Employee Handbook - West Malaysia

1. Introduction & Company Overview

1.1 Welcome Message from Management

1.2 Purpose of the Employee Handbook

This Employee Handbook is designed to provide employees with a clear understanding of the Company's policies, procedures, and expectations. It serves as a general guide to help employees understand their roles, responsibilities, benefits, and standards of conduct within the Company.

The policies outlined in this Handbook aim to promote consistency, fairness, and a professional working environment. Employees are expected to read, understand, and comply with the contents of this Handbook.

This Handbook is intended to be read in conjunction with applicable employment laws. In the event of any inconsistency, the provisions of the law shall take precedence.

The Company reserves the right to review, amend, update, or withdraw the policies and procedures contained in this Handbook from time to time as deemed necessary.

1.3 Company Background & Business Overview

The Company operates under two business entities, namely Lynch Pin Holdings (LPH) and KIAN Group of Companies, which work closely together to support overall business operations.

LPH provides shared services support to KIAN Group of Companies, including but not limited to administrative, human resources, tech, and operational support functions. In addition, LPH conducts business workshops and training programmes targeted towards external Small & Medium Enterprises (SMEs).

KIAN Group of Companies is primarily involved in the furniture business, including design, manufacturing, distribution, and related services. The Group serves both local and international markets and operates through multiple companies under the KIAN brand.

Together, both entities operate collaboratively while maintaining their respective business functions. Employees may be assigned responsibilities that support either entity depending on business and operational needs.

For the purpose of this Handbook, references to 'the Company' shall include LPH and KIAN Group of Companies unless otherwise stated.

1.4 Vision, Mission & Core Values

The Company is guided by a shared purpose of developing people, strengthening teamwork, and creating meaningful impact through our business and services.

1.4.1 Vision & Purpose

KIAN Group of Companies is guided by the purpose of Better Me, Better We, Better World, which reflects our belief that individual growth leads to stronger teams and ultimately contributes to a positive impact on the wider community.

Lynch Pin Holdings focuses on Better Leaders, Better Culture, Better Business, supporting organisations in developing leadership capability, building strong workplace culture, and achieving sustainable business growth.

Together, both entities share a common direction of empowering people, strengthening organisations, and delivering long-term value to customers and stakeholders.

1.4.2 Core Values - SPARK

Our workplace culture is guided by the SPARK values:

S - Spirit 1Kian / Spirit 1LPH
We work as one team, supporting each other and moving towards shared goals.

P - Proactive
We anticipate needs, address issues early, and take thoughtful action rather than reacting to situations.

A - Authentic Relationships
We build genuine, respectful, and trusting relationships with colleagues, customers, and partners.

R - Reliable
We are accountable for our responsibilities and deliver on our commitments.

K - Kianzen
We embrace continuous learning and improvement to drive personal and organisational growth.

1.5 Scope & Applicability of the Handbook

This Employee Handbook applies to all employees of the Company unless otherwise stated. The policies and guidelines outlined in this Handbook serve as general terms and conditions of employment and are applicable across all departments and positions.

This Handbook should be read together with the employee's Letter of Appointment. In the event of any conflict between this Handbook and the individual employment agreement, the terms stated in the individual agreement shall prevail, unless otherwise required by law.

For the purposes of this Handbook, the terms "Letter of Appointment", "Employment Contract", and "Contract of Service shall be used interchangeably to refer to the formal agreement signed between the employee and the Company.

The Company may issue additional policies, procedures, or guidelines from time to time. Such documents shall form part of this Handbook and must be complied with accordingly.

2. Employment Relationship

2.1 Nature of Employment

The Company offers different types of employment depending on business needs and the nature of the role. These may include permanent employment, contract employment, probationary employment, and internship placements.

Permanent Employment
Employees under permanent employment are engaged on an ongoing basis, subject to successful completion of the probation period (where applicable) and continued satisfactory performance, conduct, and business requirements.

Contract Employment
Contract employees are engaged for a fixed duration or for the completion of a specific project or assignment. The employment will automatically end upon expiry of the contract period unless extended or renewed in writing by the Company.

Probationary Employment
New employees are typically required to undergo a probation period at the beginning of their employment. During this period, the Company will assess the employee's suitability for confirmation of employment.

Internship
Interns are engaged for a fixed duration as part of an academic requirement or learning programme. Internship arrangements are temporary and do not constitute permanent employment with the Company.

The classification of employment will be stated in the employee's Letter of Appointment.

2.2 Employment Classification (EA & Non-EA Employees)

Employees of the Company are classified based on the Employment Act 1955 (as amended) and other applicable labour laws in Malaysia.

EA Employees (Employees covered under the Employment Act)
EA Employees are employees who are covered by the Employment Act 1955. This generally includes:

• Employees whose monthly wages are RM4,000 and below, or any updated amount as stated under the law from time to time; and/or 
• Employees working in roles that are covered under the Employment Act, including manual work and other job categories listed under the law.

EA Employees are entitled to the employment rights and benefits provided under Malaysian law.

Non-EA Employees (Employees not fully covered under the Employment Act)
Non-EA Employees are employees who are not covered under certain parts of the Employment Act due to their job role, salary level, or legal classification.

Their employment terms are mainly based on their Employment Contract and Company policies.

2.3 Appointment & Confirmation

All employees will receive a Letter of Appointment that outlines the terms and conditions of their employment. Employment with the Company begins only once the employee has accepted and signed the relevant employment documents.

The Letter of Appointment will include key details such as job title, reporting line, salary, benefits, and other employment terms.

2.3.1 Issuance of Employment Contract

Upon joining the Company, employees will be issued a Letter of Appointment for review and acceptance. Employees are required to acknowledge and sign the document as confirmation of their acceptance of the terms of employment.

2.3.2 Confirmation of Employment

New employees are required to undergo a probation period, during which the Company will assess their performance, conduct, and overall suitability for the role.

At the end of the probation period, the Company may:

• Confirm the employee's employment;
• Extend the probation period if further assessment is required; or
• End the employment, depending on the performance and business needs.

Confirmation of employment is not automatic and is subject to satisfactory performance and the Company's discretion.

2.4 Probation Period & Performance Review

H

An employee on first appointment with the Company will be required to undergo a probation as follows : (H : let's review this)

H : During the probationary period, 2 assessments will be done to determine if the employee is performing up to the expectations of the position and if he/she is fit with the culture of the Company. An employee must serve at least serve at least half of the probation period before he/she can be confirmed in the position. The immediate superior should submit the confirmation form one (1) week prior to the end of the probationary period of the employee. This period may be extended for a further period of up to three (3) months at the discretion of the Company. 

During or at the end of the period of probation, employment may be terminated by either party giving to the other party 24 hours notice or salary in lieu thereof without assigning any reason therefor.

An employee shall not be deemed to be confirmed in his/her position until receiving a formal confirmation letter from the Company. Any increment upon confirmation is subject to the discretion of Management and should not be treated as an entitlement.

P

All new employees are required to undergo a probation period at the beginning of their employment. The standard probation period is between 3 to 6 months, depending on the role and as stated in the Letter of Appointment.

During the probation period, the Company will assess the employee's performance, conduct, and suitability for the role.

During probation, employees will go through structured onboarding and performance check-ins, which may take place at approximately 30 days, 60 days, and 90 days after the joining date, or as required by the Company. These check-ins are intended to support employee integration and provide feedback for improvement.

An employee may be confirmed at any time during or upon completion of the probation period, subject to satisfactory performance and the Company's discretion.

The Company may also decide to:

• Extend the probation period for further evaluation (up to a maximum period of 3 to 6 months as determined by the Company); or
• End the employment if the employee is not suitable for the role.

If necessary, the probation period may be extended for further assessment. Any extension will be communicated in writing.

During the probation period, either the Company or the employee may terminate the employment by providing 24 hours' notice in writing or payment in lieu of notice, unless otherwise stated in the Letter of Appointment.

2.5 Transfers, Secondment & Job Rotation

The Company may, at its discretion, transfer, second, or assign employees to different roles, departments, or business units based on operational needs, business requirements, or employee development purposes.

Transfers
A transfer refers to a permanent or long-term movement of an employee from one role, department, or business unit to another within the Company or Group. Transfers may involve changes in reporting lines, job scope, or place of work.

Secondment
A secondment refers to a temporary assignment of an employee to another department, company, or business unit within the Group or to an external organisation for business or structural needs. During the secondment period, the employee remains under the employment of the Company unless otherwise stated.

Job Rotation
Job rotation refers to the temporary movement of an employee across different roles or functions within the Company for development, exposure, or operational purposes.

All transfers, secondments, and job rotations will be communicated to employees in advance where possible and will take into consideration business needs and employee suitability.

2.6 Promotion & Career Development

H

Promotions shall be at the absolute of the Management and shall be based on the performance and ability of the employee, availability of the position, prevailing economic conditions with at least two (2) years of experience in current position/level and or other criteria determined by the Company. 
Q : Do we put probationary period for this? 3 months or so?

P

The Company supports employee growth and development. Promotion opportunities may be provided based on business needs, employee performance, and readiness for increased responsibilities. Promotion is not automatic and will be considered at the Company's discretion.

Employees may also be given opportunities for career development through training, job rotation, expanded responsibilities, or participation in special projects, where applicable.

Any promotion, change in job title, or adjustments in salary will be communicated in writing and subject to management approval. The Company does not guarantee promotion within a specific timeline.

Employees are encouraged to take ownership of their development and demonstrate initiative and alignment with the Company's values.

2.7 Place of Work & Flexible Work Arrangements

2.7.1 Primary Work Location

The employee's primary place of work is the location stated in their Letter of Appointment. However, the Company reserves the right to transfer, assign, or second any employee to any other department, branch, or location within the Company or Group based on operational requirements.

2.7.2 Hybrid Work

Employees may be allowed to work remotely on a hybrid basis, subject to operational needs and approval from the respective Head Of Department (HOD).

Hybrid work arrangements must meet the following conditions:

• It does not interfere with operational requirements or team collaboration;
• Prior verbal or written agreement is obtained from the HOD; and
• The employee remains reachable and productive during standard working hours.

The Company and HODs reserve the right to require physical attendance at the office for meetings, training, or specific business needs.

2.7.3 Flexible Work Arrangements (FWA)

In accordance with the Employment Act 1955, employees may apply for flexible working arrangements to vary their working hours, workdays, or place of work.

Application Process
Any request for FWA must be submitted in writing to the HOD and HR, stating the proposed arrangement and the effective date.

Company Review
The Company will review each request based on operational requirements, job responsibilities, and impact on team productivity. A decision will be communicated in writing within 60 days from the date of application.

Discretion of Management
While all requests will be considered fairly, approval of FWA is subject to Management discretion. If a request is declined, the Company will provide the reason for the decision in writing.

2.8 Changes to Employment Terms

The Company reserves the right to make reasonable changes to an employee's job scope, responsibilities, reporting line, or work arrangements based on business and operational responsibilities. 

Where practicable, the Company will discuss such changes with the employee in advance to ensure clarity and alignment.

Any significant changes to the employment terms, including job title, salary, or benefits, will be communicated to the employee in writing and, where required, subject to mutual agreement.

Employees are expected to cooperate with reasonable changes in duties and responsibilities consistent with their role, experience, and capabilities.

3. Working Time & Attendance

3.1 Normal Working Hours

3.1.1 General Principle

Normal working hours shall not exceed 8 hours per day and 45 hours per week, excluding meal breaks, in accordance with the Employment Act 1955.

Employees shall not work more than 5 consecutive hours without being provided a minimum break of 30 minutes.

The total daily working period, inclusive of breaks (spread over period), shall not exceed 10 hours per day unless otherwise permitted under the law.

3.1.2 Operational Flexibility

Due to the nature of the Company’s business, employees may be required to work:

• Irregular hours
• Extended hours
• Weekends or public holidays
• Split shifts
• Outstation assignments

These situations may occur during events, trainings, or operational peak periods. Working hours during such periods may differ from the official working hours stated.

3.1.3 Official Working Hours (Administrative Days)

The official working hours are as follows:

Monday to Friday: 8:30am to 6:00pm
Lunch Break: 1:00pm to 2:00pm
Friday Lunch Break (for Muslim Employees): 12:30pm to 2:30pm

The Management reserves the right to vary working hours depending on operational requirements.

3.2 Break Time

Employees are entitled to a lunch break of 1 hour per working day. The timing of the break will be arranged based on operational needs and departmental scheduling.

Employees are expected to manage their break time responsibly and ensure that work responsibilities are not affected during working hours.

From time to time, the Company may extend break periods for special occasions or internal events, such as employee welcome sessions, birthdays, or team activities. These extended breaks are provided at the Company's discretion and do not form part of standard working arrangements.

3.3 Rest Days & Off Days

3.3.1 Definition of Rest Days & Off Days

3.3.2 Off Days Recognized by the Company

The Company's Rest Day is Sunday. 

To support business operations

3.3.3 Work on Rest Days & Off Days (EA Employees Only)

For employees covered under the Employment Act 1955:

Rest Day Work
Compensation for work performed on a Rest Day shall be in accordance with the Employment Act 1955:

• Up to half normal working hours: 0.5 day’s wages at the ordinary rate
• More than half but not exceeding normal working hours: 1 day’s wages at the ordinary rate
• Any hours worked beyond normal working hours: Subject to overtime payment in accordance with Section 3.5: Overtime Policy.

Rest day pay is NOT calculated the same way as normal overtime. 

Off Day Work
If an employee is required to work on an Off Day (a non-scheduled working day):

• Within normal daily hours as defined in Section 3.1: No additional pay (included in monthly salary). Employees may apply for replacement leave at the discretion of the employer.
• Work beyond normal daily hours: Overtime pay applies in accordance with Section 3.5: Overtime Policy.

3.3.4 Work on Rest Days / Off Days (Non-EA Employees)

For employees not covered under the Employment Act, compensation for work performed on rest days or off days shall be determined by the Letter of Appointment or as approved by the Company.

This may include:

• replacement leave, or
• other compensation as stated in the Employment Contract

3.4 Public Holidays

3.4.1 General Policies

The Company observes 14 paid public holidays per calendar year for all employees.

Employees covered under Part XII of the Employment Act 1955 shall be entitled to a minimum of 11 paid public holidays in accordance with statutory requirements.

5 of the public holidays are fixed as follows:

• National Day
• Birthday of the Yang di-Pertuan Agong
• Labour's Day
• Malaysia Day
• State Ruler’s Birthday / Federal Territory Day (as applicable)

The remaining public holidays will be determined by the Company and communicated at the beginning of each calendar year.

Where a public holiday falls on a Rest Day or another public holiday, a replacement day will be granted in accordance with applicable law.

Where a public holiday falls during an approved sick leave or annual leave, that day is treated as a public holiday and not deducted from the employee's leave balance. 

3.4.2 Work on Public Holidays (EA Employees Only)

For employees covered under the Employment Act 1955, compensation for work performed on a Public Day shall be in accordance with the Employment Act 1955:

• Work performed within normal working hours: 2 days' wages at the ordinary rate of pay
• Any hours worked beyond normal working hours: Subject to overtime payment in accordance with Section 3.5: Overtime Policy.

For monthly-rated employees, public holiday pay is deemed to be included in the monthly salary.

3.4.3 Work on Public Holidays (Non-EA Employees)

For employees not covered under the Employment Act, compensation for work performed on rest days or off days shall be determined by the Letter of Appointment or as approved by the Company.

This may include:

• replacement leave, or
• other compensation as stated in the Employment Contract

Where applicable, any travelling allowance payable under the employee’s contract shall remain payable. No additional housing or meal allowance shall be payable unless otherwise provided in the contract.

Q : Do we need to clarify on travelling on PH for work- related?

3.5 Overtime Policy

3.5.1 Definition of Overtime

Overtime refers to work performed beyond the employee's normal working hours as stated in Section 3.1: Normal Working Hours. All overtime must be approved in advance by the employee's HOD.

3.5.2 Applicability

Overtime compensation shall apply to employees covered under the Employment Act 1955 (EA Employees).

For employees not covered under the Employment Act (Non-EA Employees), any work beyond normal working hours shall be governed by the terms of the Employment Contract and may be deemed included in the employee's remuneration unless otherwise agreed.

3.5.3 Overtime Rates (EA Employees Only)

Overtime for employees covered under the Employment Act 1955 shall be compensated as follows:

3.5.4 Overtime Limit

Total overtime worked shall not exceed 104 hours in any 1 month, unless otherwise permitted under applicable law.

Employees shall not be required to work more than 12 hours in any 1 day, except in circumstances permitted under the Employment Act 1955 (e.g. emergencies or urgent operational necessity).

3.2.5 Overtime Claims

All overtime must be approved in advance by the employee's immediate supervisor.

Employees are required to record and submit overtime claims through the Company's designated system or process within the stipulated timeline.

Overtime claims must include:

• date of overtime worked
• duration of overtime
• reason for overtime
• approval from immediate supervisor

Late submissions or overtime worked without prior approval may not be recognised for payment, unless otherwise approved by Management.

3.2.6 Management Rights

The Company reserves the right to revise, limit, or discontinue overtime arrangements based on operational needs and legal provisions.

3.2.7 Overtime Calculation Example

If an employee earns RM 3,000 per month:

• Hourly rate = RM3,000 ÷ 26 days ÷ 8 hours
  = RM3,000 ÷ 208 hours
  = RM14.42 per hour
  
  
• Overtime rate (Normal Working Day)
  = RM14.42 × 1.5
  = RM21.63 per hour

 
3.6 Attendance Recording

Employees are required to comply with the Company's attendance and reporting requirements based on their role and work arrangement.

• Operational Employees (e.g. factory, warehouse)
  Employees in operational roles are required to accurately record their attendance using the Company's designated system. Attendance must be recorded at the start and end of each working day, and all records must be accurate and truthful.
  
  
• Non-Operational Employees (e.g. office-based roles)
  Employees who are not required to use a formal attendance system are expected to maintain regular communication with their immediate superior regarding their work location and availability, including:
• • working from home arrangements
  • leave or absence from work
  • changes to working hours where applicable

Employees must inform their immediate superior in advance or as soon as reasonably practicable if they are unable to report to work or will be unavailable during working hours. Employees are expected to remain contactable and responsive during normal working hours unless otherwise approved.

Failure to properly record attendance (where applicable), failure to inform, prolonged uncontactability, or misrepresentation of attendance may result in disciplinary action.

3.7 Lateness, Early Departure & Absenteeism

Employees are expected to observe their assigned working hours and maintain regular attendance in accordance with Company requirements.

3.7.1 Lateness

Lateness refers to reporting for work after the scheduled start time without prior approval or valid reason.

Employees who anticipate being late must inform their immediate superior as soon as reasonably practicable.

Repeated or excessive lateness may be subject to disciplinary action.

3.7.2 Early Departure

Early departure refers to leaving work before the scheduled end of working hours without prior approval.

Employees must obtain approval from their immediate superior before leaving early, unless due to unforeseen circumstances.

Frequent or unauthorised early departures may result in disciplinary action.

3.7.3 Absenteeism

Absenteeism refers to failure to report for work without prior approval or without informing the Company.

Employees must notify their immediate superior as soon as reasonably practicable if they are unable to attend work, stating the reason for absence.

Unauthorised absence, prolonged uncontactability, or failure to provide reasonable explanation may result in disciplinary action.

Absence from work for more than 2 consecutive working days without leave or reasonable excuse, and without informing the Company, may be treated as misconduct and may lead to further action in accordance with Company policy and applicable laws.

4. Wages & Salary Administration

4.1 Salary Structure & Payment Cycle

4.1.1 Payment Terms & Methods

• Wage Period: The standard wage period is 1 calendar month.
• Payment Date: Wages will be paid no later than the 7th day of the following month.
• Payment Method: All salary payments are made via electronic bank transfer into the employee’s designated bank account. Any change to payment method is subject to Company approval.
• Statement of Wages (Payslip): A monthly payslip will be issued to every employee detailing basic salary, allowances, overtime, and statutory deductions.

4.1.2 Definitions of Pay

To ensure clarity in calculations, the Company distinguishes between different ‘types’ of pay:

• Basic Salary: The fixed monthly amount stated in the employee’s Letter of Appointment
• Wages: For the purpose of statutory and payroll calculations, "Wages" includes basic salary and fixed contractual cash allowances. It excludes reimbursements, travel claims, bonuses (unless contractually stated as fixed), and gratuities.
• Ordinary Rate of Pay (ORP): The rate used for statutory calculations such as overtime and public holiday pay, as defined in Section 4.1.4. 

4.1.3 Calculation for Incomplete Months (Prorating)

If an employee does not complete a full calendar month of service (e.g., joining mid-month, resignation, or taking unpaid leave), the salary will be prorated based on the number of calendar days in the month.

The Formula:

• Example (Joining in March): If your basic salary is RM 3,000 and you worked 20 days out of the 31 days in March:

4.1.4 Statutory Calculation Rates (Ordinary Rate of Pay)

In compliance with the Employment Act 1955, the Ordinary Rate of Pay (ORP) is used for statutory calculations such as overtime, work on rest days, and public holidays, as applicable.

• Daily ORP: For monthly-rated employees, the daily rate is calculated as:

• Hourly ORP: The Daily ORP divided by normal daily working hours.

4.1.5 Final Payment Upon Separation

Final salary will be paid in accordance with the Employment Act 1955:

• Where employment ends with proper notice (resignation or termination), all outstanding wages will be paid on the last day of employment.
• Where the Company terminates employment without notice, final wages will be paid on the day of termination.
• Where an employee resigns without notice, final wages will be paid within 3 days after the last day of employment.

All payments will include earned wages and approved claims, less any lawful deductions.

4.2 Payslip & Salary Deductions

4.2.1 Monthly Payslip

In accordance with statutory requirements, the Company will provide an itemized payslip to every employee on or before the salary payment date. This payslip will include:

• Gross Salary: Basic salary and fixed monthly allowances.
• Variable Pay: Overtime (where applicable), commissions, or performance bonuses.
• Statutory Deductions: Employee's share of EPF, SOCSO, EIS, and Monthly Tax Deduction (PCB).
• Employer Contributions: Employer's share of EPF, SOCSO, and EIS (where displayed)
• Net Pay: The final amount credited to the employee's bank account.

4.2.2 Statutory Deductions & Rates

The Company is legally required to make deductions for EPF, SOCSO, EIS, and PCB from an employee's wages. These deductions are calculated based on the prevailing rates prescribed by the relevant Malaysian authorities.

Employees may refer to the official websites of KWSP (EPF), PERKESO (SOCSO/EIS), and LHDN (Income Tax) for the latest contribution rates.

4.2.3 Lawful Salary Deductions (Section 24 of the EA 1955)

The Company shall only make deductions from an employee's salary as permitted under Section 24 of the Employment Act 1955 and other applicable laws. These include:

• Recovery of Overpayments: Deductions to recover any salary overpaid due to employer error during the immediately preceding 3 months.
• Payment in Lieu of Notice: Where an employee fails to serve the required notice period as stated in the Letter of Appointment, the Company may deduct an amount equivalent to the unserved notice period, in accordance with Section 24 of the Employment Act 1955.
• Authorized Deductions: Deductions made with the employee's written consent (e.g., staff loans, voluntary EPF top-ups).
• Unpaid Leave: Deductions for absence without pay or leave extending entitlement.

4.2.4 Deduction Limits & Protections

Total salary deductions in a month will generally not exceed 50% of an employee's monthly wages, unless otherwise allowed under the Employment Act 1955 or other applicable laws (such as statutory deductions or final salary payments).

The Company shall not make deductions for damages, loss of property, or similar liabilities unless:

• the employee provides a written consent, or
• such deductions are permitted under Section 24 of the Employment Act 1955 or approved by the Director General of Labour (Jabatan Tenaga Kerja / JTK)
  
  

4.3 Allowances

4.3.1 Overview

Allowances are fixed or recurring payments provided to employees to support work-related responsibilities or employment-related costs. These allowances form part of the employee's remuneration and are subject to applicable statutory deductions (where required by law).

Eligibility, type, and amount of allowances are determined by the Company based on job role, level, or operational requirements.

4.3.2 Types of Allowances

Fixed Allowance
Fixed allowances are recurring monthly payments provided as part of an employee's compensation package.

Examples may include:

Performance-Based Allowance
Performance-based allowances are variable payments linked to individual or team performance outcomes. 

Eligibility is based on:

• Performance targets or key performance indicators (KPIs)
• Evaluation periods defined by the Company
• Performance reviews conducted by management or HR

Employees must meet the required performance criteria (as determined by the Company) to qualify.

4.3.3 Eligibility

Eligibility is determined by the Company and may vary depending on job role, level, employment contract, and operational requirements.

4.4 Incentives

4.4.1 Purpose of Incentives

The purpose of the Incentives programme is to motivate and reward employees for exceptional performance, achievements, or contributions that go beyond normal job responsibilities.

Incentives are designed to encourage performance excellence, align individual efforts with the Company’s business objectives, and support the overall growth and success of the organisation.

Incentives are not allowances or reimbursements. They are variable, non-fixed, and non-guaranteed payments, and are awarded at the Company’s discretion based on performance outcomes, eligibility criteria, and business considerations.

4.4.2 Types of Incentives

The Company may offer various incentive programmes to recognise and reward employee contributions. The availability, structure, eligibility criteria, and payment terms of any Incentive are subject to Company policy, performance outcomes, and business needs.

4.4.3 Eligibility

Eligibility is determined by the Company and may vary depending on incentive type, role requirements, performance criteria, and business needs.

Participation in any incentive programme is not automatic and is subject to management discretion, and applicable terms and conditions.

4.4.4 Calculation and Payment of Incentives

Incentive calculations, eligibility criteria, and payment terms will be determined by the Company and may vary by incentive type, role, and business performance. 

Incentives are discretionary, may be amended, deferred, or withdrawn at the Company’s discretion, and do not form part of fixed remuneration.

4.4.5 Communication and Review Process

Notification
Employees will be informed of applicable incentive programmes, eligibility criteria, and terms through official Company communication channels. Where applicable, details will be shared prior to or at the time the incentive is offered.

Regular Review
All incentive programmes are subject to periodic review to ensure alignment with business objectives and operational needs. The Company reserves the right to amend, suspend, or discontinue any programme where necessary.

Confidentiality
Employees are expected to treat their own and others’ remuneration, including incentives, allowances, and salary-related information, as confidential.

Dispute Resolution
Any concerns regarding incentives should be raised with the immediate supervisor or HR. The Company will review matters fairly and encourages internal resolution before external escalation.

4.5 Reimbursements (Claims)

4.5.1 Overview

Reimbursements refer to refunds of actual work-related expenses incurred by employees during the course of performing official duties.

Reimbursements are not considered wages and are not subject to statutory deductions.

4.5.2 Eligible Expenses

The company may reimburse employees for reasonable and necessary expenses including:

All reimbursements must be supported by valid documentation and subject to approval.

4.5.3 Submission Process

All reimbursement claims must be submitted through BrioHR in accordance with the procedures outlined below:

1. Submission Platform
   All claims must be submitted via BrioHR. Employees are responsible for ensuring that claim details are accurate and complete at the point of submission.
   
   Each employee must submit only ONE (1) claim report per month.
   
   All eligible expenses for the month must be compiled into a single claim report. Employees must not submit separate claim reports for individual expenses and do not create multiple claim reports within the same month.
   
   
2. Supporting Documents
3. 1. Receipts or proof of payment are required for all claims.
   2. Where applicable, employees must obtain and attach the e-invoice issued by seller or service provider.
   3. Mileage claims do not require receipts. Instead, employees must submit the completed mileage record using the company-provided Excel template, converted to PDF, showing:
   4. 1. Point A to B
      2. Distance travelled (in kilometres)
      3. Amount claimed per trip (in RM)
         
         
4. Submission Timeline
5. 1. Claims must be submitted by the 25th of each month for expenses incurred in that month.
   2. Claims must be submitted within the stated timeline to avoid accumulating claims across multiple months, as delayed submissions may impact processing timelines and increase administrative workload for the Finance team.
      
      
6. Responsibility & Compliance
   Employees are responsible for timely submission and compliance with the claim requirements. Incomplete, duplicate, or non-compliant submissions may be rejected or returned for clarification.

4.6 Salary Review & Adjustment

4.6.1 General Principle

The Company conducts periodic reviews of employee salaries to ensure alignment with individual performance, market conditions, job responsibilities, and business performance.

Salary reviews do not automatically result in salary adjustments.

4.6.2 Review Cycle

Salary reviews are generally conducted on a periodic basis (e.g. annually or during performance review cycles), or when there is a change in role, responsibilities, or other business needs. 

The timing and frequency of salary reviews are determined by the Company and may vary.

4.6.3 Basis for Salary Adjustment

Salary adjustments, if any, may be based on:

• Individual performance and contribution
• Company and departmental performance
• Market benchmarking and industry standards
• Changes in job scope or responsibilities
• Internal pay fairness between employees in similar roles or job levels

4.6.4 Types of Adjustments

Salary adjustments may include:

• Annual merit increment
• Promotion-related salary revision
• Market adjustment
• Reclassification due to role changes

4.6.5 Discretion of the Company

Salary adjustments are not guaranteed and are subject to Company discretion, performance outcomes, and business considerations.

Nothing in this policy guarantees annual salary increments or fixed percentage increases.

4.7 Statutory Contributions (EPF, SOCSO, EIS, PCB)

4.7.1 General Overview

In accordance with Malaysian laws and regulations, the Company is required to make statutory contributions and deductions for all eligible employees.

These include:

• Employees Provident Fund (EPF)
• Social Security Organization (SOCSO)
• Employment Insurance System (EIS)
• Monthly Tax Deduction (PCB).

 Both employer and employee contributions (where applicable) will be made in accordance with the prevailing statutory rates set by the relevant authorities.

4.7.2 Employees Provident Fund (EPF)

EPF is a mandatory retirement savings scheme for employees.

Both the Company and employees are required to contribute a percentage of the employee's wages in accordance with the rates prescribed by the Employees Provident Fund Malaysia.

Contribution rates and eligibility are subject to prevailing regulations.

4.7.3 Social Security Organisation (SOCSO)

SOCSO provides protection against employment injuries, occupational diseases, and invalidity.

Contributions are made in accordance with the requirements set by Social Security Organisation Malaysia (Contribution Rate of Act 4), based on the employee's wages and applicable contribution category.

4.7.4 Employment Insurance Scheme (EIS)

EIS provides financial assistance and support for employees in the event of job loss.

Both employer and employee contributions are required in accordance with the regulations administered by Social Security Organisation Malaysia (Contribution Rate of Act 800).

4.7.5 Monthly Tax Deduction (PCB)

The Company will deduct monthly income tax (PCB) from employee's salary in accordance with the requirements of the Inland Revenue Board of Malaysia.

The amount deducted is based on the employee's taxable income and prevailing tax regulations.

5. Leave Entitlement

5.1 Annual Leave

5.1.1 Annual Leave Entitlement

Employees are entitled to paid annual leave according to the Company’s leave schedule as follow:

Employees who have not completed a full year of service will receive annual leave on a pro-rated basis, calculated based on completed months of service within the year.

For example, if the annual entitlement is 12 days per year, an employee earns 1 day of leave for each completed month of service.

5.1.3 Application & Approval

Annual leave must be applied for in advance and is subject to approval by the Company based on operational requirements.

Employees are required to provide reasonable notice when applying for leave. The Company reserves the right to approve, defer, or decline leave applications where necessary.

5.1.4 Leave Expiry & Carry Forward

Unused annual leave may be carried forward to the following year, subject to a maximum of 5 days.

All carried forward leave must be utilised by 1 April of the following year, failing which the unused balance will be forfeited.

Any additional unused leave beyond the carry forward limit will be forfeited at the end of the leave entitlement year, unless otherwise approved by the Company.

5.1.5 Leave During Sick or Maternity Leave

If an employee is on approved annual leave but becomes eligible for sick leave or maternity leave during that period, the relevant leave will take priority, and the annual leave will be reinstated for future use.

5.1.6 Leave on Termination

Upon termination of employment, any earned but unused annual leave will be paid to the employee based on the ordinary rate of pay.

5.2 Sick Leave & Hospitalisation Leave

5.2.1 Sick Leave Entitlement

Employees are entitled to paid sick leave based on length of service:

This entitlement is in accordance with the Employment Act 1955, where applicable.

Employees are entitled to paid sick leave of up to 60 days per year if hospitalisation is required, inclusive of ordinary sick leave entitlement.

If a registered medical practitioner certifies that hospitalisation is necessary, such leave will be treated as hospitalisation leave, regardless of whether the employee is actually admitted to a hospital.

5.2.2 Certification & Notification

Sick leave must be certified by a registered medical practitioner, medical officer, or dental surgeon.

Employees must inform or attempt to inform the Company within 48 hours from the start of sick leave. Failure to do so may result in the leave being treated as absence without leave. 

5.2.3 Sick Leave Pay

Sick leave is paid at the employee's ordinary rate of pay. For monthly-rated employees, sick leave pay is deemed included in the monthly salary.

5.2.4 Sick Leave During Other Benefits

Sick leave pay shall not be payable for periods during which the employee is receiving maternity allowance or statutory disablement benefits, as provided under applicable laws.

5.3 Maternity Leave

5.3.1 Maternity Leave Entitlement

Every female employee is entitled to:

• Maternity leave of 98 consecutive days for each childbirth.
• Maternity allowance (payment in lieu of wages) for up to a maximum of 5 surviving children, subject to statutory eligibility requirements.

Exception:

• If the employee has 5 or more surviving children at the time of childbirth, she is entitled to maternity leave, but maternity allowance will not be payable.
  
  

5.3.2 Eligibility for Maternity Allowance

To receive maternity allowance, the employee must:

• Have worked for the Company for at least 90 days in total during the 9 months before childbirth, and
• Have been employed by the Company at any time in the last 4 months before childbirth.

Example:

If the expected delivery date is 31 December:

• The employee worked 1 April – 30 June (90 days in total) → ✅ meets the first rule
• The employee also worked at least 1 day between 1 September – 31 December → ✅ meets the recent employment rule

Both conditions must be met to qualify for maternity allowance.

5.3.3 Maternity Leave Pay

Maternity allowance shall be paid at the employee's ordinary rate of pay.

Employees paid monthly will continue to receive their usual monthly salary during maternity leave. No deductions are made for leave days.

An employee who works for more than one employer shall not receive maternity allowance exceeding the amount payable by one employer.

5.3.4 Commencement of Maternity Leave

Maternity leave may commence no earlier than 30 days before childbirth and no later than the day following childbirth.

If a registered medical practitioner certifies that the employee is unable to perform her duties due to advanced pregnancy, the Company may require maternity leave to commence up to 14 days earlier than the standard 30-day period (i.e. up to 44 days before childbirth).

Any absence from work before the permitted commencement period without medical certification shall not be treated as maternity leave, and no maternity allowance will be payable for such period.

5.3.5 Returning to Work During Maternity Leave

An employee may return to work during maternity leave with the Company's consent and upon certification by a registered medical practitioner that she is fit to resume work.

This applies regardless of eligibility for maternity allowance.

5.3.6 Job Protection During and After Pregnancy

The Company shall not terminate or give notice of termination to an employee on the grounds of pregnancy or illness arising from pregnancy.

Termination during maternity leave is not permitted except for reasons unrelated to pregnancy, such as misconduct, redundancy, or closure of business, and must be in accordance with applicable laws.

Where the employee is certified by a registered medical practitioner to be unfit for work due to a pregnancy- or childbirth-related condition, the Company shall not terminate her employment for a period of up to 90 days after the end of maternity leave, except in circumstances permitted by law.

5.3.7 Maternity Allowance – Special Payment Arrangements

Nomination of Recipient
The employee may nominate another person to receive maternity allowance on her behalf.

Any payment made to the nominated person will be treated as payment made to the employee.

Maternity Allowance in the Event of Death
In the unfortunate event that the employee dies during her maternity leave, any maternity allowance due will be paid to the person she nominated or, if no nominee exists, to her legal representative.

5.3.8 Notification Requirements for Maternity Allowance

The employee must notify the Company of her pregnancy and the intended start date of maternity leave at least 60 days before expected delivery.

If the employee is about to leave employment and knows she may give birth within 4 months, she must notify the Company before leaving to remain eligible for maternity allowance.

If the employer provides free medical treatment, the employee is expected to attend necessary medical check-ups. Failure to do so may result in a deduction of up to 7 days of maternity allowance.

Notice can be given in writing or orally, including to a supervisor or person designated by the employer.

Minor errors or delays in notice do not automatically affect eligibility, especially if the employee had a reasonable cause.

Nothing in this policy shall reduce or remove any statutory maternity rights provided under the Employment Act. Where there is any inconsistency, the Employment Act shall prevail.

5.4 Paternity Leave

5.4.1 Entitlement

Male employees are entitled to 7 consecutive days of paid paternity leave for each confinement, up to a maximum of 5 confinements, regardless of the number of spouses.

This entitlement is provided in accordance with the Employment Act 1955.

5.4.2 Eligibility

To qualify for paternity leave, the employee must:

• Be legally married
• Have been employed by the Company for at least 12 months immediately before the commencement of paternity leave
• Notify the Company of the spouse's pregnancy at least 30 days before the expected confinement, or as soon as reasonably practicable after the birth

5.4.3 Conditions of Leave

• Paternity leave must be taken consecutively
• The leave period includes rest days, off days, and public holidays
• The employee may be required to provide supporting documentation (e.g. birth certificate or medical confirmation)

Any request to defer or adjust the commencement of paternity leave is subject to Company approval.

5.5 Compassionate Leave

5.5.1 Entitlement

The Company may grant compassionate leave in the event of the death of an immediate family member.

Eligible relationships include:

• Spouse
• Parents (including parents-in-law)
• Children (including legally adopted children)
• Siblings
• Grandparents

Employees are entitled to 3 consecutive days of compassionate leave per occasion.

There is no minimum service requirement for this entitlement.

5.5.2 Other Compassionate Circumstances

Compassionate leave may also be granted in the following situations:

• Natural disasters affecting the employee's residence (e.g. fire, flood, landslide, etc.): up to 3 consecutive days.
• Stillbirth, as certified by a registered medical practitioner: up to 15 consecutive days, or such extended period as approved by the Company 

5.5.3 Supporting Documents

Employees may be required to provide supporting documents (e.g. death certificate, medical certification, or official reports) where applicable.

5.5.4 Additional Support

The Company may, at its discretion, provide financial assistance or contributions to employees affected by bereavement or emergencies.

The company will also give a donation of RM500 to the affected employee. If an employee is found to have obtained compassionate leave through fraudulent information, disciplinary action will be taken.

5.6 Emergency Leave

5.6.1 General Policy

Employees may be granted emergency leave for unforeseen and urgent personal matters requiring immediate attention.

5.6.2 Conditions

• Emergency leave is not a separate leave entitlement
• It will be deducted from the employee's annual leave balance
• Approval is subject to Company discretion

5.6.3 Notification & Documentation

Employees must inform the Company as soon as reasonably practicable.

Upon returning to work, employees may be required to:

• submit supporting documentation
• submit the leave application in the system upon returning to work

Failure to provide reasonable justification may result in the absence being treated as unauthorised leave.

5.7 Unpaid Leave

H : No pay leave may be granted at the sole discretion of the Management. It is granted to an employee only when he/she has fully utilised his/her annual leave and there is a valid and urgent reason to apply such leave. Employees applying for no pay leave are reminded to do so at least three (3) days in advance.

It is also the employee’s responsibility to check the status and ensure the leave application is approved before going on leave. During the period of no pay leave, all employment entitlements and benefits are suspended.

Employees on the probationary period who are not able to utilise their annual leave yet may be allowed to apply for no pay leave at the discretion of the Management.

5.7.1 General Policy

Unpaid leave may be granted at the discretion of the Company for valid and reasonable reasons.

Employees are generally expected to utilise their available annual leave before applying for unpaid leave, unless otherwise approved by the Company.

5.7.2 Application & Approval

Employees should apply for unpaid leave in advance where practicable and obtain approval prior to going on leave.

It is the employee's responsibility to ensure that the leave application has been approved before proceeding on unpaid leave.

5.7.3 Effect on Salary & Benefits

During periods of unpaid leave:

• No salary will be paid for the approved leave period
• Statutory contributions (e.g. EPF, SOCSO, EIS) will be adjusted based on actual wages paid
• Certain benefits may be affected, subject to Company policy and applicable laws

5.7.4 When to Apply for Unpaid Leave

Unpaid leave may be considered in situations such as:

• When employee has fully utilised their annual leave entitlement
• When extended time off is required beyond available annual leave
• For personal or urgent matters where the employee prefers to reserve their annual leave, subject to approval
• When the employee is not yet eligible for annual leave (e.g. during probation)

All unpaid leaves applications are subject to Company approval based on operational requirements.

5.8 Study / Exam Leave & Sabbatical Leave (if applicable)

5.8.1 General Policy

The Company may grant extended leave for purposes such as further studies, examinations, personal development, or other personal reasons, subject to management approval.

5.8.2 Study / Exam Leave

Short-term leave for examinations or study purposes may be granted at the discretion of the Company.

Unless otherwise approved, study / exam leave will be treated as unpaid leave and will subject to the same conditions outlined under Section 5.7: Unpaid Leave.

Employees may be required to provide supporting documents (e.g. exam schedule, course details) when applying.

5.8.3 Sabbatical Leave

Leave of 1 month or more will generally be considered as sabbatical leave.

Sabbatical leave may be granted at the discretion of the Company, based on:

• the reason for the request
• the employee's length of service and performance
• operational requirements

5.8.4 Terms of Sabbatical Leave

During sabbatical leave:

• No salary will be paid
• Statutory contributions will be adjusted based on actual wages paid
• Certain benefits may be affected, subject to Company policy

The employment relationship remains in effect unless otherwise stated in writing.

5.8.5 Return to Work

Employees are expected to return to work upon completion of the approved leave period.

The Company will make reasonable efforts to place the employee in their previous or a comparable role, subject to operational requirements.

5.9 Replacement Leave (if applicable)

5.9.1 General Policy

Replacement leave may be granted to employees who are required to work on a rest day, off day, or public holiday, subject to Company approval.

Replacement leave is provided at the discretion of the Company and based on operational requirements.

5.9.2 Eligibility

• For employees covered under the Employment Act 1955, compensation for work on rest days and holidays will follow statutory provisions. Replacement leave may be granted only where permitted by law or approved by the Company.
• For employees not covered under the Employment Act, replacement leave may be granted in lieu of additional compensation, subject to the terms of the employment contract or management approval.

5.9.3 Granting of Replacement Leave

Where replacement leave is approved:

• The Company will determine the number of replacement leave days granted
• Replacement leave must be taken within a specified period determined by the Company
• Scheduling of replacement leave is subject to operational needs and approval

5.9.4 Expiry of Replacement Leave

Replacement leave must be utilised within the period specified by the Company, failing which it may be forfeited unless otherwise approved.

5.9.5 Application & Granting Process

Replacement leave may be granted through the following processes:

• Company-Assigned Replacement Leave
  For Company-organised events or activities (e.g. events, projects, or assignments requiring work on rest days, off days, or public holidays), replacement leave may be assigned by HR upon management approval. Employees will be informed accordingly.
• Employee-Initiated Application
  In other cases, employees may apply for replacement leave through the HRMS. Such applications must be supported by the relevant work performed and are subject to approval by the employee's immediate supervisor and/or Management.

All replacement leave must be properly recorded in the system and approved before it is taken.

5.10 Marriage Leave (if applicable)

5.10.1 Entitlement

Employees are entitled to 3 consecutive days of paid marriage leave for their first legal marriage only.

Marriage leave must be taken in connection with the employee's official marriage.

5.10.2 Eligibility

Marriage leave is granted only once during the employee's service with the Company and applies to the employee's first legally recognised marriage in their lifetime.

Employees who are already legally married prior to joining the Company will not be eligible for marriage leave.

5.10.3 Application & Notification

Employees are required to apply for marriage leave in advance and inform the Company of their intended leave dates prior to the wedding.

Advance notice is required to allow for workforce planning and approval.

5.10.4 Supporting Documents

Employees may be required to provide supporting documents (e.g. marriage certificate or official registration documents) to verify eligibility.

5.10.5 Conditions

• Marriage leave must be taken as consecutive days, within a reasonable period in relation to the date of marriage, unless otherwise approved.
• Leave is subject to approval based on operational requirements

5.11 Leave Application & Approval Process

All leave applications must be submitted through the Company's HR system and are subject to approval by the relevant supervisor and/or Management.

Employees must obtain approval before taking leave, except in cases of emergency or sudden illness, where notification must be made as soon as reasonably practicable.

Failure to obtain approval or provide notification may result in the absence being treated as unauthorised leave and may lead to disciplinary action.

Where required, employees must provide supporting documentation to substantiate the leave application.

The Company reserves the right to approve, reject, deter, or adjust leave applications based on operational requirements. The Company will make reasonable efforts to ensure employees are able to utilise their leave entitlement within the applicable period.

6. Employee Benefits

6.1 Clinical Visit Benefit

6.1.1 Outpatient Medical Benefit

The Company provides outpatient medical reimbursement benefits for eligible employees for consultation and treatment by registered medical practitioners.

This benefit is intended for reasonable outpatient medical expenses and is subject to the annual limit determined by the Company.

The annual entitlement will be prorated for employees who join partway through the calendar year.

6.1.2 Claim Requirements

Employees must submit:

• original receipt or invoice
• supporting medical documents where applicable

Claims must be submitted through the Company's approved claim process.

6.1.3 Payment & Limitations

Approved claims will be reimbursed through the monthly payroll cycle.

Any medical expenses exceeding the approved annual limit shall be borne by the employee.

For part-time or contract employees, medical benefits (if any) shall be governed by the terms stated in the applicable employment contract.

6.2 Group Personal Accident (GPA)

6.2.1 Coverage Overview

Eligible employees are covered under the Company's Group Personal Accident (GPA) Insurance on a 24-hour basis for accidental death or accidental disability (whether temporary or permanent), subject to the terms and conditions of the applicable insurance policy.

6.2.2 Age Limit

Employees are generally covered under the GPA Insurance up to the age of 64 years old.

Coverage may be extended up to 70 years old if the employee remains in active employment and subject to the insurer's terms and approval.

6.2.3 Part-Time, Contract, Temporary Employees

For part-time, contract, or temporary employees, GPA coverage (if applicable) shall be governed by the terms stated in the relevant employment contract or insurance arrangement.

6.3 Group Hospitalisation & Surgical (GHS)

6.3.1 Coverage Overview

Eligible employees are covered under the Company's Group Hospitalisation & Surgical (GHS) Insurance for hospitalisation and surgical expenses arising from illness, disease, or accidental injury, subject to the terms and conditions of the applicable insurance policy.

Coverage is provided on a 24-hour basis upon confirmation of employment.

The coverage may extend to both domestic and overseas business-related travel, subject to the insurer's terms and conditions, provided that the overseas travel period does not exceed 90 consecutive days.

6.3.2 Eligibility & Dependants

This benefit applies to eligible employees only and does not extend to spouses, children, or dependants unless otherwise stated by the Company or insurer.

6.3.3 Age Limit

Employees are generally covered under the GHS Insurance up to the age of 64 years old.

Coverage may be extended up to 70 years old if the employee remains in active employment and subject to the insurer’s terms and approval.

6.3.4 Part-Time, Contract, Temporary Employees

For part-time, contract, or temporary employees, GHS coverage (if applicable) shall be governed by the terms stated in the relevant employment contract or insurance arrangement.

6.4 Staff Purchase & Company Privileges

6.4.1 General Policy

The Company may provide employees with access to staff purchase schemes and/or company privileges, which may include but are not limited to product discounts, training access, or other internal programmes.

These privileges are offered at the Company's discretion and may vary depending on business arrangements, role requirements, and availability.

6.4.2 Types of Privileges

Staff Purchase Discounts
Employees may be eligible for discounted purchase of selected products (e.g. furniture or other Company-related goods) under arrangements with the Kian Group or affiliated entities, subject to availability and approval.

Training & Development Privileges
Employees may be granted free or subsidised access to selected training programmes, workshops, or events organised by the Company, subject to operational requirements and management approval.

6.4.3 Eligibility

Eligibility for staff purchase schemes and company privileges applies to ???

Eligibility for vary depending on the type of privilege and will be determined by the Company.

6.4.4 Conditions of Use

All staff purchase schemes and company privileges are subject to the following conditions:

• Strictly non-transferable and for employee use only
• Not for resale or commercial use
• Subject to availability and approval by the Company and/or relevant management
• May require supporting approval or authorisation prior to use

6.5 Wellness & Employee Assistance Programme (if applicable)

6.5.1 General Policy

The Company is committed to supporting employees' overall well-being, including physical, mental, and emotional health.

Wellness initiatives and support channels are provided as part of the Company's employee culture and may evolve over time based on organisational needs and available resources.

These initiatives do not form part of contractual remuneration or guaranteed benefits and may be amended or discontinued at the Company's discretion.

6.5.2 Wellness Initiatives (SPARK & Seeds of Change)

The Company organises internal wellness and engagement activities under its SPARK initiative, which reflects the Company's core values.

Activities may include, but are not limited to:

• Regular sport and physical activities (e.g. weekly badminton sessions)
• Internal competitions and team engagement events (e.g. chess competitions, sports day)
• Other recreational or team-building activities organised from time to time

In addition, the Company may organise wellness-focused programmes under Seeds of Change (SOC), which aim to support employee's mental, physical, and emotional well-being. These may include activities such as:

• Mindfulness or meditation sessions
• Physical wellness activities (e.g. yoga, taichi)
• Mental health talks or wellness sharing sessions
• Other well-being related initiatives

Participation in these programmes is voluntary unless otherwise stated.

6.5.3 Employee Assistance & Support Channels

The Company provides multiple channels for employees seeking support for work-related or personal concerns:

People Care Channel (Confidential Support Email)
Employees may reach out via a confidential email channel (peoplecare@kian.com), which is accessible only to designated HR and senior leadership representatives.

All matters raised through this channel will be handled with discretion and confidentiality, where possible, in accordance with Company policies and applicable law.

Heart Rangers (Peer Support Group)
The Company may also establish a voluntary peer support group known as "Heart Rangers", where employees can seek informal support or guidance from trained internal volunteers.

Heart Rangers are not professional counsellors, but serve as a first point of contact for employees who may need someone to talk to or require direction to appropriate support.

6.5.4 Limitations of Support

While the Company strives to provide a supportive environment, these programmes and channels:

• Do not replace professional medical, psychological, or legal services
• Do not guarantee specific outcomes or interventions
• Are subject to availability of resources and internal capacity

Employees are encouraged to seek professional help externally where appropriate.

6.6 General Benefits Disclaimer & Company Rights

The Company reserves the right to amend, revise, suspend, replace, or discontinue any employee benefit, insurance coverage, or privilege at any time, with or without prior notice, subject to operational, business, or regulatory requirements.

Where practicable, employees will be informed of material changes affecting their entitlements.

7. Code of Conduct & Ethics

The Company expects all employees to uphold high standards of professionalism, integrity, ethical conduct, and responsibility in all aspects of work.

Employees must act honestly, responsibly, and in accordance with applicable laws, Company policies, and professional standards when performing duties or representing the Company.

This section sets out general expectations of conduct. Employees may also be required to comply with additional internal policies, guidelines, or procedures issued by the Company from time to time, including the Company's Code of Business Conduct & Ethics Policy (where applicable).

7.1 Professional Behaviour & Integrity

7.1.1 General Standard of Conduct

Employees are expected to conduct themselves in a professional, respectful, honest, and responsible manner at all times while carrying out their duties or representing the Company, whether internally or externally.

Employees must act in good faith, exercise integrity in their work, and comply with all applicable laws, Company policies, procedures, and lawful instructions issued by the Company.

Failure to comply with Company policies or expected standards of conduct may result in disciplinary action, up to and including termination of employment, subject to applicable laws and Company procedures.

7.1.2 Workplace Behaviour

Employees are expected to maintain a positive and respectful working environment. This includes:

• treating colleagues, clients, vendors, and other stakeholders with courtesy and professionalism
• maintaining appropriate workplace conduct and communication
• cooperating with colleagues and management in the course of work
• avoiding behaviour that may disrupt workplace harmony, safety, or productivity

The Company does not tolerate behaviour that is abusive, threatening, discriminatory, harassing, dishonest, or otherwise inappropriate in the workplace.

7.1.3 Integrity & Ethical Conduct

Employees must uphold high standards of integrity and ethical conduct in all work-related matters.

Employees must not:

• engage in fraud, dishonesty, or misrepresentation
• falsify records, claims, attendance, or Company documents
• misuse Company resources, authority, or confidential information
• engage in conduct that may damage the reputation or interests of the Company

Employees are expected to immediately report any suspected misconduct, unethical behaviour, or breach of Company policy through the appropriate reporting channels.

7.2 Conflict of Interest

7.2.1 General Principle

Employees are expected to act in the best interests of the Company and must avoid situations where personal interests, relationships, or external activities may conflict, or appear to conflict, with the interests of the Company.

A conflict of interest may arise where an employee's personal, financial, family, or business interests interfere with the employee's ability to perform their duties objectively, fairly, or in the best interests of the Company.

7.2.2 Examples of Conflict of Interest

Example of situations that may give rise to a conflict of interest include, but are not limited to:

• having a financial interest in a competitor, supplier, customer, or business partner
• participating in decisions involving family members, close friends, or related parties
• engaging in external employment, freelance work, or business activities that interfere with Company duties or compete with the Company's interests
• using Company information, resources, or position for personal gain
• accepting benefits or advantages that may improperly influence business decisions

7.2.3 External Employment & Business Activities

Employees must avoid engaging in any external employment, business activity, or professional commitment that may give rise to a conflict of interest or interfere with their duties to the Company.

This includes activities that:

• conflict with the Company’s business interests
• affect the employee’s performance, availability, or work commitment
• involve direct or indirect competition with the Company
• require use of Company time, resources, systems, or confidential information

Where there is no conflict of interest, employees may engage in external work or business activities, provided that prior written approval is obtained from the Company where required.

The Company reserves the right to request disclosure of such activities and to determine whether approval is required based on the nature of the role and potential risks involved.

7.2.4 Disclosure Obligation

Employees who are involved in, aware of, or become aware of any actual, potential, or perceived conflict of interest relating to their own personal, financial, family, or external business activities must promptly disclose the matter to the Company.

Disclosure should be made to the employee's immediate supervisor, HR, or other designated reporting channel as determined by the Company.

The Company may assess the situation and determine appropriate measures to manage, mitigate, or avoid the conflict.

7.2.5 Failure to Disclose

Failure to disclose a conflict of interest, or engaging in activities that improperly conflict with the interests of the Company, may result in disciplinary action, up to and including termination of employment, subject to applicable laws and Company procedures.

7.3 Confidentiality & Data Protection

7.3.1 General Principle

Employees are required to handle Company confidential information and personal data responsibly and in accordance with Company policies, operational requirements, and applicable laws, including the Malaysian Personal Data Protection Act 2010 (PDPA) where applicable.

Further confidentiality and intellectual property obligations are set out under Section 14: Confidentiality & Intellectual Property.

7.3.2 Personal Data Protection

Employees are required to handle personal data in accordance with applicable laws, including the Malaysian Personal Data Protection Act 2010 (PDPA), where applicable.

Personal data collected, accessed, or processed during employment must only be used for authorised business purposes and handled with appropriate confidentiality and security measures.

Employees must not improperly access, disclose, transfer, retain, or misuse personal data belonging to employees, customers, suppliers, or other individuals.

7.3.3 Use & Security of Information

Employees are expected to:

• safeguard Company documents, systems, and records
• keep passwords and access credentials secure
• avoid sharing confidential information through unauthorised channels
• comply with Company IT, cybersecurity, and document handling procedures
• immediately report any suspected data breach, loss of information, or unauthorised disclosure

The Company may implement monitoring, access controls, or security measures where necessary to protect Company information and systems, subject to applicable law.

7.3.4 Breach of Confidentiality

Any breach of confidentiality, data protection, or information security obligations may result in disciplinary action and/or legal action in accordance with Company policies and applicable laws.

7.4 Gifts, Entertainment & Anti-Bribery

7.4.1 General Principle

The Company adopts a strict policy against bribery and corruption. Employees must at all times act with integrity and must not directly or indirectly offer, give, solicit, or accept any form of bribe or improper advantage in any business dealings.

This policy is aligned with the Malaysia Anti-Corruption Commission Act 2009 (MACC Act 2009) and any breach may result in disciplinary action, termination of employment, and/or legal action.

7.4.2 Prohibited Conduct

Employees must not:

• offer, promise, give, request, or accept bribes or kickbacks of any form
• use personal or third-party channels to bypass this policy
• accept or provide gifts or entertainment intended to influence business decisions or create a sense of obligation
• engage in any conduct that may be perceived as corrupt or improper, even if no actual benefit is received

7.4.3 Gifts & Hospitality (Permitted Practice)

Modest and reasonable gifts or hospitality may be accepted or offered only if they:

• are infrequent and given in good faith as a normal business courtesy
• do not influence, or appear to influence, professional judgement or business decisions
• are not in the form of cash or cash equivalents (including vouchers, gift cards, or similar instruments)
• are not excessive, inappropriate, or capable of being misinterpreted

7.4.4 Declaration Requirement

All gifts or hospitality above a reasonable value threshold (as determined by the Company) must be declared to Management or HR for review and approval.

7.4.5 Reporting Obligation

Employees must report any suspected or actual bribery, corruption, or unethical conduct to their immediate supervisor or HR. All reports will be treated confidentially, and employees will be protected from retaliation when reporting in good faith.

7.5 Use of Company Property & Assets

7.5.1 General Responsibility

Employees are responsible for the proper use, care, and protection of Company property, assets, systems, and resources provided for work purposes.

Company property must be used responsibly, ethically, and primarily for legitimate business purposes.

7.5.2 Company Property & Assets

Company property and assets may include, but are not limited to:

• laptops, computers, mobile devices, and office equipment
• software, systems, email accounts, and communication tools
• documents, records, and Company information
• access cards, keys, and security credentials
• vehicles, tools, machinery, and furniture
• intellectual property, digital assets, and work materials

All Company property remains the property of the Company unless otherwise stated.

7.5.3 Acceptable Use

Employees are expected to:

• use Company property in a safe, responsible, and lawful manner
• take reasonable care to prevent loss, damage, theft, or misuse
• comply with Company policies relating to IT systems, cybersecurity, and workplace safety
• promptly report any loss, damage, malfunction, or security concern involving Company property

Limited personal use may be permitted where reasonable, infrequent, and does not interfere with work responsibilities, security, or Company operations.

7.5.4 Prohibited Use

Employees must not:

• misuse, damage, remove, or dispose of Company property without authorisation
• use Company property for illegal, unethical, or unauthorised purposes
• install unauthorised software or bypass Company security controls
• share Company systems, passwords, or access credentials without approval
• use Company assets for personal business, commercial activities, or personal gain without approval

7.5.5 Monitoring & Access

To protect Company assets, systems, and information, the Company may monitor, access, review, or audit Company property, systems, accounts, communication, or records in accordance with applicable laws and Company policies.

Employees should not expect absolute privacy when using Company-provided systems or resources for work purposes.

7.5.6 Return of Company Property

Employees must return all Company property upon resignation, termination, transfer, or upon request by the Company.

This includes physical items, documents, access credentials, electronic records, and any other Company-owned materials in the employee's possession or control.

Employees must not retain unauthorised copies of Company information after employment ends.

7.5.7 Damage, Loss, or Misuse

Any intentional misuse, negligence, unauthorised removal, or damage to Company property may result in disciplinary action. The Company reserves the right to recover losses or pursue legal action where permitted by applicable laws.

7.6 Social Media, Public Statements & External Representation

7.6.1 General Principle

Employees are expected to use social media and public communication channels responsibly and in a manner that does not negatively affect the Company's reputation, confidential information, business interests, employees, clients, or business partners.

This policy applies to public statements made through social media platforms, online forums, messaging applications, interviews, publications, or other forms of public communication where the Company may be identified or associated with the employee.

7.6.2 Confidentiality & Professional Conduct

Employees must not:

• disclose confidential, proprietary, or non-public Company information
• share internal documents, business information, client information, or personal data without authorisation
• make false, misleading, defamatory, discriminatory, harassing, or offensive statements relating to the Company, its employees, clients, vendors, or business partners
• represent personal opinions as official Company views without authorisation

Employees are expected to maintain professional conduct online and avoid behaviour that may seriously damage the Company's reputation or working relationships.

7.6.3 Authorised Public Statements & Media Communication

Only authorised employees may:

• issue official public statements on behalf of the Company
• communicate with the media regarding Company matters
• represent the Company in public interviews, press releases, or external communication
• create or publish official Company content through corporate channels

Employees who receive media enquiries or external requests for official statements should refer the matter to the designated Management representative or authorised department.

7.6.4 Use of Company Name, Brand & Content

Employees must not use the Company's name, logo, branding, intellectual property, images, videos, or official materials for unauthorised personal, commercial, or public purposes.

Any use of Company branding or representation in external materials must receive prior approval from the Company.

7.6.5 Personal Social Media Use

The Company respects employee's personal use of social media. However, employees remain responsible for ensuring that personal online activities do not:

• breach Company policies or confidentiality obligations
• creates conflicts of interest
• amount to harassment, bullying, discrimination, or unlawful conduct
• improperly imply official Company endorsement or representation

Where appropriate, employees may be required to clarify that views expressed are personal and do not represent the Company.

7.6.6 Photography, Video & Company Events

The Company may take photographs, videos, or other recordings during Company activities, events, training sessions, or workplace activities for internal communication, branding, recruitment, marketing, or promotional purposes.

Where required by applicable law or Company practice, the Company may obtain employee consent for such use.

Employees must not record or publish internal meetings, confidential discussions, workplace incidents, or non-public Company activities without authorisation.

7.6.7 Authority to Represent the Company

Employees are not authorised to enter into agreements, commitments, or make representations that may create legal or financial obligations for the Company unless expressly authorised by the Company.

Only employees who have been granted delegated authority by the Company (e.g. Directors, authorised signatories, or designated personnel) may:

• sign contracts or binding agreements
• make commitments on behalf of the Company
• negotiate terms that may create legal obligations

Employees who are not authorised must not hold themselves out as having such authority.

7.6.8 Breach of Policy

Any breach of this policy may result in disciplinary action, and where applicable, legal action in accordance with Company policies and applicable laws.

8. Workplace Rules & Policies

8.1 Dress Code & Personal Grooming

Attire should be clean, modest, and appropriate for the working environment and job responsibilities. Personal grooming, including hygiene, hair, and overall appearance, should be properly maintained.

The following are generally not permitted unless otherwise approved or required for work purposes:

• clothing or accessories that are offensive, inappropriate, or unprofessional
• attire that is excessively casual or revealing
• clothing, footwear, or accessories that may pose a health or safety risk in the workplace

Employees must also comply with any role-specific, uniform, safety, or site-related dress requirements communicated by the Company.

The Company reserves the right to advise employees on appropriate workplace attire and require reasonable adjustments where necessary.

8.2 Workplace Safety & Housekeeping

Employees are responsible for helping to maintain a safe, clean, and orderly work environment at all times. 

Employees are expected to:

• keep work areas tidy and free from unnecessary clutter
• ensure walkways, exits, and common areas remain clear and unobstructed
• use equipment, tools, machinery, and facilities properly and safely
• follow all workplace safety procedures, instructions, and signage
• dispose of waste and materials in designated areas
• promptly report any unsafe conditions, hazards, accidents, or incidents to Management or the relevant department

Employees must not engage in unsafe behaviour, misuse equipment, or act in any manner that may endanger themselves or others in the workplace.

The Company may issue additional workplace safety rules, procedures, or operational guidelines from time to time, and employees are required to comply with such requirements.

8.3 Smoking, Alcohol & Substance Abuse

To maintain a safe and professional work environment, employees must not report to work or perform work while under the influence of alcohol, illegal drugs, or other substances that may impair their judgment, performance, safety, or ability to carry out their duties responsibly.

Smoking, including the use of electronic cigarettes or vaping devices, is only permitted in designated smoking areas, where provided. Employees must comply with all applicable smoking restrictions within the workplace and surrounding premises.

The following conduct is prohibited:

• Consuming alcohol during working hours without prior Company approval
• Reporting to work under the influence of alcohol, illegal drugs, or other impairing substances
• Possessing, using, distributing, or selling illegal drugs within Company premises or during work-related activities
• Misuse of prescription or over-the-counter medication that may impair performance or safety

Employees who are required to take medication that may affect their alertness, judgment, or ability to work safely should inform their supervisor or HR where appropriate, particularly where safety-sensitive duties are involved.

The Company reserves the right to take appropriate action where an employee's conduct, performance, attendance, or workplace safety is affected by alcohol or substance use, in accordance with the Company's disciplinary procedures.

8.4 Harassment, Discrimination & Bullying

8.4.1 Commitment to a Safe Workplace

The Company is committed to maintaining a safe, respectful, inclusive, and professional working environment free from harassment, discrimination, bullying, and other inappropriate conduct.

The Company does not tolerate any form of harassment, discrimination, bullying, victimisation, or other inappropriate behaviour that may negatively affect an individual's dignity, well-being, safety, or ability to work.

This policy applies to all employees at all levels, including management, temporary staff, interns, contractors, and consultants. The Company also expects clients, vendors, visitors, and other third parties interacting with the Company to uphold these standards.

This policy applies to conduct occurring in all work-related settings, including but not limited to:

• the workplace or office premises
• Company events or functions
• training sessions or workshops
• business travel or off-site meetings
• work-related communications, including email, messaging platforms, phone calls, and social media
• interactions involving clients, vendors, visitors, or other third parties

This policy may apply regardless of whether the conduct occurs during or outside working hours, where the behaviour is connected to work or reasonably affects the working environment or working relationships.

The Company takes all complaints seriously and encourages employees to report concerns without fear of retaliation. Reports will be handled as fairly, respectfully, and confidentially as reasonably practicable in accordance with the Company's reporting, investigation, and disciplinary procedures.

8.4.2 Sexual Harassment

Sexual harassment refers to any unwanted conduct of a sexual nature, whether verbal, non-verbal, physical, or written, that is offensive, humiliating, intimidating, or creates a hostile working environment.

Examples of sexual harassment may include, but are not limited to:

• Unwelcome sexual advances or requests for sexual favours
• Inappropriate jokes, comments, or remarks of a sexual nature
• Displaying or sharing sexually suggestive materials
• Unwanted physical contact
• Repeated invitations despite rejection
• Sending sexually suggestive messages, images, or content

Sexual harassment may occur between individuals at any level, including between supervisors and subordinates, peers, or involving clients, vendors, or other third parties.

8.4.3 Workplace Harassment / Bullying 

Workplace harassment or bullying refers to repeated or serious behaviour that intimidates, humiliates, isolates, or undermines another person, creating a hostile or uncomfortable working environment.

Workplace harassment or bullying may include, but are not limited to:

• Repeated criticism, ridicule, or personal insults
• Intimidation, threats, or aggressive behaviour
• Public humiliation or belittling of an individual
• Deliberate exclusion from work-related activities or information
• Misuse of authority or power to disadvantage others
• Persistent unreasonable work demands or sabotage of work performance

Bullying or harassment may occur between colleagues at the same level, including supervisors and subordinates, peers, or involving clients, vendors, or other third parties.

8.4.4 Discrimination 

The Company prohibits discrimination in any form. Discrimination refers to unfair or unequal treatment of an individual based on personal characteristics unrelated to job performance.

Discrimination may include, but is not limited to:

• gender
• pregnancy or maternity status
• race or ethnicity
• religion or belief
• disability
• age
• marital Status
• nationality or background

Discriminatory behaviour may include:

• unfair hiring or promotion decisions
• unequal access to opportunities or training
• unjustified differences in job assignments
• exclusion from work-related activities
• offensive remarks or conduct relating to personal characteristics

Discrimination may occur between employees at any level or involve clients, vendors, or other third parties.

8.4.5 Reporting Procedure 

Employees are encouraged to report any incidents of harassment, discrimination, or bullying as soon as possible. Reports should be made in writing and may be submitted through any of the following channels:

• Immediate supervisor or manager
• Human Resources (HR)
• Any designated Company representative or alternative reporting contact (if applicable)

Where an employee is uncomfortable reporting through normal channels, or where the report involves a supervisor, the employee may report directly to HR or an alternative designated contact.

If a report is initially made verbally, the employee may be asked to provide a written statement to support proper documentation and investigation.

Upon receiving a report, the Company will assess the matter and conduct an internal investigation where appropriate, in accordance with its investigation and disciplinary procedures. The Company may take appropriate corrective or disciplinary action where a breach of this policy is substantiated.

Employees are encouraged to report concerns in good faith. Retaliation against any individual who makes a complaint or participates in an investigation is strictly prohibited. 

8.5 Violence-Free Workplace

The Company is committed to maintaining a safe and secure working environment free from violence, threats, intimidation, and aggressive behaviour.

Employees must not engage in any act of violence, threatening behaviour, intimidation, harassment, or conduct that may endanger the safety, security, or well-being of others in the workplace.

Prohibited conduct includes, but is not limited to:

• physical assault or fighting
• threats of violence or harm
• intimidation, aggressive behaviour, or verbal abuse
• deliberate damage to Company property or personal property
• possession of weapons or dangerous items on Company premises without authorisation
• any behaviour that causes fear, panic, or risk to workplace safety

This policy applies to all work-related settings, including Company premises, business travel, Company events, off-site meetings, and work-related communications.

Employees are encouraged to immediately report any violent, threatening, or unsafe behaviour to Management, HR, Security personnel, or other designated reporting channels.

The Company may take immediate and appropriate action where necessary to protect employees, visitors, property, or workplace safety, including removal from the workplace, suspension from duties, involvement of law enforcement authorities, or disciplinary action in accordance with Company procedures and applicable law.

8.6 Visitors & Security Procedures

To maintain workplace safety, security, confidentiality, and operational control, all employees are expected to comply with the Company's visitor management and security procedures.

Visitors, vendors, contractors, interview candidates, and other non-employees entering Company premises may be required to:

• register at the designated reception or entry point
• obtain approval or authorisation before entering restricted areas
• wear visitor passes or identification where applicable
• be accompanied by an authorised employee where required

Employees are responsible for ensuring that visitors under their care comply with applicable Company rules, safety requirements, and confidentiality obligations while on Company premises.

Employees must not permit unauthorised individuals to access restricted areas, Company systems, confidential information, or secured facilities without proper approval.

Employees are expected to safeguard Company property, access cards, keys, passwords, and other security credentials at all times and must immediately report any loss, theft, suspicious activity, or security concern to the relevant department or Management.

The Company reserves the right to implement and enforce reasonable security measures, including access control procedures, surveillance systems, bag checks, visitor logs, or other security protocols where necessary, in accordance with applicable laws and operational requirements.

9. Health, Safety & Environment (HSE)

9.1 Occupational Safety & Health Commitment

The Company is committed to providing and maintaining a safe, healthy, and secure working environment for all employees, in accordance with applicable laws, including the Occupational Safety and Health Act 1994 (OSHA 1994) and other relevant regulations.

The Company places strong emphasis on preventing workplace accidents, injuries, and occupational health risks, and will take reasonable and practicable measures to ensure a safe working environment for all employees, contractors, visitors, and other stakeholders.

The Company’s safety and health objectives include:

• promoting a safe and health-conscious workplace culture
• preventing workplace accidents, injuries, and occupational illnesses
• ensuring compliance with applicable health and safety laws and regulations
• identifying, assessing, and controlling workplace hazards where reasonably practicable
• providing appropriate safety information, training, and guidance where necessary

While the Company will take reasonable steps to maintain a safe working environment, all employees are required to play an active role in ensuring workplace safety by complying with Company policies, procedures, and lawful safety instructions.

Safety is a shared responsibility, and employees are expected to support and contribute to a safe working environment at all times.

9.2 Employee Responsibilities on Safety

All employees are responsible for contributing to a safe and healthy workplace and are required to take reasonable care for their own safety, as well as the safety of others who may be affected by their actions or omissions at work.

Employees are expected to:

• comply with all applicable safety laws, Company policies, procedures, and instructions
• follow safety guidelines, signage, and operating procedures at all times
• use equipment, machinery, tools, and facilities in a safe and proper manner
• wear and utilise required personal protective equipment (PPE), where applicable
• report unsafe conditions, hazards, near-misses, accidents, or injuries promptly to Management or the relevant department
• avoid engaging in any unsafe behaviour or practices that may endanger themselves or others
• participate in safety training, drills, or awareness programmes when required

Employees must not:

• knowingly ignore or bypass safety procedures or controls
• misuse safety equipment or safety systems
• remove, tamper with, or disable safety devices or warnings
• undertake work for which they are not trained, authorised, or competent

Where employees are unsure about any safety procedure or potential risk, they are encouraged to seek clarification from their supervisor or the relevant safety personnel before proceeding.

The Company expects all employees to actively support and uphold a safe working environment as part of their daily responsibilities.

9.3 Accident Reporting & Incident Management

The Company is committed to ensuring that all workplace accidents, incidents, injuries, and near-misses are properly reported, recorded, and managed in a timely and effective manner.

Employees must immediately report any of the following to their supervisor, Management, or the relevant department:

• workplace accidents or injuries, regardless of severity
• near-miss incidents that could have resulted in injury or damage
• unsafe conditions or hazards in the workplace
• damage to Company property or equipment that may affect safety
• any incident involving visitors, contractors, or third parties within Company premises

Employees should provide clear and accurate information when reporting an incident, including what happened, when and where it occurred, and any persons involved or affected.

Where necessary, the Company may require employees to submit a written incident report and cooperate fully in any internal investigation or follow-up actions.

The Company will review reported incidents and take appropriate corrective or preventive measures where necessary to reduce the risk of recurrence and to improve workplace safety.

Failure to report incidents in a timely manner may result in disciplinary action, where appropriate, as it may affect workplace safety, investigation accuracy, and regulatory compliance.

9.4 Emergency Procedures & Evacuation

The Company is committed to maintaining appropriate emergency preparedness measures to protect employees, visitors, property, and workplace safety in the event of an emergency situation.

Employees are required to familiarise themselves with applicable emergency procedures, evacuation routes, emergency exits, assembly points, and safety instructions communicated by the Company.

Emergency situations may include, but are not limited to:

• fire or smoke-related incidents
• medical emergencies
• natural disasters or severe weather conditions
• chemical spills or hazardous situations
• security threats, violence, or other emergency situations affecting workplace safety

In the event of an emergency, employees are expected to:

• remain calm and follow instructions issued by authorised personnel or emergency responders
• evacuate the premises promptly when instructed to do so
• proceed to designated assembly points or safe areas
• avoid using lifts or restricted routes where prohibited during emergencies
• cooperate with emergency response procedures, safety drills, or investigations
• immediately report any missing persons, injuries, or unsafe conditions where possible

Employees must not interfere with, misuse, or obstruct emergency equipment, alarm systems, emergency exits, or evacuation procedures.

The Company may conduct emergency drills, training sessions, or safety exercises from time to time, and employees are expected to participate where required.

9.5 First Aid & Medical Emergencies

The Company will take reasonable and practicable measures to provide basic first aid support and respond appropriately to medical emergencies occurring within the workplace.

First aid kits, emergency contact information, and designated first aid personnel (where applicable) may be made available at Company premises in accordance with operational needs and applicable safety requirements.

Employees must immediately report any work-related injury, illness, medical emergency, or situation requiring urgent medical attention to their supervisor, Management, HR, or designated first aid personnel.

In the event of a medical emergency, employees are expected to:

• seek immediate assistance from available first aid personnel or emergency services
• cooperate with emergency response procedures and instructions
• avoid moving injured persons unless necessary for safety reasons or instructed by trained personnel
• promptly report any unsafe condition or incident contributing to the emergency

Where necessary, the Company may arrange emergency medical assistance, transportation, or contact the employee's emergency contact person based on the circumstances.

Employees are encouraged to provide updated emergency contact information to the Company and to inform the Company where appropriate of any medical condition that may require workplace emergency assistance or accommodation, subject to applicable privacy and confidentiality obligations.

The Company may maintain records relating to workplace injuries or medical incidents for safety management, insurance, legal, or regulatory purposes in accordance with applicable laws and Company procedures.

10. Performance Management

10.1 Performance Planning & Expectations

The Company adopts a structured approach to performance planning to ensure that employees clearly understand their roles, responsibilities, and expected standards of performance.

At the beginning of each performance cycle or upon commencement of employment, employees may be required to discuss and understand performance expectations with their supervisor or manager. These expectations are intended to align individual performance with departmental objectives and the overall goals of the Company.

Performance expectations may include, but are not limited to:

• key performance indicators (KPIs), where applicable
• role-specific duties and responsibilities
• project deliverables and deadlines
• behavioural and competency expectations relevant to the role
• other work-related objectives as determined by the Company

Performance expectations may be reviewed and adjusted from time to time to reflect changes in business needs, job scope, or operational priorities.

Employees are expected to make reasonable efforts to understand and achieve the performance expectations set for their role. Supervisors are responsible for providing clarity, direction, and reasonable support to assist employees in meeting these expectations.

The Company reserves the right to determine, modify, and update performance expectations where necessary to ensure alignment with business requirements.

10.2 Performance Appraisal & Review

The Company conducts structured performance appraisal and review processes to assess employee performance, development progress, and overall contribution to the organisation.

Performance reviews are typically conducted on a periodic basis (e.g. annually or as determined by the Company). The review cycle may be adjusted from time to time based on business needs or operational requirements. 

The performance appraisal process may take into consideration, but is not limited to:

• achievement of KPIs and work objectives
• demonstration of job-related competencies and behaviours
• feedback from supervisors, peers, and/or stakeholders (including 360-degree feedback where applicable)
• overall contribution to team and Company performance
• attendance, reliability, and work discipline where relevant

As part of the performance review process, employees may receive feedback discussions with their supervisors to support development and performance improvement.

Following the performance review, the Company may, where applicable, conduct internal discussions between Heads of Department and Human Resources to consider outcomes such as:

• performance ratings or classifications
• career development opportunities
• role adjustments or promotions
• salary adjustments, bonuses, or other compensation-related decisions

Any approved changes to compensation, role status, or employment terms will be formally communicated to the employee in writing, which may include a revised employment letter or confirmation letter where applicable.

The Company reserves the right to determine the timing, structure, and outcomes of performance reviews, and may amend the process from time to time based on organisational needs.

10.3 Coaching, Feedback & Development

10.3.1 General Development Framework

The Company is committed to supporting employee development through continuous learning, coaching, and professional growth opportunities.

Employees are encouraged to take ownership of their own development and may propose trainings, courses, or learning initiatives for Management consideration and approval.

Development initiatives may include, but are not limited to:

• on-the-job coaching and mentoring
• internal knowledge-sharing sessions
• training programmes, workshops, and seminars
• professional certifications or external courses
• cross-functional or project-based learning opportunities

Where the Company approves or sponsors training or development programmes, employees may be required to comply with reasonable conditions set by the Company, which may include:

• sharing of learning outcomes or key takeaways
• conducting internal knowledge-sharing or training sessions
• submitting documentation or reports upon completion of training
• serving a training bond or repayment obligation where applicable under a separate written agreement

Any training sponsorship or bonding arrangement (if applicable) shall be governed by a separate written agreement between the Company and the employee, which will set out the specific terms, duration, and conditions.

10.3.2 Lynch Pin Holdings Internal Learning Culture (where applicable)

For LPH employees, the Company encourages a knowledge-sharing culture where employees who attend sponsored training or development programmes may be required to present or share their learnings with colleagues as part of internal capability building initiatives.

Participation in such knowledge-sharing sessions may be assigned based on business needs and operational requirements.

10.4 Performance Outcomes & Career Development

The Company recognises and rewards employee performance and contributions through various career development and performance-related outcomes, subject to business performance, organisational needs, and management discretion.

All performance-related outcomes are subject to Company discretion, business requirements, and applicable policies. The Company reserves the right to determine appropriate outcomes based on overall performance assessment and organisational needs.

10.4.1 Positive Performance Outcomes

Employees who demonstrate strong performance, consistent contribution, and alignment with Company values may be considered for the following outcomes, subject to business needs and Management approval:

• annual salary increment (where applicable)
• performance-based bonus (subject to Company and/or business performance)
• promotion or advancement to higher job grades or responsibilities
• expanded job scope, leadership opportunities, or special assignments
• learning and development opportunities

Any salary adjustments, bonuses, or promotions are not guaranteed and are determined at the sole discretion of the Company.

10.4.2 Unsatisfactory Performance Outcomes

Where an employee's performance does not meet the expected standards, the Company may take appropriate steps to address performance concerns. These may include, but are not limited to:

• coaching and performance support
• closer supervision or monitoring
• reassignment of duties or role adjustment where appropriate
• placement under a Performance Improvement Plan (PIP)

10.4.3 Performance Improvement and Further Action

Where performance concerns persist, the employee may be placed under a formal PIP to provide a structured opportunity for improvement.

Further details regarding the PIP process are set out in Section 10.5 of this Handbook.

If performance does not improve to a satisfactory level following the PIP, the Company may take appropriate action, which may include reassignment, restructuring of duties, or termination of employment, subject to applicable laws and Company procedures.

10.4.4 Role Review and Organisational Fit

The Company may also review an employee's role suitability from time to time. Where appropriate, the Company may consider role realignment, restructuring, or redeployment based on business needs, organisational changes, or employee capability and suitability.

10.5 Performance Improvement Plan (PIP)

10.5.1 Purpose of PIP

The Performance Improvement Plan (PIP) is a structured performance management tool designed to support employees whose performance does not meet expected standards, by providing clear expectations, guidance, and an opportunity to improve.

10.5.2 Initiation of PIP

An employee may be placed under a PIP where performance concerns are identified through performance reviews, ongoing feedback, or supervisory assessment.

The PIP will be developed by the employee's Head of Department in consultation with Human Resources and will outline:

•  areas of performance concern
• expected improvement standards and objectives
• support and guidance to be provided
• review checkpoints and monitoring process
• duration of the PIP

10.5.3 Duration of PIP

The PIP period is typically between 3 to 6 months, depending on the nature of the performance issues and role requirements. The duration may be adjusted by the Company where appropriate.

10.5.4 Employee Participation

The Company encourages employees to participate in the PIP in good faith as part of a structured performance improvement process.

Where an employee does not reasonably participate in the PIP, the Company may proceed with performance management based on available performance records and evidence.

Non-participation in the PIP does not prevent the Company from taking appropriate performance-related action in accordance with Company procedures and applicable laws.

10.5.5 Review & Outcomes

At the end of the PIP period, the Company will review the employee's performance and determine the outcome, which may include:

• successful completion of the PIP, with continuation of employment under normal terms
• extension of the PIP period where further improvement is required
• reassignment, role adjustment, or other performance-related actions
• termination of employment, subject to applicable laws and Company procedures

For employees on probation, successful completion of a PIP may contribute towards confirmation of employment where applicable.

For confirmed employees, successful completion of a PIP will result in continuation of employment under existing confirmed status, without change to employment status.

10.5.6 General Principle

The PIP process is intended as a structured support mechanism and does not guarantee continued employment. The Company reserves the right to take appropriate action based on overall performance and business requirements.

11. Disciplinary Procedures

11.1 Misconduct

Misconduct refers to any behaviour, action, or omission by an employee that is inconsistent with the Company's policies, rules, standards of conduct, or terms and conditions of employment.

Misconduct may include conduct that disrupts workplace operations, compromises safety, affects professional working relationships, or damages the Company's reputation.

Examples of misconduct may include, but are not limited to:

• Insubordination or refusal to follow reasonable instructions
• Dishonesty, fraud, or theft
• Harassment, bullying, or inappropriate workplace behaviour
• Violence, threats, or abusive conduct
• Reporting to work under the influence of drugs or alcohol
• Misuse of Company property, systems, or confidential information
• Repeated lateness, absenteeism, or failure to follow attendance requirements
• Negligence or failure to perform duties responsibly
• Breach of workplace safety rules or procedures

A breach of any Company policy, rule, or procedure may also constitute misconduct depending on severity and circumstances.

The Company reserves the right to determine whether an act or omission constitutes misconduct and to take appropriate action in accordance with the Disciplinary Procedures set out in this section.

11.2 Domestic Inquiry

11.2.1 Purpose of Domestic Inquiry

Where allegations of misconduct arise, the Company may conduct a Domestic Inquiry to establish the facts before making any disciplinary decision. 

A Domestic Inquiry is an internal investigation process where the employee will be informed of the allegations and given an opportunity to respond before any disciplinary action is taken. The Company may gather relevant information, interview involved parties, and review available evidence as part of this process 

11.2.2 Investigation Principles

All Domestic Inquiries will be conducted in accordance with the following principles:

• Fairness & impartiality: The inquiry will be conducted objectively and without bias
• Opportunity to respond: The employee will be given a reasonable opportunity to explain their position
• Confidentiality: Information will be shared only with individuals involved in the inquiry process where necessary
• Good faith review: All available information will be considered in good faith
• Proportionate approach: The level of inquiry may vary depending on the severity and complexity of the case

The Company reserves the right to determine the appropriate inquiry process based on the nature of the allegation.

11.2.3 Investigation Process 

Employees are not required to provide perfect or conclusive evidence when making a complaint. The absence of complete evidence will not prevent a complaint from being reviewed.

The Company will consider all relevant evidence in good faith, which may include:

• Written statements
• Messages, emails, or digital communications
• Documents or records
• Witness accounts
• Any other supporting information available
• Where appropriate, the Company may also consider contextual factors such as patterns of behaviour or prior related incidents.
  
  

Employees are encouraged to provide any supporting evidence they already have access to, such as relevant communications or records related to the incident. However, employees are not expected or required to obtain evidence in any manner that may violate privacy laws or involve unlawful conduct.

Investigation Flow Chart

The Company may adjust this process depending on the severity or urgency of the complaint to ensure safety and fairness.

11.2.4 Protection Against Retaliation 

The Company strictly prohibits retaliation against any individual who makes a report, raises a concern, or participates in an investigation relating to harassment, discrimination, or bullying.

Retaliation includes any negative action or treatment, such as:

• Intimidation or harassment
• Discrimination or unfair treatment
• Demotion, dismissal, or disciplinary action
• Any other disadvantage resulting from a report made in good faith

Any employee found to have engaged in retaliation will face disciplinary action, up to and including termination of employment.

The Company also expects all reports to be made in good faith. Any knowingly false or malicious report may also result in disciplinary action.

11.3 Suspension Pending Investigation

Where necessary, the Company may suspend an employee from work to facilitate investigation into alleged misconduct.

Suspension is not a disciplinary action and does not imply that misconduct has occurred. It is a temporary measure to allow the Company to conduct an inquiry without interference, risk, or disruption.

The period of suspension shall not exceed 2 weeks. During the suspension period, the employee shall be paid not less than half of their wages.

If the inquiry does not establish any misconduct, the employee will be reinstated and the balance of wages withheld during the suspension period will be paid in full.

The Company reserves the right to determine whether suspension is necessary based on the nature and seriousness of the allegation.

11.4 Disciplinary Actions & Progressive Discipline

Where misconduct is established following an investigation or Domestic Inquiry, the Company may take appropriate disciplinary action based on the severity and circumstances of the case.

The Company generally adopts a progressive discipline approach where appropriate, with the aim of providing employees an opportunity to correct behaviour before more serious disciplinary action is taken.

Depending on the nature and seriousness of the misconduct, disciplinary action may include one or more of the following: ​

• informal counselling or verbal warning
• written warning
• final written warning
• mandatory training or counselling
• transfer or reassignment of duties
• demotion
• termination of employment

The Company reserves the right to determine the appropriate disciplinary action based on factors including the seriousness of the misconduct, the employee's disciplinary record, surrounding circumstances, and operational impact.

In cases involving serious misconduct, the Company may bypass one or more progressive disciplinary steps and proceed directly to to a Domestic Inquiry and/or appropriate disciplinary action, including suspension where necessary and termination of employment, subject to applicable laws and Company procedures.

Progressive discipline applies to misconduct-related matters. Performance-related issues will generally be managed under Section 10: Performance Management.

In cases involving third parties (such as clients, vendors, contractors, or visitors), the Company may take appropriate action, including restricting access, terminating engagement, or escalating the matter to the relevant party or authority where necessary.

12. Grievance Handling

12.1 Purpose & Scope of Grievance Handling

The Company encourages open communication and aims to maintain a fair, respectful, and professional working environment where employees are able to raise workplace concerns in an appropriate manner.

The Grievance Handling process provides employees with a structured channel to raise concerns, complaints, or dissatisfaction relating to work-related matters, with the objective of seeking clarification, support, or resolution where appropriate.

A grievance may relate to matters including, but not limited to:

• interpersonal conflicts or workplace relationship issues
• concerns regarding management decisions or supervisory conduct
• communication or work-related misunderstandings
• perceived unfair treatment or workplace concerns
• concerns relating to working conditions, workload, or operational practices
• other work-related matters affecting the employee's work environment

This grievance process is separate from the disciplinary procedures outlined in Section 11: Disciplinary Procedures, although certain matters may be referred for further investigation or disciplinary review where appropriate.

The Company will review grievances fairly, respectfully, and in good faith, while taking into consideration the nature of the concern, available information, operational requirements, and applicable Company policies and procedures.

12.2 Raising a Grievance & Reporting Channels

Employees are encouraged to raise work-related concerns or grievances through appropriate communication channels as early as reasonably practicable to support timely review and resolution.

Where appropriate, employees are encouraged to first discuss the matter informally with their immediate supervisor or manager, as many workplace concerns may be resolved through open communication and discussion.

Where the employee is uncomfortable raising the matter with their supervisor, or where the concern involves the supervisor directly, the employee may raise the grievance through alternative channels, including:

• Human Resources (HR)
• Management or other authorised representatives of the Company
• designated support or reporting channels established by the Company (including confidential support channels where applicable)

The Company may also provide confidential communication channels from time to time, such as the Peoplecare email channel referenced under Section 6.5.3: Employee Assistance & Support Channels, for employees who may require additional support or an alternative reporting avenue.

Grievances may initially be raised verbally or informally where appropriate. However, depending on the nature or seriousness of the matter, the Company may request that the grievance be submitted or documented in writing to facilitate proper review, investigation, or resolution.

Employees are encouraged to raise grievances in good faith and provide any relevant information available to assist the Company in understanding and addressing the concern appropriately.

12.3 Review, Investigation & Resolution Process

Upon receiving a grievance, the Company will review the matter and determine the appropriate approach for handling the matter based on the nature, seriousness, and circumstances of the issue raised.

Where appropriate, the Company may first attempt to resolve the matter informally through discussion, clarification, mediation, counselling, or communication between the relevant parties.

Depending on the circumstances, the Company may:

• meet with the employee raising the grievance
• gather relevant information or supporting documents
• speak with supervisors, employees, or other relevant parties
• conduct an internal review or investigation where appropriate
• recommend practical steps or workplace solutions to address the concern

Not all grievances will require a formal investigation or disciplinary process. The Company reserves the right to determine the appropriate level of review, intervention, or action required based on the specific circumstances of each case.

Where the grievance involves potential misconduct, breach of Company policy, workplace harassment, discrimination, safety concerns, or other serious matters, the Company may escalate the matter for further investigation under Section 11: Disciplinary Procedures or other applicable Company policies.

The Company will make reasonable efforts to handle grievances fairly, respectfully, and within a reasonable timeframe. However, the time required for review or resolution may vary depending on the complexity of the matter, availability of information, and operational requirements.

Where appropriate, the Company may maintain records relating to grievances, discussions, investigations, or outcomes for operational, legal, or compliance purposes.

12.4 Confidentiality & Non-Retaliation

The Company will handle grievances in a confidential and discreet manner, and information will only be shared with individuals involved in the review or resolution process on a need-to-know basis.

Employees are expected to respect the confidentiality of the grievance process and must not disclose the details of the matter to uninvolved parties, except where necessary or required by law.

The Company strictly prohibits any form of retaliation against employees who raise grievances in good faith or who participate in the grievance process.

Retaliation is addressed under Section 11.2.4 Protection Against Retaliation and will be treated seriously in accordance with Company policies.

Employees are also expected to raise grievances in good faith. Any knowingly false or malicious grievance may be subject to appropriate action under the Company's disciplinary procedures.

13. Separation from Employment

13.1 Resignation & Notice Period

13.1.1 General Principle

Either the employee or the Company may terminate the employment relationship by providing notice in accordance with the employee's employment contract, this Handbook, and applicable laws.

Employees who wish to resign are required to inform the Company in writing. The resignation will take effect based on the applicable notice period unless otherwise agreed by the Company.

The Company reserves the right to manage resignation and separation processes in accordance with operational, business, and legal requirements.

13.1.2 Notice Period

The applicable notice period shall be as stated in the employee's employment contract.

Where the employment contract does not specify a notice period, the minimum notice period under applicable law shall apply as follows:

Length of Service	Notice Period
< 2 years	4 weeks' notice
2 - 5 years	6 weeks' notice
5 years and above	8 weeks' notice

The notice period will commence from the date written notice is received by the receiving party unless otherwise agreed.

13.1.3 Payment in Lieu of Notice

The Company or the employee may, subject to applicable laws and Company approval where applicable, terminate the employment by making payment in lieu of notice for all or part of the required notice period.

The calculation of payment in lieu of notice shall be based on the employee's wages in accordance with applicable laws and Company practice.

13.1.4 Garden Leave / Waiver of Duties

During the notice period, the Company reserves the right, at its sole discretion, to require the employee to proceed on garden leave for all or part of the notice period.

Where an employee is placed on garden leave, the employee shall remain employed by the Company and shall continue to receive their normal salary and contractual benefits, unless otherwise permitted by law and any mutually agreed written separation arrangement where employment is terminated earlier.

During garden leave, the employee may be required to:

• remain away from the workplace;
• refrain from performing any work duties;
• not represent or act on behalf of the Company;
• return or surrender Company property and/or access rights; and/or
• comply with any reasonable instructions issued by the Company during the notice period.

The employee shall remain bound by all terms of employment, including but not limited to confidentiality obligations, non-disclosure requirements, and other continuing contractual duties.

The Company may also, in lieu of garden leave, waive all or part of the employee's requirement to serve the notice period. In such cases, the employment shall terminate earlier, subject to payment in lieu of notice where applicable.

13.1.5 Resignation Without Notice

Employees who resign without serving the required notice period or without payment in lieu of notice may be required to compensate the Company in accordance with the employment contract and applicable laws.

Nothing in this section prevents an employee from exercising any rights available under applicable laws, including situations where immediate resignation without notice may be permitted under the law.

13.2 Termination by the Company

13.2.1 Termination by Notice (General Termination)

The Company may terminate the employment relationship by providing written notice or payment in lieu of notice, in accordance with Section 13.1, the employee's employment contract, and applicable law.

This form of termination applies in general circumstances where the employment is ended without allegations of misconduct or disciplinary action.

The notice period shall be determined in accordance with:

• the employee's employment contract; or
• if not stated in the contract, the minimum notice periods under applicable law as set out in Section 13.1

The notice period will commence from the date the written notice is received by the employee.

During the notice period, the employee is expected to continue performing their duties unless otherwise directed or agreed by the Company, including placement on garden leave where applicable.

Where the Company elects not to require the employee to serve the notice period, payment in lieu of notice may be made equivalent to the wages that would have been earned during the notice period.

13.2.2 Termination Due to Performance (Non-Disciplinary)

The Company may terminate employment where an employee has not met the required performance standards for their role.

Performance-related matters are managed under Section 10: Performance Management, which may include performance reviews, coaching, feedback, and a Performance Improvement Plan (PIP).

Where performance concerns are identified, the Company may initiate a PIP to provide a structured opportunity for improvement. The PIP will include clear performance expectations, review timelines, and support measures.

If, after the completion of the PIP process (including any extension where applicable), the employee does not demonstrate sufficient improvement, the Company may proceed with termination of employment.

Termination under this section will be carried out in accordance with the applicable notice requirements under Section 13.2.1: Termination by Notice.

This is not a disciplinary termination and is managed separately from misconduct proceedings under Section 11.

13.2.3 Termination Due to Business or Operational Needs

The Company may terminate employment due to business, operational, or organisational requirements. This includes, but is not limited to:

• business closure or cessation of operations
• relocation or restructuring of operations
• redundancy arising from reduced business needs or reorganisation
• elimination or reduction of job roles or functions
• changes in organisational structure or ownership affecting roles
• employee refusal to accept transfer or relocation where required under contract

Such terminations will be carried out in accordance with applicable law, the employment contract, and the applicable notice provisions under Section 13.2.1: Termination by Notice, based on genuine operational requirements by the Company. 

13.2.4 Termination Without Notice (Misconduct)

Misconduct matters will be handled under Section 11: Disciplinary Procedures, including investigation and due inquiry before any disciplinary decision is made.

Where misconduct is established, the Company may take disciplinary action, which may include:

• summary dismissal without notice
• demotion or reassignment of duties
• other disciplinary measures deemed appropriate under Company policy
  

Examples of misconduct may include, but are not limited to:

• theft, fraud, or dishonesty
• violence, threats, or abusive conduct
• harassment, including sexual harassment or bullying
• reporting to work under the influence of alcohol or drugs
• insubordination or refusal to follow lawful instructions
• gross negligence causing damage, loss, or safety risk

Termination under this section is disciplinary in nature and is separate from performance-related or operational terminations.

13.3 Retirement

H

The compulsory retirement age for all employees is sixty (60) years while the optional retirement age is fifty-five (55) years. The Company may, at its discretion, invite the employee to continue in employment beyond that age. Such an offer, if accepted, will constitute a new contract of employment. All such extension of employment shall be on a fixed basis. 
Q : do we have retirement benefit? 

13.3.1 Mandatory Retirement Age

The mandatory retirement age for employees is 60 years, in accordance with the Minimum Retirement Age Act 2012 (Malaysia).

Employees will normally cease employment upon reaching the mandatory retirement age. The employment relationship shall automatically end on the employee's last working day upon reaching retirement age, unless an extension of employment is offered by the Company.

Upon retirement, employees will be required to return all Company property and complete the necessary clearance procedures in accordance with Company requirements.

13.3.2 Extension of Employment Beyond Retirement Age

The Company may, at its discretion, offer an extension of employment beyond the retirement age.

Any such extension shall be on a fixed-term basis and subject to a separate written agreement. Extension of employment is not automatic and will depend on business needs, role requirements, and mutual agreement between both parties.

13.3.3 Early Retirement

Employees may request to retire early before reaching the mandatory retirement age, subject to mutual agreement with the Company and applicable notice requirements under this Handbook and/or the employment contract.

Unless otherwise agreed in writing, early retirement will be treated as a resignation.

13.3.4 Retirement Benefits & Entitlements

Upon retirement, employees will be entitled to statutory and contractual entitlements (if applicable), which may include:

• salary up to last day of employment
• payment in lieu of notice (where applicable)
• encashment of unused annual leave (subject to Company policy)
• statutory contributions and benefits (e.g. EPF in accordance with EPF regulations)
• any other benefits expressly stated in the employment contract or Company policy

13.3.5 General Principle

The Company does not guarantee any additional retirement benefits unless expressly stated in the employee's employment contract or written Company policy.

All retirement arrangements shall be handled in accordance with applicable laws, contractual terms, and Company operational requirements.

13.4 Redundancy & Retrenchment

13.4.1 General Principle

The Company strives to provide stable employment; however, business circumstances, operational requirements, or organisational restructuring may result in redundancy from time to time. 

In such events, the Company will manage the separation process fairly and in accordance with the Malaysian Employment Act 1955, the Employment (Termination & Lay-Off Benefits) Regulations 1980, and applicable Malaysian labour laws and practices.

The Company will ensure that any redundancy exercise is carried out in a fair and reasonable manner, taking into consideration operational requirements and relevant employment practices.

13.4.2 Notice of Termination

Employees affected by redundancy will be provided with the notice period in accordance with their Letter of Appointment or statutory requirements under the Employment Act 1955, whichever is applicable. 

The Company reserves the right to provide payment in lieu of notice where immediate separation is required due to operational needs.

13.4.3 Statutory Retrenchment Benefits

For employees covered under the Employment Act 1955, termination benefits shall be in accordance with the Employment (Termination and Lay-Off Benefits) Regulations 1980, based on length of service:

For the purpose of this calculation, "wages" refer to the employee's basic salary and fixed contractual allowances, where applicable.

Incomplete years of service shall be calculated on a pro-rata basis.

13.4.4 Exclusions

Statutory termination benefits will not apply in the following circumstances, in accordance with applicable law:

• Termination due to misconduct following due inquiry
• Retirement upon reaching retirement age
• Voluntary resignation by the employee
• Expiry of fixed-term contract (where applicable)
• Mutual separation agreement between the Company and employee

13.4.5 Non-EA Employees

For employees not covered by the Employment Act 1955, any retrenchment or termination benefits (if applicable) shall be governed strictly by the terms and conditions stated in their Letter of Appointment.

13.5 Exit Interview

13.5.1 Purpose

The Company conducts exit interviews to understand employee's experiences, reasons for resignation, and to identify opportunities for improvement in workplace practices, employee engagement, and organisational development.

Exit interviews are intended to support continuous improvement and are not part of any disciplinary process.

13.5.2 Arrangement of Exit Interview

Exit interviews are normally be arranged by the HR department after an employee has signed off the Acceptance of Resignation letter.

The interview is typically conducted on a one-on-one basis between HR and the resigning employee to encourage open and honest feedback.

Where appropriate and with the employee's consent, the Head of Department or other management representatives may also participate in the session.

13.5.3 Conduct of Exit Interview

During the exit interview, HR may ask questions relating to the employee's experience, including but not limited to:

• reasons for resignation
• job satisfaction and work environment
• supervision and management support
• workload, role clarity, and working conditions
• suggestions for improvement

Employees are encouraged to provide honest and constructive feedback. Participation is voluntary, and responses will be treated with respect and professionalism.

13.5.4 Use of Feedback

Feedback collected during exit interviews will be reviewed by the HR department and may be shared in summary form with Management for organisational improvement purposes.

Where serious concerns are raised (including but not limited to workplace misconduct, harassment, safety issues, or policy breaches), the Company may escalate the matter for further review or investigation in accordance with relevant Company policies.

13.5.5 Confidentiality

Exit interview feedback will be handled confidentially and shared only on a need-to-know basis for HR and management purposes.

13.6 Exit Clearance Process

Employees who resign, are terminated, retire, or otherwise cease employment are required to complete an exit clearance process coordinated by the Company.

The process may involve confirmation from relevant departments, including HR, IT, Finance, and the reporting manager, to ensure all Company property, access rights, and employment-related obligations have been properly addressed. 

Employees are required to cooperate with the exit clearance process as part of their separation from employment.

14. Confidentiality & Intellectual Property

14.1 Confidential Information

14.1.1 General Principle

During the course of employment, employees may have access to confidential, proprietary, sensitive, or non-public information relating to the Company, its employees, clients, customers, vendors, business partners, or operations.

Employees are required to protect and maintain the confidentiality of such information at all times and must use such information only for legitimate work-related purposes and authorised Company business.

Confidential information must not be improperly accessed, disclosed, copied, shared, transferred, retained, or used without proper authorisation.

14.1.2 What Constitutes Confidential Information

Confidential information may include, but is not limited to:

• business plans, strategies, and operational information
• financial information, budgets, pricing, and forecasts
• customer, client, vendor, or business partner information
• employee records, payroll information, and personal data
• contracts, proposals, reports, and internal documents
• technical information, systems, software, databases, and processes
• passwords, access credentials, and cybersecurity-related information
• trade secrets, intellectual property, and proprietary materials
• any information designated as confidential or which would reasonably be understood to be confidential in nature

Confidential information may exist in physical, electronic, verbal, visual, or any other form.

14.1.3 Employee Responsibilities

Employees are expected to exercise reasonable care to safeguard confidential information and prevent unauthorised access, disclosure, misuse, loss, or theft.

Employees must:

• comply with Company policies relating to confidentiality, data protection, cybersecurity, and information handling
• only access confidential information where required for authorised work purposes
• store and handle confidential information securely
• avoid discussing confidential matters in public or unauthorised settings
• immediately report any suspected loss, unauthorised disclosure, or security breach involving confidential information

14.1.4 Exceptions

Confidential information does not include information that:

• becomes publicly available through lawful means;
• is disclosed with proper Company authorisation; or
• is required to be disclosed under applicable law, court order, or regulatory requirement

Where disclosure is legally required, employees may be required to notify the Company where legally permissible and reasonably practicable.

14.1.5 Return & Deletion of Confidential Information

Upon resignation, termination, retirement, or upon request by the Company, employees must immediately return or securely delete all confidential information, records, documents, systems access, and Company materials in their possession or control.

Employees must not retain unauthorised copies of confidential information after employment ends.

14.1.6 Breach of Confidentiality

Any unauthorised access, disclosure, misuse, or mishandling of confidential information may result in disciplinary action, legal action, or other appropriate measures by the Company in accordance with applicable laws and Company policies.

14.2 Intellectual Property Rights

14.2.1 Ownership of Work Product

All work, materials, creations, developments, inventions, designs, documents, systems, processes, content, reports, software, presentations, databases, trademarks, concepts, ideas, or other intellectual property created, developed, produced, or contributed by an employee during the course of employment and relating to the Company's business or operations shall belong to the Company, to the extent permitted by applicable law.

This applies whether such work is created individually or jointly with others and regardless of the format or medium in which it exists.

14.2.2 Work Created During Employment

Intellectual property created by employees in connection with their employment duties, using Company resources, confidential information, systems, working time, or business opportunities, shall be deemed to be created for the benefit of the Company unless otherwise agreed in writing.

Employees may be required to disclose such work or developments to the Company where relevant to the Company's business, operations, or projects.

14.2.3 Assignment & Assistance

Employees agree to cooperate with the Company and provide reasonable assistance in relation to the protection, registration, transfer, or enforcement of the Company's intellectual property rights, both during and after employment, where reasonably required. 

This may include signing documents or providing information necessary to confirm or protect the Company's ownership rights.

14.2.4 Employee Pre-Existing Intellectual Property

Any intellectual property independently created by an employee prior to employment, and not related to the Company's business, operations, confidential information, or work duties, shall remain the property of the employee.

Employees must not improperly incorporate personal intellectual property, third-party intellectual property, or unauthorised materials into Company work in a manner that may expose the Company to legal or operational risks.

14.2.5 Use of Company Intellectual Property

Employees must not use, reproduce, distribute, publish, modify, or exploit the Company's intellectual property, branding, materials, systems, or proprietary information for personal benefit or unauthorised purposes without prior approval from the Company.

14.2.6 Survival of Obligations

The obligations relating to intellectual property ownership, protection, and confidentiality under this section shall continue after the employee's employment ends, to the extent permitted by applicable law.

14.3 Post-Employment Obligations

14.3.1 Continuing Confidentiality Obligations

The obligations relating to confidentiality, intellectual property, and protection of Company information under Sections 14.1 and 14.2 shall continue after the termination of employment to the extent permitted by applicable laws.

Employees are required to comply with these continuing obligations after leaving the Company.

14.3.2 Post-Employment Restrictions

The Company recognises that employees are free to pursue employment opportunities of their choice after the end of their employment.

In accordance with Section 28 of the Contracts Act 1950, restrictions that prevent or restrict an individual from engaging in a lawful profession, trade, or business after employment (commonly referred to as “non-compete clauses”) are generally not enforceable in Malaysia.

However, employees remain bound by their continuing obligations relating to confidentiality, intellectual property, and protection of Company interests as set out in this Handbook and their employment contract.

14.3.3 Legal Consequences

Any breach of post-employment obligations may result in legal action by the Company, including claims for damages or other remedies available under applicable law.

15. Data Privacy & Media Consent

15.1 Employee Personal Data & Privacy (PDPA 2010)

15.1.1 General Principle

The Company is committed to handling employee personal data responsibly and in accordance with applicable laws, including the Malaysian Personal Data Protection Act 2010 (PDPA), where applicable.

15.1.2 Collection & Use of Personal Data

The Company may collect, use, process, store, disclose, or retain employee personal data for legitimate employment, operational, administrative, legal, compliance, safety, payroll, benefits, business, or HR management purposes.

Employee personal data may include, but is not limited to:

• personal identification and contact information
• employment and payroll records
• attendance and performance-related information
• emergency contact information
• statutory contribution and taxation records
• health, safety, or medical-related information where relevant
• other information reasonably required for employment administration or business operations

15.1.3 Access, Disclosure & Protection

Access to employee personal data will be restricted to authorised personnel on a need-to-know basis, including HR, Management, authorised departments, or appointed service providers where necessary for legitimate business or operational purposes.

The Company will take reasonable and appropriate measures to safeguard employee personal data against unauthorised access, misuse, disclosure, alteration, loss, or destruction.

Where reasonably necessary for legitimate business, operational, legal, regulatory, or administrative purposes, the Company may disclose employee information to authorised third parties, regulatory authorities, professional advisors, service providers, insurers, or statutory bodies in accordance with applicable laws and business requirements.

15.1.4 Employee Responsibilities

Employees are expected to provide accurate and updated personal information to the Company and to promptly notify the Company of any material changes to their personal data where relevant.

Further employee responsibilities relating to confidentiality, information handling, and data protection are set out under Section 7.3: Confidentiality & Data Protection

15.2 Privacy & Media Consent

15.2.1 Use of Media Content

The Company may capture or use photographs, videos, audio recordings, or other media content that may include employees during the course of work, Company events, training sessions, meetings, or other work-related activites.

Such media content may be used for internal purposes (including communication, training, and documentation) as well as external purposes such as marketing, branding, recruitment, and social media publications.

15.2.2 Purpose & Company Rights

The Company will ensure that the use of media content is appropriate and consistent with business and organisational needs.

All media content created in the course of employment and in connection with Company activities shall remain the property of the Company, unless otherwise stated.

15.2.3 Employee Participation & Consent

Where practicable, employees may be informed in advance when media content is being captured for external use.

Employees who do not wish to appear in externally published media content may notify the Company in writing. The Company will take reasonable efforts to accommodate such requests where operationally feasible.

However, employees acknowledge that in group, event-based, or workplace settings, complete exclusion may not always be practical.

15.2.4 Conduct in Media Activities

Employees are expected to maintain professionalism when participating in Company-related media activities.

Employees must not misuse, reproduce, or distribute Company media content for personal or unauthorised purposes without prior approval from the Company.

16. Whistleblowing Policy

16.1 Purpose & Scope

16.1.1 Purpose of the Whistleblowing Policy

The Company is committed to maintaining high standards of integrity, accountability, ethical conduct, and compliance in its business operations and workplace practices.

The purpose of this Whistleblowing Policy is to provide a channel for employees and other relevant parties to raise genuine concerns regarding suspected misconduct, unlawful conduct, unethical behaviour, or serious improper practices affecting the Company, its employees, stakeholders, or operations.

This policy is intended to encourage reporting in good faith and to support the early identification and appropriate handling of serious concerns.

16.1.2 Scope of Reportable Matters

Matters that may be reported under this policy include, but are not limited to:

• fraud, theft, or dishonesty
• corruption, bribery, or abuse of authority
• serious breaches of Company policies or procedures
• unlawful, unethical, or improper conduct
• harassment, discrimination, or workplace misconduct
• conflicts of interest or misuse of Company resources
• financial irregularities or falsification of records
• serious safety, health, or environmental concerns
• retaliation against individuals who raise concerns in good faith
• attempts to conceal any of the above matters

16.1.3 Relationship with Other Company Processes

This Whistleblowing Policy is separate from the grievance handling process under Section 12: Grievance Handling, which generally relates to personal workplace concerns or employment-related dissatisfaction.

Where appropriate, the Company reserves the right to redirect or manage matters under the relevant Company policy, procedure, or investigation process.

16.1.4 Good Faith Reporting

Individuals making whistleblowing reports are expected to act honestly, responsibly, and in good faith.

Whistleblowing reports should not be used to make knowingly false allegations, personal attacks, malicious accusations, or reports intended to harass, retaliate against, or improperly harm another individual.

Any abuse of the whistleblowing process may result in disciplinary action or other appropriate measures by the Company.

16.2 Reporting Channels & Whistleblowing Mechanism

16.2.1 Reporting Channels

Employees and other relevant parties are encouraged to report whistleblowing concerns through appropriate reporting channels as soon as reasonably practicable.

Reports may be made through one or more of the following channels, where appropriate:

• HR
• the employee's supervisor or Head of Department
• Management or authorised Company representatives
• designated whistleblowing or confidential reporting channels established by the Company
• other reporting channels determined by the Company from time to time

Where the concern involves the employee's supervisor, department, HR personnel, or any individual who may present a conflict of interest, the report may be raised through an alternative reporting channel.

16.2.2 Form of Report

Whistleblowing reports may be raised verbally or in writing. However, depending on the nature or seriousness of the matter, the Company may require the report to be documented in writing to facilitate proper review, investigation, and recordkeeping.

Where possible, the reporting individual is encouraged to provide relevant details or supporting information available to assist the Company in understanding and reviewing the matter appropriately.

16.2.3 Anonymous Reports

The Company may accept anonymous reports where sufficient information is provided to allow reasonable review or investigation of the matter.

However, anonymous reports may limit the Company's ability to conduct a full investigation, obtain clarification, or provide updates regarding the outcome of the matter.

16.3 Confidentiality & Protection Against Retaliation

16.3.1 Confidential Handling of Reports

The Company will handle all whistleblowing reports in a confidential and discreet manner.

Information relating to a whistleblowing report will only be disclosed to individuals involved in the review, assessment, or investigation process on a strict need-to-know basis.

The Company will take reasonable steps to protect the identity of the reporting individual (whistleblower), where possible and appropriate.

However, confidentiality and anonymity may not be fully guaranteed where:

• disclosure is required by law or regulatory authorities
• disclosure is necessary for a fair and proper investigation
• disclosure is required in legal proceedings or enforcement actions

In such circumstances, the Company will limit disclosure to what is strictly necessary and reasonable.

16.3.2 Protection Against Retaliation

The Company strictly prohibits any form or retaliation against individuals who raise whistleblowing concerns in good faith or who participate in any related investigation.

Retaliation includes any direct or indirect adverse action, including but not limited to:

• intimidation, harassment, or victimisation
• discrimination or unfair treatment
• demotion, dismissal, or disciplinary action
• reduction in duties, benefits, or opportunities
• any other act that may negatively affect employment conditions

Any employee found to have engaged in retaliation will be subject to disciplinary action, up to and including termination of employment.

16.4 Review, Investigation & Outcome Process

16.4.1 Initial Review of Report

Upon receipt of a whistleblowing report, the Company will conduct an initial assessment to determine:

• whether the matter falls within the scope of this Whistleblowing Policy
• the seriousness and urgency of the issue raised
• whether immediate action is required to protect individuals, assets, or operations
• the appropriate channel or team to handle the matter

The Company reserves the right to reclassify or redirect the matter under other Company policies where appropriate (including disciplinary procedures, grievance handling, or operational review processes).

16.4.2 Investigation Process

Where necessary, the Company may initiate a formal or informal investigation depending on the nature and severity of the report.

An investigation may include, where appropriate:

• interviews with the reporting party and relevant individuals
• collection and review of documents, records, or communications
• review of relevant systems, transactions, or evidence
• consultation with relevant departments (e.g. HR, Finance, Operations, IT)
• engagement of external parties (where required for independence or expertise)

Investigations will be conducted in a fair, objective, and impartial manner. The investigation may be conducted by HR or any designated internal or external investigator appointed by the Company.

The Company may adjust the scope or approach of the investigation depending on operational requirements or the seriousness of the matter.

16.4.3 Interim Measures

Where necessary, the Company may implement interim measures during the investigation to protect individuals, preserve evidence, or safeguard business operations.

Such measures are generally applied to the individual(s) subject to the allegation and may include:

• temporary reassignment of duties
• administrative suspension (in accordance with Company policy and applicable law)
• restriction of access to systems, premises, or information
• other operational controls deemed necessary by the Company

In appropriate circumstances, interim measures may also be applied to other relevant parties (including the whistleblower or witnesses) only where necessary to prevent retaliation, protect safety, or maintain the integrity of the investigation, and such measures must not be punitive in nature.

All interim measures are precautionary in nature and do not imply any determination of wrongdoing.

16.4.4 Investigation Outcome

Upon completion of the investigation, the Company will determine the appropriate outcome based on the findings.

Possible outcomes may include, where applicable:

• no further action required
• recommendation for process or policy improvements
• coaching, counselling, or corrective action
• disciplinary action under Section 11: Disciplinary Procedures
• referral to external authorities or regulators where required
• other corrective or preventive measures deemed appropriate

The Company will ensure that outcomes are handled in accordance with applicable laws, internal policies, and principles of fairness.

16.4.5 Communication of Outcome

Where appropriate, the Company may provide feedback or general updates to the whistleblower regarding the status or outcome of the investigation.

However, the Company may not disclose detailed findings or specific disciplinary actions due to confidentiality, privacy, or legal restrictions.

16.4.6 Record Keeping

The Company may maintain records of whistleblowing reports, investigations, and outcomes for governance, compliance, and operational purposes.

Such records will be stored securely and accessed only by authorised personnel.

17. Amendments & Management Rights

17.1 Right to Amend Policies

The Company reserves the right to review, amend, update, modify, suspend, replace, or remove any policies, procedures, rules, practices, benefits, or provisions contained in this Handbook from time to time, subject to applicable laws and operational requirements.

Such amendments may be made where necessary to:

• comply with changes in applicable laws or regulatory requirements
• reflect operational, business, technological, or organisational changes
• improve workplace practices, governance, or compliance standards
• address evolving business or workforce needs

Where appropriate, the Company may notify employees of material changes to the Handbook or related policies through internal communication channels, updated policy documents, employee briefings, or other reasonable methods determined by the Company.

Employees are expected to familiarise themselves with and comply with the latest version of the Handbook, policies, and procedures issued by the Company.

17.2 Interpretation of the Handbook

The Company reserves the right to interpret, manage, and apply this Handbook in a reasonable manner based on applicable laws, operational requirements, and business needs.

Where there is any uncertainty, ambiguity, omission, or dispute regarding the meaning or application of any part of this Handbook, the Company reserves the right to determine the appropriate interpretation or action, subject to applicable laws.

The Company may apply this Handbook differently depending on the circumstances, operational needs, employee role, or other relevant factors, where reasonably appropriate.

Nothing in this section limits any employee rights or protections provided under applicable laws.

17.3 Non-Contractual Clause

This Handbook is intended as a general guide to the Company's policies, procedures, and workplace practices. It is designed to provide employees with information on how the Company typically manages employment-related matters.

Unless expressly stated otherwise in writing or in an employee's employment contract, the contents of this Handbook do not form part of an employee's employment contract and should not be interpreted as creating contractual rights or obligations beyond those required under applicable laws or expressly stated in an employment contract.

The Company may update, amend, or withdraw any part of this Handbook from time to time in accordance with Section 17.1: Right to Amend Policies. 

Nothing in this Handbook shall override any rights or obligations provided under applicable Malaysian laws or the terms of an employee's individual employment contract.

18. Acknowledgement by Employee

18.1 Employee Declaration

I, ___________________________________ NRIC/Passport : _____________________________ acknowledge that I have received, read, and understood the KIAN/Lynch Pin Holdings Sdn Bhd Employee Handbook.

I agree to comply with the terms and conditions of my employment and the policies set out in this Handbook, as amended from time to time, upon notification by the Company.

Signature       :

Designation   :

Company       :

Date               :

Note : The Company reserves the right to amend, add, modify, or remove any part of this Employee Handbook from time to time, subject to applicable laws and operational requirements. Employees will be notified of material changes through appropriate communication channels. Employees are required to comply with the latest version of the Employee Handbook issued by the Company.