there are four types of misconduct:

  1. Absenteeism and tardiness problems.

  2. Policy and procedure violations.

  3. Performance.

  4. Behavior and conduct infractions.

These transgressions can occur simultaneously and then written up individually or grouped together on one report. The disciplinary action taken is a result of the severity of the offense. Misconduct transgressions are divided into three levels of severity: Serious, Very Serious and Inexcusable. Misconduct shall be noted in the employee’s personnel file. Management reserves the right to terminate or discipline any employee for misconduct.

Serious Misconduct

The first level of misconduct involves activities that undermine the Company’s morale or focus, thus leading to a loss of attention to detail, quality or professionalism. Company management’s first response should include verbal warnings to alert employees to the unacceptable behavior.

The disciplinary action for Serious Misconduct for the second offense should be a written notice with a copy to the employee’s personnel file. A third occurrence should result in a “Final Written” notice. Further occurrences of serious misconduct may then result in the employee being suspended for one (1) to five (5) working days with or without pay, leading to termination. Offenses include:

• Unauthorized leave from the work area during work schedule exceeding the time allowed for scheduled break or lunch period.

• Unauthorized distribution of literature in the work area or posting on Company property.

• Distraction of other employees, or causing confusion by unnecessary shouting, catcalls, whistling or demonstration while on Company property.

• Punching in more than five minutes prior to the start of the employee's shift or more than fifteen minutes following the conclusion of their shift without authorized permission.

• Engaging in horseplay, practical jokes, gambling, selling merchandise, solicitation, or general loitering while on Company property. This applies to non-shift time as well as shift time.

• Having non-employees on Company property at any time without authorized permission.

• Using profane language on Company property, which in management’s opinion is offensive to guests and to other employees.

• Unauthorized manufacture of products for personal use.

Very Serious Misconduct

The second level of misconduct involves activities that more than undermine The Company’s morale or focus but also cross the line of attention to detail, quality or professionalism. In other words, The Company is now experiencing the effects of lower morale or focus and such actions could lead to worse harm if continued. Company management’s first response should include both verbal and written warnings alerting the employee that the unacceptable behavior is harming The Company.

The disciplinary action for Very Serious Misconduct for the second offense should result in a “Final Written” notice. Further occurrences of Very Serious Misconduct may then result in the employee being suspended for one to five working days with or without pay or termination.

Offenses include:

• Reporting for work or entering the plant under the influence or when suffering from a hangover from alcohol, any intoxicant, any narcotic, any barbiturate, any amphetamine, any hallucinogen, or any other stimulating or depressing drug.

• Threatening, intimidating, coercing, or interfering with any person on Company premises at any time.

• Sleeping on Company time.

• Altering, defacing or removing governmental or Company notices and bulletins that are posted on the Company bulletin board.

• Gaining unauthorized access to Company records and files whether they are locked or otherwise.

• Handling or operating machines, tools or equipment, which do not come within the employee’s authority.

• Careless or negligent use or operation of Company tools or equipment.

• Failure to immediately report any injury or accident to management resulting from an on-the-job situation.

• Performing substandard work both in quality and quantity after having been instructed in proper procedure and technique.

Inexcusable Misconduct The final level of misconduct involves activities that undermine The Company’s morale or focus, cross the line of attention to detail, quality or professionalism, and are done with deliberate intent to harm The Company. In other words, The Company is now experiencing the effects and is being harmed in a substantive way.

Company management’s first response should include both a verbal and a “Final Written” notice alerting the employee that the unacceptable behavior has harmed the Company and that complete disciplinary action results are pending the results of an investigation. Next, management should begin an investigation into the extent of the damage to the Company in order to determine the disciplinary action to be applied.

The disciplinary action for Inexcusable Misconduct may then result in the employee being suspended for one to five working days with or without pay or termination.

Offenses include:

• Falsification of any reports, reports pertaining to absence from work, claims pertaining to injuries occurring on Company premises, claims for any benefits provided by the Company, communications, or records including personnel and production records.

• Giving false fire alarms, or causing false fire alarms to be given, or tampering with plant protection equipment.

• Restricting output, or persuading others to do so, or promoting, encouraging, agitating, engaging in, or supporting suspension of work, slowdowns, or any other interruptions of production.

• Sabotage, or subversive activity of any kind.

• Misuse or removal from the premise, without authorization, of any Company property, or possession of any property removed from Company premise without proper authorization.

• Bringing, using, or having in possession weapons on Company premises at any time.

• Bringing, using or having in possession, transporting, selling, or promoting the use of alcohol, any intoxicant, any narcotic, any barbiturate, any amphetamine, any hallucinogen, or any other stimulating or depressing drug on Company premise at any time.

• Striking or manhandling another person or fighting while on Company premises at any time.

• Striking a supervisor or other member of management at any time.

• Theft of any property on Company premises, or a theft matter relating to employment.

• Willful abuse, or deliberate destruction of Company property, tools or equipment or any property on Company premises at any time.

• Gross insubordination – a willful and deliberate refusal to follow reasonable orders given by a member of management.

• Violation of the Company’s Equal Employment Opportunity Policy or Harassment Policy.

• Committing an immoral or indecent act while on Company property regardless of whether the act was committed during the employee’s shift.

• Altering any employee time card regardless of whether it is the employee’s own card or that of another employee.

• Intentionally punching the time card of another employee or having another employee punch their time card.

• Conviction of any offense by a court of law which, in management’s judgment, would make that employee undesirable for association with the Company and its other employees.

Misconduct Investigations

The Company may be required to investigate suspected employee misconduct. Investigations may be conducted by outside investigators, management, or law enforcement personnel. All employees are expected to assist any investigation to the best of their abilities.

7.9 Problem Resolution

Win Thein & Sons Co., Ltd is committed to providing the best possible working conditions for its employees. Part of this commitment is encouraging an open and frank atmosphere in which any problem, complaint, suggestion, or question receives a timely response from Win Thein & Sons Co., Ltd supervisors and management.

Win Thein & Sons Co., Ltd strives to ensure fair and honest treatment of all employees. Supervisors, managers, and employees are expected to treat each other with mutual respect. Employees are encouraged to offer positive and constructive criticism.

If employees disagree with established rules of conduct, policies, or practices, they can express their concern through the problem resolution procedure. No employee will be penalized, formally or informally, for voicing a complaint with Win Thein & Sons Co., Ltd in a reasonable, business-like manner, or for using the problem resolution procedure.

If a situation occurs when employees believe that a condition of employment or a decision affecting them is unjust or inequitable, they are encouraged to make use of the following steps. The employee may discontinue the procedure at any step.

  1. Employee presents problem to immediate supervisor after incident occurs. If supervisor is unavailable or employee believes it would be inappropriate to contact that person, employee may present problem to HUMAN RESOURCES DEPARTMENT or any other member of management.
  1. Supervisor responds to problem during discussion or after consulting with appropriate management, when necessary. Supervisor documents discussion.
  1. Employee presents problem to HUMAN RESOURCES DEPARTMENT if problem is unresolved.
  1. HUMAN RESOURCES DEPARTMENT counsels and advises employee, assists in putting problem in writing and visits with employee's manager(s), if necessary.
  1. Employee presents problem to the President in writing.
  1. The President reviews and considers problem. The President informs employee of decision and forwards copy of written response to HUMAN RESOURCES DEPARTMENT for employee's file. The President has full authority to make any adjustment deemed appropriate to resolve the problem.

Not every problem can be resolved to everyone's total satisfaction, but only through understanding and discussion of mutual problems can employees and management develop confidence in each other. This confidence is important to the operation of an efficient and harmonious work environment and helps to ensure everyone's job security.

7.10 Workplace Etiquette

Win Thein & Sons Co., Ltd strives to maintain a positive work environment where employees treat each other with respect and courtesy. Sometimes issues arise when employees are unaware that their behavior in the workplace may be disruptive or annoying to others. Many of these day-to-day issues can be addressed by politely talking with a co-worker to bring the perceived problem to his or her attention. In most cases, common sense will dictate an appropriate resolution. Win Thein & Sons Co., Ltd encourages all employees to keep an open mind and graciously accept constructive feedback or a request to change behavior that may be affecting another employee's ability to concentrate and be productive.

The following workplace etiquette guidelines are not necessarily intended to be hard and fast work rules with disciplinary consequences. They are simply suggestions for appropriate workplace behavior to help everyone be more conscientious and considerate of co-workers and the work environment. Please contact the HUMAN RESOURCES DEPARTMENT if you have comments, concerns, or suggestions regarding these workplace etiquette guidelines.

• Return copy machine and printer settings to their default settings after changing them.

• Replace paper in the copy machine and printer paper trays when they are empty.

• Retrieve print jobs in a timely manner and be sure to collect all your pages.

• Be prompt when using the manual feed on the printer.

• Keep the area around the copy machine and printers orderly and picked up.

• Be careful not to take or discard others' print jobs or faxes when collecting your own.

• Avoid public accusations or criticisms of other employees. Address such issues privately with those involved or your supervisor.

• Try to minimize unscheduled interruptions of other employees while they are working.

• Communicate by email or phone whenever possible, instead of walking unexpectedly into someone's office or workspace.

• Be conscious of how your voice travels and try to lower the volume of your voice when talking on the phone or to others in open areas.

• Keep socializing to a minimum and try to conduct conversations in areas where the noise will not be distracting to others.

• Minimize talking between workspaces or over cubicle walls. Instead, conduct conversations with others in their workspace.

• Try not to block walkways while carrying on conversations.

• Refrain from using inappropriate language (swearing) that others may overhear.

• Monitor the volume when listening to music, voice mail, or a speakerphone that others can hear.

• Clean up after yourself and do not leave behind waste or discarded papers.

7.10.1 Legal & Ethical Conduct

It is the policy of the Company that each employee conducts his/her business affairs with such standards of integrity that no conflict of interest exists or can be reasonably implied or construed. The following paragraphs set forth legal and moral restrictions with respect to legal and ethical business conduct.

Ethical Standards

All employees should comply with the ethical standards of the Company as set forth in this handbook. Employees should routinely ask themselves:

• Is my action legal and ethical?

• Does my action comply with corporate policy?

• Is my action appropriate in the situation?

• Would my action be an embarrassment to the Company, if known?

• Does my action agree with my personal ethics or behavior?

An employee should be able to answer “yes” to all of these questions

before taking action or compromising themselves in the situation.

Unethical business conduct, actions, and even the appearance of unethical behavior are unacceptable under any conditions. The reputation of the Company depends on each employee applying common sense in situations where specific rules of conduct are insufficient to provide clear direction. A strong sense of personal ethics, which should extend beyond compliance with applicable laws, is necessary to guide the behavior of all employees.

Conflicts of Interest

A conflict of interest can arise in dealings with anyone with whom the Company transacts business: Customers, clients, owners, buyers, suppliers, banks, insurance companies, and people in other organizations with whom we contact and make agreements. The following actions and conditions are specifically prohibited, but are not intended to enumerate all actions or situations, which might be avoided:

• Working for any of the groups mentioned above for personal gain.

Employee should not have any direct interest in any company which competes with the Company, sells or supplies to or buys from the Company any products or property, or furnishes any service to the Company.

• Borrowing from, or lending money to, individuals representing organizations with whom business dealings are conducted.

Employee should not borrow money or accept advances or other personal payments or gifts or entertainment from any company or firm (or any person acting directly or indirectly for any company or firm), which has transactions with the Company, as described above.

• Engaging in part-time activity for profit or gain in any field in which the Company is engaged.

Employee should not enter into any transaction, acquire any interest, or take any action which, in his/her own judgment, is contrary to the interest of the Company or is incompatible with loyalty and obligation inherent to his/her employment.

The foregoing prohibitions apply not only to the employee personally, but also to the employee’s spouse and dependent minor children.

Any situation involving a possible conflict of interest which arises in relation to the above outlined policies must be brought to the attention of the employee's immediate supervisor or manager for possible action.

Personal Conduct

The Company expects that all of its employees should conduct themselves with the pride and respect associated with their positions, their fellow employees, customers, suppliers and everyone else associated with the Company in one form or another. Employees should always use good judgment, discretion, and the highest standards of ethical conduct in carrying out the Company’s business.

Confidentiality

The Company is engaged in manufacturing and distribution, which requires that a strict code of confidentiality of information be maintained. No employee should store information outside of the Company (either in written or electronic form) about any matter pertaining to the conduct of the Company’s business. No information regarding the Company’s purchase prices or manufacturing processes shall be given to anybody without permission of senior management.

Conversations regarding prices, service, problems, gossip, etc. about one vendor or customer to another are prohibited. Any employee who compromises information may be subject to dismissal. In addition, idle gossip or dissemination of confidential information within the Company such as personal financial information should subject the responsible employee to disciplinary action or possible termination.

Bribes, Kickbacks, and Illegal Payments

Bribes, kickbacks, and other illegal payments to or from any individual with whom we conduct business (in any form and for any purpose) are prohibited. Certain types of rebates to the Company from suppliers (but not to or from an individual employee) are legitimate to correct commercial inequity if done within government trade regulations.

Patents and Copyrights

Any patent or copyright developed by an employee of the Company is property of the Company. Any information pertaining to such patent or copyright must remain on Company premises. An employee sharing any internal information relating to the Company must have prior approval of management to do so.

If an employee attends conferences, publishes information, or passes on any Company related information to third parties which he or she attained, accumulated, or learned on the job, any monetary compensation awarded to the employee in relation to this form of information sharing is property of the Company.

An employee willing to use his/her own time to work on projects related to the Company or the industry the Company is part of, must have prior approval of management. Projects not related to the Company are at the employee’s discretion and may not interfere in any way with the employees work. All related activities must take place on the employee’s own time and not on the Company premises.

Any violation of these policies can lead to the immediate termination of employment and might have legal consequences.

7.11 Suggestion Program

As employees of Win Thein & Sons Co., Ltd, you have the opportunity to contribute to our future success and growth by submitting suggestions for practical work-improvement or cost-savings ideas. All employees are eligible to participate in the suggestion program.

A suggestion is an idea that will benefit Win Thein & Sons Co., Ltd by solving a problem, reducing costs, improving operations or procedures, enhancing customer service, eliminating waste or spoilage, or making Win Thein & Sons Co., Ltd a better or safer place to work. Statements of problems without accompanying solutions, or recommendations concerning co-workers and management are not appropriate suggestions. All suggestions should contain a description of the problem or condition to be improved, a detailed explanation of the solution or improvement, and the reasons why it should be implemented. If you have questions or need advice about your idea, contact your supervisor for help.

Submit suggestions to the President and, after review, they will be forwarded to the Direction. As soon as possible, you will be notified of the adoption or rejection of your suggestion.

Special recognition may be given to employees who submit a suggestion that is implemented.

**IF YOU HAVE ANY COMMENTS OR SUGGESTIONS REGARDING THE CONTENT OF THE EMPLOYEE HANDBOOK, PLEASE DIRECT THEM TO [HUMAN RESOURCES DEPARTMENT OR OTHER].

WISHING YOU A LONG AND REWARDING CAREER AT Win Thein & Sons Co., Ltd**

8. Acknowledgement of Receipt and Understanding

I acknowledge that I have received a copy of the Win Thein & Sons Co., Ltd Employee Handbook (“Handbook”). I understand that I am responsible for reading and abiding by all policies and procedures in this Handbook, as well as other policies and procedures of the Company.

I also understand that the purpose of this Handbook is to inform me of the Company’s policies and procedures, and it is not a contract of employment. Nothing in this Handbook provides any entitlement to me or to any Company employee, nor is it intended to create contractual obligations of any kind. I understand that the Company has the right to change any provision of this Handbook at any time and that I will be bound by any such changes.

I expressly agree to the provisions of Part 6, Dispute Resolution, of the Handbook, in which I have agreed to use alternative dispute resolution, in lieu of litigation, as the sole means of resolving any dispute that may arise between the Company and me, subject to the Company’s right to seek injunctive relief. I understand that by agreeing to arbitration I waive any right I may have to sue or seek a jury trial. The decision of the arbitrator will be final and binding.


Signature Date


Full Name (please print)

Please sign and date one copy of this acknowledgement and return it to Human Resources. Retain a second copy for your reference. 8.1 Statement of Legal and Ethical Business Conduct Read and Sign Immediately

I have read and understand the section from the Employee Handbook titled “Conflict of Interests.” The following questions are answered complete and honest in accordance to my full knowledge. Within the intent and meaning of the section titled “Conflicts of Interest,” please answer the following questions with “Yes” or “No” if not otherwise indicated:

  1. Have you read and fully understood the Section from the Employee Handbook titled “Conflicts of Interest.” __
  2. Are you are stockholder or hold a financial interest in any way in: a. A competing Company? __ b. A supplier of goods or services or other principal dealings with the Company? __ c. A customer of the Company or in any business venture with a customer concern that you have access to privileged information by reason of your position in the Company? __
  3. Are you a director of any business operated for profit? (If “Yes,” please list the names of the companies.) __



  1. Are there circumstances or any other matters of a personal or family nature, which could reasonably be subject to question as to their effect on the interests of the Company? (If “Yes,” please explain.) __



If, in the future, any situation involving a possible conflict of interest should arise, I shall notify my immediate supervisor before taking any action, which, without the required approval from management, might be incompatible with the outlined policy in the Employee Handbook under the Section “Conflicts of Interest.”

As an employee of Win Thein & Sons Co., Ltd, I will honor to the full extend all rules and regulation discussed in the Employee Handbook, Section “Conflict of Interest” with regard to policies in relation to Patents and Copyrights. I acknowledge that any violation of these policies can lead to immediate termination of my employment at the Company.

Employee's Signature: ___ Date: _ Location: _ Authorized Witness: ___

8.2 Social Media Policy & Acknowledgement

The Company wants its employees to be able to use social media personally and professionally. In either case, employees must use social media responsibly. They must understand that their use of social media, both on and off site and whether using the Company’s communication infrastructure or another means (e.g., public network, private network), carries with it serious responsibilities and potential ramifications. Employees shall endeavor to be good ambassadors for the company and shall not take part in any social media activity that could be construed as illegal, unethical, or harmful to the Company or others.

DISCLOSURE • Use your own name, not a pseudonym or code name that could mislead anyone. Clearly state your role within the Company. • Be clear about your intent and whose interests you represent. If there could be a potential conflict of interests, be clear about this possibility. • Write about issues where you have some expertise and state what your level of expertise is. If you write about a topic on which you are not an expert, make it clear to the reader that you are not a subject matter expert but are expressing an opinion (i.e., write a disclaimer, like “the opinions are mine and not necessarily those of the Company”).

SECURITY

• Never divulge any classified, confidential, or proprietary Company information. This may include but need not be limited to the Company’s trade secrets, product information, litigation, financial information, contracts, patents, and copyrights. If you are unsure, contact the Public Relations Manager or the Manager who is assigned responsibility for social media within the Company. • Do not cast competitors, etc., in a negative or unfavorable light when posting. • Understand the difference between facts and emotions. Don’t post your emotions on social media – they may hurt you and the Company. • Be extremely careful about what you share. Once you share something on social media, you cannot take it back. • Do not post anything without running it past a disinterested, impartial party. In the case of using Company infrastructure, your posts must go through the Company’s social media monitor before posting.

USER GUIDELINES

• Make your posts helpful. Add insight and value for your readers. Be sure your writing is entertaining and informative. We want to build relationships. • Deal with people and issues fairly and factually. • Do not incite or inflame emotions! Debate is fine as long as it is the facts being debated and not personalities. Stay away from innuendo, rumors, character assassination, and topics which could be sensitive to one or more groups. • Any negative reference to race, ethnicity, religion, politics, etc., is strictly forbidden. • Do not try to hide errors or avoid responsibility. Be honest about your mistakes and correct them quickly and completely. Take responsibility for everything you do on social media – the good as well as the bad. • Don’t go where you don’t belong. Sites, blogs, pages, etc., promoting illegal or unethical behavior (e.g., pornography, hate crimes, violence, gambling) are strictly off-limits while using the Company infrastructure and should be any time, regardless of how it is accessed. We expect our employees to exhibit sound judgment and hold themselves to the highest moral standards.

DISCIPLINE

Wrongful behavior in social media will be dealt with on a case-by-case basis. Illegal, immoral, or unethical behavior while using social media may result in the employee’s suspension, termination, and/or prosecution.

ACKNOWLEDGEMENT

By signing this acknowledgement form, I am verifying that I have been trained in the Company’s Social Media Policy, I understand and accept its contents, and I will comply with these guidelines.

(Signature)    (Date)


(Print Name)

8.3 Job Related Incidents

Read and Sign Immediately

This form is used for documentation purposes of Job Related Accidents. Every time an employee incurs an accident on the job, this form has to be completed by the employee, and signed by the employee and the employee’s immediate supervisor or the personnel manager. I, the employee, certify with my signature that all information given is true and to my full knowledge. Any abuses or deliberate misinformation will lead to disciplinary actions. Employee’s Name:


Date of Accident:


Location of Accident:



Description of Accident:











Time Missed from Work:


Medical Treatment: __


Location of Treatment:


Employee’s Signature: ___ Date: ___ Location: ___ Authorized Witness: _

Employee’s Supervisor:__

9. Comprehensive Policies & Procedures