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PROHIBITED ACTIVITIES (STANDARDS OF CONDUCT)

Win Thein & Sons Co., Ltd wishes to create a work environment that promotes job satisfaction, respect, responsibility, and value for all of our employees, clients, customers and other stakeholders. Every employee at Win Thein & Sons Co., Ltd has a shared responsibility toward improving the quality of the work environment. By agreeing to work at Win Thein & Sons Co., Ltd you have agreed to follow the company’s rules and to refrain from conduct which is detrimental to our goals. The prohibited conduct that is listed below is not an inclusive list, as the company cannot, with foresight, determine what inappropriate conduct under every circumstance is. Moreover, the company does not limit its right to discipline or discharge employees to the prohibited conduct listed below. Remember that, while we value our employees, the company maintains the right to terminate its employees at any time and for any reason, with or without notice.

Violation of the prohibited conduct set forth below, or any other conduct deemed inappropriate by management, may subject you to disciplinary action, including oral or written warnings, suspension without pay, transfer or possible termination. If you have any questions about your personal conduct or that of any fellow employee, immediately consult your supervisor for clarification.

The following list contains examples of conduct considered improper which may result in discipline, including termination. Again, note this is not a complete list and understand that other behaviors may also result in discipline.

1. Possessing, using, selling, negotiating the sale of, or being under the influence of alcohol, drugs or other controlled substances during working hours, on company property (including company vehicles), in company uniform or on company business.

2. Falsification of the hours worked by you or any other employee.

3. Falsification of any other employment related document including, but not limited to, personnel files, employment review documents, intra-company communication, communications with those outside the company, expense records, etc.

4. Theft or destruction of company property or that of visitors, clients or fellow employees.

5. Possession of potentially hazardous or dangerous property, such as firearms, weapons, chemicals, etc., without prior authorization.

6. Fighting with, or harassment of, any fellow employee or customer.

7. Unauthorized or excessive use of company property or property of any visitors, customers, fellow employees, including but not limited to, vehicles, supplies, telephones, mail and computers.

8. Disclosure of company trade secrets or any other confidential or proprietary information of the company, its customers or fellow employees.

9. Insubordination, including but not limited to, refusal to perform a requested or required job task.

10. Failure to follow, or general neglect of, safety rules and procedures.

11. Excessive tardiness or absences.

12. Smoking in non-designated areas.

13. The taking of unauthorized overtime.

14. Solicitation of fellow employees on the company premises.

15. Failure to dress appropriately.

16. Failure to keep your workplace in a neat and sanitary condition.

17. Use of obscene or otherwise inappropriate language or conduct in the work place.

18. Failure to provide medical authorizations for medical absences in excess of two days.

19. Inappropriate horseplay which is either distracting to fellow employees or which could create dangers to others.

20. Criminal activity at, or outside of, the workplace.

21. Off-duty conduct which can affect the company’s credibility or reputation.

22. Outside employment which interferes with your ability to perform your job at this company including, but not limited to, that with a competitor of the company.

23. Gambling on company premises.

24. Sleeping or neglect of job duty.

25. Taking unauthorized gratuities in connection with company business.

26. Lending keys to company property to unauthorized persons or allowing duplicate keys to be made.

27. Being away from the work area without prior authorization.

28. Harassment of, or discrimination against, an employee, customer or visitor because of that person’s race, religion, color, sex, age, disability or national origin.

29. Bad-mouthing or spreading rumors.

Disciplinary Action

As indicated earlier, violation of company policies or procedures may result in disciplinary action, including but not limited to, demotion, transfer, suspension with or without pay, or termination. The company encourages a system of progressive discipline depending on the type of prohibited conduct. The company is not required to engage in progressive discipline and may discipline or terminate an employee where he or she violates the rules of conduct, or where the quality or value of their work fails to meet expectations. Again, our attempt at progressive discipline does not imply a contract with you or that your employment is anything other than on an “at will” basis. This means that both the company and the employee may terminate the employment relationship at any time, for any reason, or no reason at all.

As part of our progressive discipline system, and based on the nature of the employee violation, management will attempt to provide the employee first with a verbal warning, then one or more written warnings, and if the conduct is not sufficiently altered, eventual demotion, transfer, forced leave or termination. Your supervisor will make very effort possible to allow you to respond to any disciplinary action taken. Understand that the company is not obligated to follow any disciplinary or grievance procedure and that you may be disciplined or terminated without going through any procedure.