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Our Policies

Myanma Awba Group recognises its role as a responsible corporate citizen.With over 20 years’ track record of rural community building and investing in shared value initiatives in villages across the country, the Group is fully compliant with the tax laws of the Union of Myanmar. Our accounts are audited by internationally-recognised ‘Big Four’ companies and the Group has consistently been identified as a top taxpayer in Myanmar.

A number of our corporate policies can be accessed by clicking the buttons below:

Employee
Handbook
Employee
Handbook
Health and
Safety Policy
Health and
Safety Policy
Code of
Ethics
Code of
Ethics
Environmental and
Sustainability Policy
Environmental and
Sustainability Policy
Anti-Bribery and
Anti-Corruption Policy
Anti-Bribery and
Anti-Corruption Policy
Related Party
Policy
Related Party
Policy
Advisory Board
Charter
Advisory Board
Charter

Employee Handbook

GENERAL POLICIES & GUIDELINES

1. Basic Ethics

The employee shall comply with the following basic ethics.

a. Perform duties and responsibilities with due diligence, integrity, honest and ethical manner

b. Comply with all applicable laws, rules and regulations

c. Give priority to act in the company’s best interests and fulfill your fiduciary obligations to the company

d. Employee shall carry out the assigned duties strictly and carefully

e. Keep trying continuously to improve skill and ability

f. Carry out assigned duties given by immediate superior in timely manner

g. Don't waste company resources

h. Avoid immoral and ignobly in the work place

i. Employees shall not fail to discharge their duties within scheduled working hours without any reason

j. Avoid creating disunity and dispute amongst staffs

k. Employees shall not fail to discharge their duties within scheduled working hours without any reason

l. Employee shall prevent the confidential information and documentations of company, knowing the job security.

m. Employees are not allowed to do anything for their own interest by misusing power and mandate

n. Always act in a manner to enhance and maintain the reputation of the Company

o. Do not involve in illegal act or committing offences against to the existing law


2. Rules and Regulations for Disciplinary Actions

a. Arriving office late without any sound reason

b. Disrespecting superior officers verbally or by gesture

c. Serving duties without due diligence and care

d. Wasting office time and leaving office during working hours

e. Embarrassing or degrading other office staff with or without intention

f. Sleeping at workplace

g. Not allowed to invite or meet any guest during working hour

h. Smoking and chewing betel squad in workplace

i. Don't stay near and behind at running machine

j. Don't running and playing around the work place

k. Leaving office early before the end of office hours

l. Staffs from marketing department shall cooperate with auditors from Legal Department and Account Department when invited to audit, and anyone who fails to do so shall be taken action


3. Attendance

a. The employee is expected to report to work regularly and on time.

b. In those instances when you cannot avoid being late for work or are unable to work as scheduled, the employee must notify your departmental head within the first hour of the workday, barring extenuating circumstances that make such notification impossible or extremely difficult.

c. Poor attendance and/or excessive tardiness may lead to disciplinary action, up to and including termination of employment.


4. Working Hours

a. Working hours for office staff

- From Monday to Friday: 9 am to 5pm - Saturday: 9 am to 12 Noon

b. Working hours for factory staffs

- From Monday to Friday: 8 am to 5 pm, Lunchtime: 12 Noon - 1 pm - Saturday: 8:00 am to 12 Noon

c. The regular working hours, which are specified for an employee, shall not exceed forty four hours per week and eight hours per day.

d. Employees are allowed to take one hour break or the time for lunch on the normal work days. The employees must not work five hours continuously. The working hours and break time (rest) must not exceed 10 hours.

e. Regarding the company with the nature of business, which requires continuous working, the working hours shall not exceed continuously forty-eight hours per week.

Remark:

(1) In case of specifying the particular working hours according to work which by its nature or condition, may be specified by the agreement between company and employee.

(2) In case of changing the working hour by its nature or condition, shall notify in advance to the relevant township/ district Factories and the General Labor Laws Inspection Department.


5. Holidays

Holidays are gazette holidays, Sundays and the hours after 1pm on Saturdays. If an employee is assigned to work on the holidays, one day of off day within three days before and after the assigned must be allowed.


6. Travel & Business Expenses

The company shall provide the following matters for travelling to the local and abroad with the duty. The following travel allowances are entitled if an employee is sent on a domestic trip assignment.

(a) Travelling Expense

- Actual airfare if the place the employee has been assigned is accessible only by plane. - Actual cost of the most reasonable mode of travel if the township of assignment can be reached by train, bus, and boat

(b) Uniform Expense (Only for Travelling abroad)

(c) Accommodation Expense

(d) Meal Allowance

(e) Fuel Allowance for company own car


7. Social Security Board

Social security fee paid by both of an employer and a worker is as follows. The rate of burden is determined depending upon the amount of the monthly wage of the worker.

a. The employees are entitled to security benefits according to law. The monthly fees for social security will be deducted by the employer (the company HR department) from the salary of each employee every month and pay them at the Social Security Department (the government).

b. The employees are entitled to get medical treatment at Social Security Clinic if he or she is sick or injured. The employee (worker) must inform operational manager about taking medical leave. Getting medical treatment is according to social security law prescribed by the government. It is the operational manager's decision to recognize medical certificates issued by private medical doctors.


8. Income Tax

Income tax must be paid if the annual total salary is more than K20 lakhs after basic allowance, allowance for spouse, allowance for sons and daughters, premium fees for life insurance, fees for social security funds have been deducted and the income tax will be calculated according to the Income Tax Law enacted on 1-4-2014.


9. Worker Compensation for Work-related Injury

Worker compensation is a legal remedy that covers medical expenses and wage loss for employees who have been injured in the course and scope of their employment. The employee must report any work-related injury or illness to the supervisor immediately reports his/her injury directly to the Company HR. All employee work injuries/illnesses should be reported within 24 hours from the time a claim/incident occurs. If an employee is medically unable to report his/her claim, their supervisor should call the emergency contact number to report on their behalf. The company will provide for the costs of medical treatment for injuries and accidents caused while on duty. For employees who have been injured, the company will pay the benefits gained by SSB insurance and group life insurance.


10. Overtime Allowance

a. When the company makes an employee work exceeding working hours stipulated by the laws, the company shall pay double the basic hourly payment rate as allowance for overtimes.

b. The overtime pay shall be calculated and paid according to the specifications of the relevant law.

c. In case of overtime on Gazette holidays, wage shall pay double the basic salary rate.

Calculation method for wage payment rate mentioned is provided by the Ministry of Labor as the figure 1 below. Figure 1: Calculation method of overtime allowance for monthly salaried employees Monthly basic wage * 12 months *2 = Overtime allowance per hour 52 weeks * 44 hours (working hours per week)


11. Types of Leave

The following types of leaves are allowed for the employee so that he or she could be convenient for social affairs. But, staff shall exactly follow terms and conditions related with taking leave not to have any negative effect on office duties.

a. Earned Leave

An employee who has served in the company for a year continuously from the day receiving employment contract (probation) is eligible for 10 days of earned leave a year.

* The employee is entitled to 10 days of earned leave with full salary (pay).

* If the employee is ill while on earned leave, the company will not change that type of leave to medical leave.

* Employee can take earned leave and medical leave consecutively together.

* Earned leave is entitled within a year and cannot be saved or carried over for the next year.

* Employees are not allowed to take earned leave as a right.

* The employee can submit leave application form to departmental head and/or HR department in person or via email at least one day ahead for short term leaves ( 1- 3 days)and one week ahead for long term leaves (above 3 days).

b. Casual Leave

Any employee is entitled to take 6 days of casual leave with full salary (pay) since probation.

* Casual leave is allowed to be used only in emergency matters.

* Not more than 3 days of casual leave can be taken at a time per month.

* Casual leave can't be combined with other types of leave.

* The employee can inform about the leave in writing or by phone for emergency case and it can cover only when the staff shows evidence.

* If the employee does not take casual leave in the year, the leaves cannot be added in the following year.

* If it is necessary to take leave in emergency, the employee shall inform the department head concerned in two hours after leaving office so as to transfer the duty to someone else.

c. Medical Leave

An employee who has completed six months of service in the company, he or she can apply for medical leave presenting medical certificate.

* Employees are entitled to take 30 days of medical leave in a year with full salary (pay).

* But for employees with less than six months service, medical leave can be taken without salary.

* If it is necessary to take medical leave, the employee shall submit leave application with attached official medical certificate issued by a relevant medical doctor.

* Under an emergency situation which requires hospitalization, it can cover medical leave only if the employee can present medical certificate on the day when the employee resumes duties.

* If it is necessary, the employee can take medical leave together with earned leave under the approval of the departmental head and head of HR.

* If it is necessary to take medical leave more than 30 days for the situation of severely bad health condition, the employee is allowed to add earned leave, or if there is no more earned leave, without pay leave will be allowed.

* If an employee needs to take medical leave for more than 100 days, it is necessary to apply to the departmental head and head of HR with solid reason. Head of HRwill present to management team to allow medical leave in excess of 100 days.

* If an employee takes medical leave for more than 100 days without permission, the company will suspend employment contract and the day on which the employee resumes duties will be deemed as the first day of the employment contract.

d. Maternity/Paternity Leave

(i) Permanent female employee can take 98 days of maternity leave according to amendment law for 1951 Leave and Holiday enacted on July 19, 2014. According to the law, female employee is entitled to take maternity leave with payment for six weeks (42days) before the childbirth and eight weeks (56 days) after the childbirth. The maternity leave can take along with medical leave.

* Maternity leave can be taken with full salary (pay).

* If it is necessary, maternity leave can be taken along with earned leave with the approval of head of department.

* After childbirth, birth certificate must be presented to HR department.

* Gazette holidays and off-days during the maternity leave cannot be replaced later.

(ii) Permanent male employee who has been engaged himself at his own expense in benefit from social security board (SSB)is entitled to take 15 days of paternity leave to take care of wife and infant. Incomplete Miscarriage For miscarriage occurred in less than 24 weeks of pregnancy can be allowed maternity leave for the numbers of days the doctor recommended. But, it must not be more than four weeks. Note: To prevent against cases of claiming maternity leave soon after joining the office

* Not to hire pregnant women for the work place that needs physical labour and to consider hiring the women employees six weeks after delivery of birth.

* The pregnant women with her due date four months away, can be hired for the workplaces that do not need to use physical labour. But the company should hire her only after six weeks after her childbirth.

* The new women employee is required to make a written pledge that she joins the company after six weeks of delivery.

The new women employee is not entitled to take maternity leave due to her false statement in written pledge and only leave without pay shall be taken.

e. Marriage Leave

Permanent employee is entitled to take marriage leave 7 days for the first time on his or her special occasion. Employee shall attach the sound evidence of marriage in his or her leave application.

f. Compassionate Leave

It is a kind of leave the company allows the employees with sympathy if a staff’s family member (parents, spouse, children and siblings) pass away. If parent, spouse, or children of a permanent employee dies, 7 days of compassionate leave is allowed. But, he or she lost a sibling; the company allows 3 days of compassionate leave. The employee needs to attach relevant evidence in leave application. That leave can’t be combined with earned leave.

g. Leave without Pay

Leave without pay is a kind of leave the company has allowed its employee taking leave if the paid leaves are run out. An employee is entitled to take maximum 30 days of leave without pay within a year in addition to casual leave and other leaves. Especially, the leave can be taken under the approval of departmental head. The decision to grant the leave depends on the workload. If an employee wants to take leave without pay for more than a month, he or she shall inform departmental head and HR one month in advance. The leave can be taken only when the employee gets the approval from departmental head. In taking such kind of leave, the period in excess of 30 days are not calculated in the duration of service of the employee. Any employee is not allowed to take more than 30 days of leave without pay as a right.

h. Leave for exam

(a) Employees are entitled to take leave for their exam and the company will not grant separate leave for it. If there is not enough leave, the staff can take leave without pay. (b) Employee shall take long term leave for exam even if it does not effect on work. Exam leaves are set as follows; (b-i) Sitting for examination for Distance Education

Those who have been registered for Bachelor of Arts degree course, they are allowed to take leave for 10 days before the examination until the completion of the examination. Those who have been registered for Bachelor of Science degree course, they are allowed to attend class on Saturday and entitled to take leave starting from a day before the examination until the completion of the examination. (b-ii) Sitting for examination of the training sent by the company at company cost

a) The examination days of the training sent by the company will be deemed as on-duty days.

If the employees want to take leave for preparation prior to exam date, the employee can take leave granted to them. If the leave is not adequate, they can take leave without pay.

i. Absent

If an employee does not come to work without applying leave or an employee fails to resume his or her duty even though the leave period is ended without solid reason, it shall be deemed as absent from work and the following action shall be observed;

a. If an employee did three consecutive days of absent or three times of absent, the employment contract shall be ceased automatically.

b. The continued absence after the entitled leave period shall be deemed as absent. Salary won’t be paid for absent days.


12. Computer Access and Use

Employees shall follow terms and conditions over computers mentioned below:

(a) Employees are allowed to observe computer programs and company’s data in it only with the permission of the company management.

(b) Employees are not allowed to transfer data and information related with the company by CD, DVD, memory stick and other things without permission from the company.

(c) Employees are not allowed to copy or download data of other departments without permission. All employees are responsible for safe and secure maintenance of company data in relation to respective job function.

(d) According to the company’s IT policy, all employees must not be used by personal Gmail account. All employees must use only the company domain account for correspondence of company business matter. Using personal Gmail for office correspondence is a major offence.

(e) The resigning employee needs to give back the company's computer and IT related software, documents, email accounts, and password to the supervisor manager on the last day of his or her day at the company.

(f) Computer software and other intellectual property protected by copyright may not be copied from, into, or by Company computing facilities, except as permitted by law, or by

(g) The unauthorized downloading or transferring of copyrighted materials, including movies, video games, software, music, and using social media for personal interest is not permitted and may subject an offender to company disciplinary action.


13. Access to Employee Personnel Files

Staff salaries, personnel data, and all aspects of Company affairs are confidential and have not been released as public information. HR department will review and update employee personal data once a year. If the head of concerned department and employee wishes to review or update the staff personal data, he/she may also request and inform HR department.


14. Breaking Rules Leading to Contract termination

If a staff member is found guilty of breaking or abetting the acts mentioned below, the company can terminate his or her employment contract.

a. Committing theft or misusing company owned properties

b. Committing to staff any harm, molest and quarrel.

c. Do not follow the announcement of explosive place

d. Across the prohibit place without permission.

e. Doing divisively, factional and don't cooperate within staff

f. Doing to stop the working process by aim

g. Doing coercion, disservice and disobey to supervisor

h. Committing bet by money at work

i. Doing crowd and making meeting without permission

j. Committing to illegitimately activism

k. Drink alcohol during office hour and do not come to office drank alcohol

l. Break and not follow the rule of safety and security

m. Don't do accusatory to someone who is involvement with work

n. Applicant make mention wrong data or cheating bio data or not honestly

o. Sharing secret data & news of company to strange person

p. Destroy and carless keep the very important data of company

q. Taking and keeping the things of company or colleague without permission

r. Smoking & Lighter taking to prohibit area.

s. Bully & blame to each of the staff

t. Signing to on behalf of someone at attendant and making forgery voucher

u. Taking illegal things to office and company owned facilities

v. Taking arms to the office

w. Committing a major crime against to morale

x. Accepting or abetting or involving in bribery

y. Unauthorized copying or distributing or leaking the company's confidential facts, records, financial data and commercial contracts without any permission

z. Fail to appear at office for three consecutive days without taking leave without informing and/or having approval of supervisor.

aa. Get imprisoned by any criminal offences


15. Severance Pay for Termination of Employment

(a) The company can provide reasonable amount of payment for the employees who resign for own personal reason in consideration of the efforts the employees have contributed to the company.

(b) The company has no responsibility to provide any payment to the employees who were removed due to the breaking of company regulations 

(c) The employees are entitled to the following benefits if the company issues an order of termination due to certain business situations of the company. 

  • i) An Employee who has worked for an uninterrupted period of more than 6 months but less than 1 year shall receive severance pay of no less than the late rate of wages for 0.5 month. 
  • ii) An Employee who has worked for an uninterrupted period of more than 1 year but less than 2 years shall receive severance pay of no less than the late rate of wages for 1 month. 
  • iii) An Employee who has worked for an uninterrupted period of more than 2 years but less than 3 years shall receive severance pay of no less than the late rate of wages for 1.5 month. 
  • (iv) Am Employee who has worked for an uninterrupted period of more than 3 years but less than 4 years shall receive severance pay of no less than the late rate of wages for 3 month. 
  • v) An Employee who has worked for an uninterrupted period of more than 4 years but less than 6 years shall receive shall receive severance pay of no less than the late rate of wages for 4 months. 
  • vi) An Employee who has worked for an uninterrupted period of more than 6 years but less than 8 years shall receive severance pay of no less than the late rate of wages for 5 months. 
  • vii) An Employee who has worked for and uninterrupted period of more than 8 years but less than 10 years shall receive severance pay of no less than the late rate of wages for 6 months. 
  • viii) An Employee who has worked for an uninterrupted period of more than 10 years but less than 20 years shall receive severance pay of no less than the late rate of wages for 8 months. 
  • ix) An employee who has worked for an uninterrupted period of more than 20 years but less than 25 years shall receive severance pay of no less than the late rate of wages for 10 months. 
  • x) An employee who has worked for an uninterrupted period of more than 25 years and upwards shall receive severance pay of no less than the late rate of wages for 13 months.


16. Employee Social welfare Assistance for the family of employees means the employees having families (living together) like

  • Man employee himself and wife, sons and daughters
  • Woman employee herself, her husband, sons and daughters

For unmarried employees, the employee and his or her two parents are entitled under this policy (adopters and guardians are not entitled). The company's financial assistance for the employees shall be used as social assistance (for marriage and death). Whatever the assistance may be, it must be used according to the company's policy. Any variations or discrepancies from these policies shall be decided by the management. (The decisions shall be effective from this meeting and the previous cases shall not be relevant). Permanent employees are entitled to company's social welfare assistance.

(a) Assistance for wedding ceremony

-The ceremony must be the wedding of an employee -The assistance is given for the first time wedding of an employee -The wedding of sons and daughters of an employee is not relevant -The assistance is categorized as follows: Manager level - K500,000 Assistant manager level -K300,000 Supervisor level -K200,000 Ordinary staff -K100,000

(b) Compensation on death of an employee

The company will provide compensation as mentioned below if an employee (staff) and/or family member dies;

* Employee - K500, 000

* A family member of an employee - K300, 000

(1) Appointment letter or employment contract certifying that the dead person is an employee

(2) Death certificates (photo copy) shall be presented to the company in order for the company to give compensation

(c) Assistance for a new born baby

The company will provide assistance for the employee for the birth of baby. The assistance for the employee who gets a new baby is set as K100,000 for those whose salary is lower than K200,000.

(d) Assistance for the family of employee affected by natural disaster

The natural disaster must affect many other people. The crisis must affect the livelihood of the family of the employee living together. The amount of assistance will be based on the damages caused by the natural disaster.

(e) Assistance for the health of employee family

The company will consider the medical assistance for employee and family members for hospitalization and getting medical treatment depending on the severity, condition and type of diseases.

(f) Assistance for education of sons and daughters of employee

The educational assistance is entitled for the sons and daughters of employees whose salary is K200,000 and lower. Basic educational assistance is prescribed as follows. Primary Grade (1) to (5) - 20,000 Kyats Secondary Grade (6) to (9) - 30,000 Kyats High SchoolGrade (10) to (11) - 40,000 Kyats Requirements for Educational Assistance

  • employees whose salary is K200,000 and lower
  • Only permanent employees are entitled to the assistance
  • Only one employee can get the assistance (If father getsthe assistance, mother cannot get)
  • All students of a family can get the assistance
  • The assistance is not entitled to those who fail the exam in previous year (Not allowed to those who are the same class in previous and current list)
  • Submit the correct list of student. If incorrect list is found, company will suspend the assistance for the next (3) years.

Health and Safety Policy

Health & Safety Manual

Chapter 1-General

1. General

1.1 Purpose

1.1.1 This manual provides guidelines for the preparation of a company's safety and health system

1.1.2 The objectives of this manual are to

a) highlight the important aspects of safety and health protection to assist company in planning implementing and auditing management system in order to satisfy company, legal and social obligations and

b) Assist to put in place safe work practice and management system to enhance their safety performance.

1.2 Scope

The procedures in this manual are applicable to product development, procurement, manufacture, sales, transport, use and disposal of agrochemicals produced by the company.

1.3 Responsibility

1) Managing Director (All Business Units)

2) Directors (HSE)

3) Managers

4) GM

5) Supervisors

6) Staffs

7) Factory Labors

1.4 Forms and Reference

a) Occupational Safety and Health Assessment Series 18001

b) OHSA PPE

1.5 Procedure- General

1.5.1 The structure of this manual is similar to that of the above standards which are representative of Safety and Health Management Systems.

1.5.2 Similar to these standards, the Plan-Do-Check-Act continual improvement framework has been adopted for this manual.

1.6 Promoting Safety Culture in workplace

1.6.1 It is the responsibility of the top management to provide all assistance to the HSE duty officer in order that they are able to promote workplace safety culture.

1.6.2 The HSE personnel must endeavor to maintain a good working relationship with all staff members.

1.6.3 This can be done by involving all employees in toolbox meeting, regular inspection, and by actively considering and acting upon the feedback given by them.

1.6.4 Where HSE Officers observes lapses in safe working practices, he must be consulted & implemented.

1.6.5 Risk assessment and guidance provided in this Manual must be consulted & implemented.

1.6.6 Behavior based safety must be promoted in workplace.

1.6.7 Health and safety standards of the company can be significantly enhanced by increasing awareness and highlighting benefits of safe work practices.

1.7 Reporting

1.7.1 The employee is required to the HSE Department in case of following occurrence:

a) Occupational injuries, accidents

b) Unsafe conditions at work

c) Any injury that renders a worker unfit for more than 3 days

d) Hospitalization of an employee for over 24 hours

1.8 Housekeeping

1.8.1 Good housekeeping is a basic requirements that promotes and maintains the work environment and employee in a healthy and safe condition.

1.8.2 Cleanliness standards must be maintained at a high level.

1.8.3 All ventilators/dampers must be stenciled with name of space they service.

1.8.4 Offices, production lines, warehouses, toilets & washrooms must be kept clean, inspected weekly and results logged.

1.9 Related Documents/Forms

* Weekly HSE Inspection Checklist

* Monthly HSE Monitoring Report


2.0 Hazard Identification & Risk Assessment

2.1 Purpose & Scope

This procedure is applicable to

1) address the risks and opportunities as determined

2) Assess the risk from chemicals or processes at workplace

3) Implement Control actions to eliminate or reduce the risk.

2.2 Responsibilities

2.2.1 All managers are responsible to participate in identifying the hazard associated with their work-related process.

2.2.2 The Regular Meeting body shall review the significant risks and impacts at management review meeting and shall consider the various control measures to eliminate or reduce the risk..

2.3. Hazard ID & Risk Assessment

2.3.1 Risk Assessment

a) A 'Risk Assessment' is intended to be a careful examination of what, in the nature of operation, could cause harm, so the decisions can be made as to whether enough precautions have been taken or where more should be done to prevent harm. The aim is to minimize accidents and ill health at workplace.

b) Risk assessment should be seen as a continuous process. In practice, the risks in the workplace should be assessed before work begins on any task.

2.4 Identify the Hazard

2.4.1 Answers to following sample questions will assist

2.4.2 Who or what could be harmed

2.4.3 How could harm occur?

2.5 Determine the Risk

2.5.1 The risk from the hazard is determined by estimating

a) The potential severity of the harm

b) The likelihood that harm will occur

2.5.2 When determining the likelihood of harm the adequacy of control measure already in place shall be considered.

2.5.3 Thus, if a proper procedure is followed harm is less likely to occur.

2.6 Decide if the risk is tolerable

2.6.1 If the risk is tolerable, additional safety precaution will need to be taken.

2.6.2 On a practical level, whenever a task is being given the person giving the tasks must evaluate the risks and determine what safety precautions need to be taken

2.6.3 It is a good practice to discuss the safety precautions prior starting of a task, even if the persons carrying out the task are experienced personnel. It reduced the likelihood of accidents considerably.

2.7 Types of Hazards

A hazard is a source of potential harm or damage or a situation with potential for harm or damage. Hazard encountered in workplace may be the following;

a) Chemical hazards

b) Physical hazards

c) Biological hazards

d) Ergonomic hazards

e) Psychological hazards

2.8: Please review diagram in full policy

2.9: Existing Risk Control

Risk Control is the process of determining the best available means of implementing measures whereby the likelihood and/or the severity is reduced. The preferred means is to eliminate the hazard in the first instance. Where this is not possible, the risk posed by the hazard must be minimized

2.9.1 Elimination- elimination of toxic substances, hazardous plant or processes that are not absolutely necessary to the system of work

2.9.2 Substitution- Substituting a toxic substance, hazardous plant or process with one known to be harmful to health. Substitution is only a preferred control method. It may also be the least expensive.

2.9.3 Isolation- enclosing or isolating a hazard such as a toxic substance, plant or process from employees, to eliminate or reduce the risk of injury or illness. Using a noise enclosure booth is an example of separating employees from excessive noise levels.

2.9.4 Engineering Controls- changing processes, equipment or tools for example

a) machine guards and machine operation controls,

b) Changing layout of work areas to minimize bending and twisting during manual handling

2.9.5 Administrative Controls- changing work procedures to reduce exposure to existing hazards. For example:

a) Reducing time of exposure to hazards by job rotation

b) Limiting the number of employers exposed to the hazard by limiting access to hazardous area.

2.9.6 Personal Protective Clothing (PPE)

Devices and clothing that provide individual employees with some protection from hazards. All effective protective clothing and equipment system requires considerable effort by the employer to ensure that:

a) proper protective devices are selected

b) where necessary, employees are individually fitted.

c) proper instruction on the need for, and use of PPE is provided.

d) standards are enforced

e) an effective system of cleaning and maintenance is devised.

Further down the scale controls, the risk still exists. Administrative controls and PPE provide interim solutions in a planned program to eliminate or reduce a particular risk or they may be used in addition to other control methods.

2.10 Risk Matrix

2.10.1 Likelihood & Severity

Likelihood of Occurrence

Severity of impact

(1) Rare- So unlikely it can be assumed that occurrence may not be experienced (1) Insignificant (No impact)

(2) Unlikely- Not likely to occur in Company but probable (2) Minor (little effect)

(3) Likely to occur sometimes in Company (<3/year) (3) Moderate (May pose a problem)

(4) Likely to occur several time in Company (4-10/year) (4) Major

(5) Likely to occur repeatedly in Company (>10/year) (5) Catastrophic

2.10.2 Risk Rating

Low Risk

Acceptable Risk: Work Procedure Normal <=3

Medium Risk: Acceptable Risk0 Exercise Caution with these hazards 4-12

High Risk: Unacceptable Risk- Work cannot proceed till further control measures


3.0 Permit-to-Work

3.1 Purpose and Scope

To give instruction and guidelines for permit application for the following work;

1) Working at height

2) Maintenance of machinery

3) Electrical system and equipment

4) Cargo Load On/Off

5) Hot Work/ Welding

6) Entry into confined space

3.2 Responsibilities

All personnel including permanent employees, temporary and seasonal workers and subcontractors

3.3 Procedure

3.3.1 Permit-to-Work System

All sub-contractors must strictly follow the information given in Permit-To-Work and sign Master Agreement with Myanma Awba Group

a) Detailed visual inspections should be carried out by a competent person and formally recorded using HSE-FF-12 Permit to Work Form.

b) If safety condition is satisfactory, HSE Department issue Permit-to-work certificate which clearly state the period of validity, location and details of work to be done, the nature, and the results of any preliminary test undertaken, the measures taken to make the job safe and any safeguards to be taken during operation

c) Only the work specified on the permit should be undertaken. The permit should be recognised as an overriding instruction until it is cancelled i.e. the person involved should not be diverted to other tasks.

d) Before signing the permit, the responsible officer should personally check that all the measures specified as necessary have in fact been taken and that safety arrangements will be maintained until the permit is cancelled.

e) The person responsible for carrying out the specified work should countersign the permit to indicate his understanding of the safety precautions to be observed. On completion of the work he should notify the authorising officer.

3.4 Related Document

* HSE-FF-12 Permit-to-Work Form


4.0 Working at Height

4.1 Purpose

To give instruction, guidelines and considerations to be adopted by all personnel who are required to work at height

4.2 Scope

This procedure applies to all employees and contractors of Myanma Awba Group, at all locations of work within or without the confines of the Myanma Awba Group's Rules & Regulations.

4.3 Responsibilities

All personnel including permanent employees, temporary and seasonal workers and subcontractors must strictly follow the safe work practice as described in this procedure.

The concerned department Manager or Supervisor shall notify the HSE Manager once he/ she observe anyone performs duties against to safe working practice and HSE Manager shall take appropriate disciplinary action accordingly.

4.4 Definitions

i Working at height Work includes moving around at a place of work but not travel to or from a place of work- A place is at height if a person could be injured falling from it.

ii Fall arrest System means equipment and/or material that is designed for the purpose of preventing or reducing the severity of injury to a person in the event of a fall such as safety harness system. Safety belts are generally used in a travel restraint system and not as fall arrest system

iii. Work restraint or Travel Restraint system means methods of preventing a person from reaching beyond the safe work zone within which he will not be in falling. For example, safety belt attached to a suitable lifeline.

iv Fall Protection System means material and/or equipment that are designed for the purpose of preventing a person falling from height such as scaffolds and mobile elevated work platforms

v Hazardous Work at Height Hazardous work at height means work-

a) in or on an elevated workplace from which a person could fall

b) in the vicinity of an opening through which a person could fall

c) in the vicinity of an edge over which a person could fall

d) on a surface through which a person could fall or

e) on a surface through which a person could fall or

f) in any other place (whether above or below ground) from which a person could fall, a distance more than 3 meters

4.5 Procedure-Work at height

1) Prior to working at height, a risk assessment is to be carried out to establish what health and safety measures need to be adopted to avoid or reduce risk. Consideration shall be given to

a) The physical condition of people involved

b) The activity

c) The equipment to be used

d) The location- is it near water, close to power cables, etc.

e) The condition and stability of the work area and surfaces

f) The duration of work

2) Workers must follows Rules to prevent falling

a) Make sure the working platform is secure that

 Will support the weight of workers using it and any materials and equipment they are likely to use on it

 Is stable and is not overturn, For example, scaffolding needs to be tied to a supporting structure. Mobile elevating work platforms may not be safe on sloping ground

* Provide adequate working space and

* Is footed on stable ground or on a stable support or structure

b) Provide guardrails, barriers, etc. at open edges including edges of floors, decks, roofs, floor or openings and edges of working platforms

3) Protecting against falling materials

The risk of falling materials causing injury should be minimised by;

* Barricading the area below any work at height and posting signage to warn others of the potential danger.

* Keeping work platform clear of loose materials

* Provide means of preventing materials and other objects rolling, or being kicked off the edges of platforms

* Register of tools/portable equipment to be brought to work at height are to be formulated and maintained by the responsible in charge

* All tools/equipment shall be inspected (not loose, corroded, or damaged, etc) prior to use

* Tools/equipment shall be taken in appropriate containment kit (tool bag, pouches, etc).

* While work at height with heavy items is on-going, the “Drop Zone” below the work site should need to be barricaded off if need be evaluated by risk assessment

4) Mobile Elevating Working Platform

a) Mobile elevating work platforms (MEWPs) can provide excellent safe access to high level work. When using MEWP make sure that

* Whosoever is operating it is fully trained and competent

* The work platform is provided with guard rails and toe boards

* It is used on firm and level ground

* It’s tyres are correctly inflated

* Any outriggers are extended and choked as necessary before raising the platform and

* Everyone knows what to do if the machine fails with the platforms in the raised positions

b) Do not

* Operate MEWP’s close to overhead cables or dangerous machinery

* Allow a knuckle, or allow of the arm to protrude into a traffic route when working near vehicles,

* Move the equipment with platform in the raised position unless the equipment is designed to allow this to be done safely.

c) All personnel within working platform must use a harness with a fall restraint at all times

Ladders

a) In any cases, ladders should be secured against movement and supported from a firm, level and non-slip surface.

b) If series of ladders are used to gain access to a surface, landing platforms should be provided at every 6 m interval.

c) Fall arrest system must be used by persons using a ladder as working surface.

d) When climbing/descending vertically a ladder, the three point contact rule shall be followed. One hand and two feet, or two hands and one foot should always be in contact with the ladder.

e) Ladders should not be used

* On working platforms to gain height above the protected edge

* In access areas within the arc of swinging doors

* To support a working platform

* After something has changed (ie ladder dropped or moved from one area to another)

f) Ladders should be subject to pre-use checks to be carried out by user before use and after something has changed (i.e ladder dropped or moved from a dirty area to a clean area.

g) Detailed visual inspections should be carried out by a competent person every week and formally recorded on HSE-CHL-003 Weekly Safety Inspection Checklist Form.

4.6 Related Document

* HSE-CHL-003 Weekly Inspection Checklist

* HSE-FF-012 Permit –to-Work Form


5.0 Maintenance of Machinery

5.1 Purpose

To ensure that workshop machinery is maintained in a good, safe condition and that it is used in a safe manner at all times

5.2 Scope

The procedure relates to the maintenance and use of all plant machinery such as Wolf filling and packaging machines, Inline filling, capping, labelling, induction, shrinking machines, mixed blended, granulated formulation plant, pneumatic and hydraulic tools and appliances installed within the Manufacturing Plants of Myanma Awba Group

5.3 Responsibility

All personnel including permanent employees, temporary and seasonal workers and subcontractors must strictly follow the safe working practices as described in this procedure.

The Maintenance Engineer, Manager or Supervisor shall notify the HSE Manager once he/ she observe anyone performs duties against to safe working practice and HSE Manager shall take appropriate disciplinary action

5.4 Procedure

5.4.1 General

i. Maintenance work on MAG Manufacturing Plants must not be carried out by any person other than a trainer and competent person authorised to do so by the Maintenance Department Manager.

ii. All operators must be aware of the hazards involved with operating each particular machine and how to stop the machine in an emergency.

iii. Any damage or malfunction must be reported immediately to the Maintenance Department for rectification, in such cases the machine must be stopped, switched off at its power source, and assign must be affixed stating 'Do Not Use Of Order'.

iv. Do not distract or interfere with any person who is operating a machine. If you are the operator, maintain concentration on the work being carried out.

v. Do not leave a machine unattended while it is running, wait for the machine to come to a complete stop before leaving

vi. Do not attempt to stop a machine with your hands or the body.

vii. Suitable eye protection, goggles or full-face visor must be worn at all times while operating a machine or when near to a machine that is being operated

viii. Ensure that potential hazards such as loose clothing, gloves, jewelry, long hair and materials projecting from pockets cannot come into contact with moving parts.

ix. Do not reach around or over, moving parts of a machine or the work being machines.

5.4.2 Machinery Guarding and Safety Devices

i. In general all moving parts of machinery and equipment shall be effectively guarded to prevent persons from coming into contact with them.

ii. Whenever fitted all machines guards and safety devices must be in place and used at all times. Whenever fitted guards are removed or fitted safety devices are inoperable, the power to the machine is to be isolated and tagged accordingly.

iii. All new machines purchased and installed within MAG's Manufacturing Plant must comply with the latest international standards with regard to guards and safety devices. Further, the manufacturer must be requested to supply a risk assessment for the machine being supplied.

iv. Where it is not reasonably practicable to retrofit guards or safety devices to such machines, other reasonably practicable measures are to be introduced to safeguard the operator and often in the vicinity of the machine.

5.5 Related Document

* Machine Master List

* Maintenance Schedule & Checklist for machineries


6.0 Electrical System & Equipment

6.1 Purpose

To ensure that procedure are in place to prevent electrocution and/or fires resulting from electrical connection or equipment.

6.2 Scope

i. This procedure covers the supply of electric power directly to equipment onsite and the use of electrical equipment used on site

ii. In addition this procedure will cover the safe isolation of all electrical installations and distributions networks that are being maintained, repaired or modified in buildings, production line, warehouse throughout MAG premises

iii. It will specify the process of “Lock out, Test and Tag Out” as a means to satisfy control the risk associated with the inadvertent energising of any electrical system.

6.3 Definition

i. PAT Portable Appliance Testing

ii. LOTTO Lock Out-Test-Tag Out

iii. Lock Out The placement of a lock out device on an emergency isolation device, in accordance with the established procedure, for ensuring that the energy isolating device and the machine being controlled cannot be operated until the lock out device is removed.

iv. Lock Out Device A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolation device in the safe position and prevent energitization of a machine

6.4 Responsibility

All personnel including permanent employees, temporary and seasonal workers and subcontractors must strictly follow the safe working practices as described in this procedure.

The Maintenance Engineer, Manager or Supervisor shall notify the HSE Manager once he/ she observe anyone performs duties against to safe working practice and HSE Manager shall take appropriate disciplinary action

6.5 Procedure

6.5.1 General

i. Maintenance Department shall provide and maintain all electrical installation and equipment of good construction and sound materials, free from defects, and in accordance with the generally accepted principles of sound and safe practice.

ii. Plugs and socket- outlets used for connection any electrical equipment shall be of heavy duty industrial types.

iii. It is strictly forbidden for any person other than those authorised within the Maintenance Department to interfere with those power supplies

iv. All precautions must be taken to avoid damage to power cables and any damage which may occur is found, must be immediately reported to the Maintenance Department.

v. Power supply must be isolated prior to any work commencing upon an electrical installation The isolation must be proved 'dead' by competent electrical officer using suitably approved and calibrated test equipment, e.g. Digital Multimeter, Electrical Test Pen or Contact Free Voltage Tester which is fitted with audible beeper and flashing red LED voltage indicator.

vi. The only exception to this requirement is when it is necessary to carry out electrical work in a 'live' condition, e.g. testing or maintenance work. However all necessary precautions must be taken in line with the appropriate risk assessment.

6.5.2 Procedure on site

i. Do not interfere with or attempt to repair any electrical equipment, machinery or tools.

ii. Repair all faults or breakdowns immediately to either the Maintenance Department.

iii. All switchboard, distribution boards, sub-stations and similar installation must be kept clear of obstructions at all times.

iv. No person is permitted to enter any electrical sub-station or room containing high voltage electrical equipment/unless authorised to do so by the Maintenance Department Manager.

v. Protection against contact with electrical power must be provided in all installations where the operating voltage exceeds 55V AC to earth.

vi. Only MAG electrical equipment, which are inspected and certified can be directly to the MAG electrical system, unless with prior approval of the Maintenance Department Manager.

vii. Equipment brought into the MAG premises by any subcontractor must be inspected and approved by maintenance department and only the equipment, which is manufactured to a recognised standard.

viii. All portable electrical equipment must be properly earthed and must be periodically inspected for damage. Plug ad sockets must be used at all times for connections.

ix. Operators of any electrical equipment must be trained and fully competent in its use.

6.5.3 Portable Electrical Equipment

i. Contractors are strictly forbidden to take electrical equipment or tools on site without first having such equipment inspected by Maintenance Department.

ii. Once the inspection has been completed and Maintenance Department are satisfied that the equipment or tools are of good construction and safe to use, they will attach an inspection sticker and allow the equipment or tools to be connected to the electrical systems.

iii. Any portable electrical equipment used shall be operated at a voltage not exceeding alternating current (AC) 55 volts between the conductor and earth or direct current 110volts. In exceptional circumstances where the use of supply greater than 110 volts is unavoidable, approval to use such equipment or tools in factory must be sought from the factory HSE Department.

iv. All temporary electrical installation supplying electricity to any portable electrical equipment shall be protected by effective residual circuit breakers with a tripping current (sensitivity) of not exceeding 30 milliamps (mA)

v. The low voltage shock preventer shall be fitted in accordance with the manufacturer's instructions. The low voltage shock shall be inspected and tested by a competent person once every 6 months.

vi. Welding equipment brought on site by contractor must be 440 V AC with the secondary voltage being DC.

vii. In areas when flammable vapours may be present, intrinsically safe equipment and fittings must be used

6.5.4 High or Medium Voltage Electrical Systems or Equipment

i. All high or medium voltage electrical system or equipment or building used specifically to house high or medium voltage electrical systems or equipment must display appropriate warning signs.

ii. Unauthorized persons are not to:

iii. In the event of breakdown, malfunction or damage to high or medium voltage electrical systems or equipment, Maintenance Department must be informed immediately.

iv. Maintenance Department personnel must not attempt to repair or otherwise interfere with high or medium electrical voltage systems or equipment unless specifically authorized to do so try the Maintenance Engineer.

v. When working on high or medium voltage electrical system or equipment, authorized Maintenance Department personnel must strictly adhere to Maintenance Department Instruction.

6.5.4 High or Medium Voltage Electrical Systems or Equipment

i. All high or medium voltage electrical system or equipment or building used specifically to house high or medium voltage electrical systems or equipment must display appropriate warning signs.

ii. Unauthorized persons are not to:

iii. In the event of breakdown, malfunction or damage to high or medium voltage electrical systems or equipment, Maintenance Department must be informed immediately.

iv. Maintenance Department personnel must not attempt to repair or otherwise interfere with high or medium electrical voltage systems or equipment unless specifically authorized to do so try the Maintenance Engineer.

v. When working on high or medium voltage electrical system or equipment, authorized Maintenance Department personnel must strictly adhere to Maintenance Department Instruction.

6.5.5 Temporary Disconnection of Power Supply

i. In case alternative power supplies is required to complete on site, Department Manager are to ensure that such request (Lock out and Tag out Notification) is forwarded to Maintenance Department in good time.

ii. Power supply will be isolated at appropriate sub-station, with the breaker being padilocked and tagged by the Maintenance Department. The person in charge of the isolation for Maintenance Department will retain the padilock key. Sub-station doors are also locked shut.

6.6 Related Document

* HSE-CHL-001 General Safety Checklist

* HSE-CHL-003 HSE Weekly Checklist

* HSE-CHL-005 Generator Safety Checklist

* HSE-CHL-006 Electrical Safety Checklist

7.0 Requirement for Procurement

7.1 Purpose

To ensure that all new plant and capital equipment is purchased with an in debt understanding of all relevant Occupational Health and Safety issues and that all future Safety Maintenance is conducted to address any issues known.

7.2 Scope

This procedure relates to the purchase of all new plant, capital equipment and all machine equipment. This procedure does not cover the purchase of hand or portable tools

7.3 Procedure

i. When the need for any new plant, capital equipment or machine equipment is identified, Occupational Health and Safety issues such as equipment must considered at the outset.

ii. When first approaching potential suppliers, the equipment of this procedure are to be made known of them.

iii. The supplier of any new plant, capital equipment or machine equipment is to supply the following information as a minimum.

a) A fully documented and independently verified Failure Mode and Critical Analysis (or equivalent) relating to all system, Sub systems, Modules and Components- identifying all safety critical items. Reliability data is to be provided for all identified safety critical items.

b) All relevant Occupational Health, Safety and Environmental issues.

c) Recommended test examination and maintenance protocols including method statements,

d) Regular updates as new information becomes available.

iv. The above requirements are to be communicated to the supplier in writing and are to be included on the Purchase Order to form part of the contract.

7.4 Related Document

* QMS- System Procedure Purchasing

8.0 Entry into Confined Space

8.1 Purpose

To provide a record of all personnel in confined/enclosed space to ensure that in the event of emergency complete evacuation can be quickly confirmed.

8.2 Scope

Control of entry into confined space, contractors, customers all workers, services engineers and visitors

8.3 Definitions

i. Confined Space- a place which is substantially, though not always entirely, enclosed and where there is a risk that anyone who may enter the space could be:

* Oxygen deficiency

* Poisonous vapours

* Flammability

* Corrosive chemicals

8.4 Responsibility

All personnel including permanent employees, temporary and seasonal workers and subcontractors must strictly follow the safe working practices as described in this procedure. HSE Manager, HSE Supervisor

8.5 Procedure to Confined Space Entry

i. A Risk Assessment should be carried out by responsible supervisor requesting entry permit. All the hazards and risk associated with work activity must be considered and appropriate control measures must be installed.

ii. Responsible person shall arrange adequate lighting and ventilation space. Responsible supervisor shall highlight work activity and raise request for Entry into Confined Space by filling up Permit to Work Form (HSE-FF-012). Requester must ensure that all safety measures are complied with before application is handed over to HSE Department

iii. Competent HSE Personnel shall then inspect the confined space and when it is confirmed that the confined space is safe for Entry, the HSE department shall endorse the Permit-to-Work form for Entry into Confined Space.

iv. If the work is performed by a subcontractor, he must acknowledge and agree to the terms and conditions of the permit.

v. The HSE Officer shall carry out periodic testing of the atmosphere and maintain record of the test.

vi. During work in confined space at least one competent person among a group must be equipped with a valid portable Gas Detector and a whistle, PGD shall be always kept in ON position at all time.

vii. In car of any abnormal readings or if the alarm of PGD is activated, PGD holder must alert everyone in confined and space must be evacuated at once.

viii. Confined Space Attendant shall maintain a regular contact with persons working inside confined space.

ix. In event of emergency Confined Space Attended shall summon Emergency Response Team and assists persons working inside confined space to evacuate.

x. Rescue shall be done by ERT as described in HSE-SP-01 Emergency Response Procedure.

xi. Once work in confined space is completed, the Supervisor shall remove all equipment and evacuate all persons from confined space.

xii. The HSE Officer shall keep the copy of filling and record keeping. He must also ensure that a 'No Entry Sign' is displayed at confined space entrance.

xiii. If there is no sign at the entrance of a space or there is doubt about the condition of a space, then entry is forbidden until HSE personnel has checked or re-checked the condition.

xiv. Personnel must never enter a confined space alone. It is strictly forbidden to enter any confined space without first depositing Permit-To-Work Card at the appropriate rack.

xv. Access Passes must be removed from the rack immediately upon existing or evacuating the confined space.

xvi. If in an emergency, an individual evacuates a confined space from a different opening or access from that which they entered, every effort should be made, without endangerment to the individual, to remove the Access Pass from the original point of entry.

8.6 Related Document

* HSE-FF-12 Permit- to-Work Form

9.0 Personal Protective Clothing PPE

9.1 Purpose

To ensure that all necessary PPE is made available, maintained and used correctly where required and that it conforms to recognized international standards. The provision of PPE will comply with local and international guidelines.

9.2 Scope

This procedure relates to the type and standard of PPE to be used within MAG's premises by employees, contractors and visitors. It also contains guidance on situations where the wearing of PPE is required and areas within MAG factory where the wearing of PPE is mandatory.

9.3 Definitions

i. PPE Personal Protective Equipment can be summarily classified as;

a) Head protection (safety helmets, hair protection);

b) Hearing protection;

c) Face and eye protection (goggles and spectacles, facial shields)

d) Respiratory protective equipment (dust masks, respirators, breathing apparatus)

e) Hand and foot protection (gloves, safety boots and shoes);

f) Body protection (safety suits, safety belts, harnesses, aprons);

ii. Approved standards NS, DIN, ANSI, etc.

9.4 Procedure

9.4.1 General

i. Personal Protective Equipment (PPE) is used throughout industry as means of safeguarding workers from a wide range of health and safety hazards at work, such as exposure of toxic fumes or extreme temperatures, being stuck by falling objects or being splashed by hazardous liquid.

ii. However, it must be made clear that PPE should be the last choice of risk control as per hierarchy of control measures.

ii. The company shall provide suitable PPE for all employees protective clothing and equipment when engaged in a specified work process, or who may be at risk from such a process

a) Head protection (safety helmets, hair protection);

b) Hearing protection;

c) Face and eye protection (goggles and spectacles, facial shields)

d) Respiratory protective equipment (dust masks, respirators, breathing apparatus)

e) Hand and foot protection (gloves, safety boots and shoes);

f) Body protection (safety suits, safety belts, harnesses, aprons);

iii. HSE Department of MAG factory must approve all PPE maintained in stock. Where appropriate, all PPE must comply with approved standards and all items must be marked with the standard to which they conform.

iv. The Material Catalogue lists all items of PPE available as stock items. Any PPE not held as a stock item must be approved by the HSE Department prior to being purchased.

v. All personnel who may be required to use protective equipment should be properly trained in its use and advised of its limitations.

vi. The basic minimum PPE comprises helmet, protective footwear, coverall, gloves and dust/cartridge mask must be worn at all times when working within warehouse, or production lines.

vii. PPE for specific must be used when required. i.e. safety harness, respiratory equipment,, hearing protection, hand protection from hazardous substances and special eyes protection such as full-face shields or googles.

viii. All workers who are working at height, or in any other area where there is a risk of falling more than 3 metres, should wear a safety harness attached to a lifeline.

ix. Risk assessments should be conducted to establish the requirements for PPE above the basic minimum.

x. The marking and maintenance of PPE must be in compliance with the manufacturer’s instructions, or in such a way that the materials or methods do not affect the integrity of the equipment.

xi. If a person is not able to wear PPE when required due to injury or sickness, then he may be given alternative work where PPE is not required.

xii. The correct maintenance of PPE is responsibility of the person to whom is issued. Where the PPE may have multiple users, the relevant department manager will set up an internal system for the examination and correct storage/maintenance of the PPE.

xiii. HSE supervisor inspects each item of protective equipment at regular intervals and in all cases before and after use. He should ensure that the equipment is kept clean and disinfected as and when necessary for health reasons. Personal protective clothing and equipment should always be checked by the wearer each time before use.

xiv. Each department will maintain records of the issue of PPE to individuals. Department Managers may use the form for PPE Issuance.

9.4.2`Head Protection

Safety helmet is required to be used all times whilst at work with the exception of those areas within the factory which have been deemed not to pose a risk of injury through the non-wearing of such PPE, having been assessed by the Risk Assessment process.

Safety helmet are normally manufactured from an acetate butyrate styrene (abs) plastic.

9.4.3 Eyes Protection

Eye Shield

Also referred to as over spectacles, these are often a one-piece wrap-around polycarbonate protector manufactured to meet how energy impact levels, designed to be larger enough to fit over the top of person's own prescription glasses.

Goggles

There are basically two types of goggles, panoramic with a curved lens and a wide field of vision or more traditional box type.

Goggles are available to guard impact against chemical splash, dusts and gases and can often be multi-purposes. In the main they are manufactured to meet EN 166 medium energy impact levels and an alpha numeric system of marking on both housing and the lens us used to indicate their purpose and impact resistance level as follows.

a) CHEMICALS 3

b) DUSTS 4

c) GASES 5

d) MOLTEN METAL 8

e) LOW ENERGY IMPACT F

f) MEDIUM ENERGY IMPACT B

Googles with varying degrees of green filter are also available for welding and similar processes. Manufactured to meet the requirements of EN 166 they are intended to provide protection against ultraviolet, strong light sources and are suitable for use only for short period.

9.4.4 Face screen/visors

These provide protection for both the face and eyes, and are usually manufactured to meet the requirements of EN 166 to either medium energy impact resistance or the new high energy impact resistance.

9.4.5 Respiratory Protection

i. In general, respiratory protection can be summarily classified into three types.

a) Disposable dust masks

b) Negative pressure respirators

c) Positive pressure respirators

ii. It is important to obtain and use the right type to achieve the maximum protection against a respiratory hazard. Always ensure that the exact nature of the hazard has been identified and that all equipment meets with appropriate EN standards.

iii. Many disposable dusk masks can be used only for protection against non-toxic nuisance dusts. They often little or no protection against fumes, gases and vapours. 

Code of Ethics

Code of Ethics 

Introduction 

We operate with specific values and principles of our own that we expect every employee to adhere to, and which remain constant regardless of country and culture. These values and principles are based on respect: for our work, for our profession and for the people with whom we work - our colleagues, clients, suppliers and business partners. These values and principles should be applied in all your professional dealings. Mostly this is instinctive because they are a mixture of normal working standards and everyday common sense. But it is helpful to describe in this Code of Ethics so that, whenever in doubt, you can refer to them as and when necessary. 

1.1 Clients and Suppliers Fair dealing with clients and suppliers: 

Productive relationships with clients and suppliers are based on integrity, ethical behavior, mutual trust, fairness and non-discrimination. The selection of a vendor or supplier of goods and services for the company must be based on quality, need, performance and cost, preceded by a fair competitive tender process where appropriate. Brides, kickbacks or any other form of improper payment, direct or indirect, to any representative of a client or a supplier in order to obtain a contract or some other commercial benefit are strictly prohibited. Gifts and entertainment: Favors, gifts and entertainments to or from customers, suppliers or media partners can create a conflict of interest. This is why you are not allowed, nor any member of your family, to give or accept valuable gifts (including money, discounts or special treatment) to or from anyone associated with vendors or clients. 

Favors, gifts and entertainment are only permitted when the following conditions are met: 

* They are consistent with our business practices 

* They do not violate any applicable law 

* They are of limited value For further information about conflicts of interest, please see section 2.7 below. 

1.2 The Marketplace Antitrust policy and compliance guidelines: 

* Antitrust laws are intended to prevent agreements among companies that fix prices, carve up markets, limit production or otherwise impede market forces. You must strictly comply with the antitrust, competition and anti-monopoly laws of every country, state and locality in which we do business. We also recognize the importance of working alongside and discussing common issues with competitors during congresses, trade fairs, festivals, industry meetings and professional conferences. 

1.3 The Government and the Law Compliance with laws, rules and regulations: 

* The Group expects all employees to conduct themselves with absolute integrity. Obeying the law, both in letter and in spirit, is one of the foundations on which Awba's ethical policies are built. You must respect the laws of any city, state or country where you are working/ visiting. 

Contact with government officials: 

* Our policy is to comply with all relevant legislation that relates to lobbying or attempting to influence government officials. However, effective lobbying on our own behalf, or our clients/ industry, is considered perfectly acceptable business practice so long as it complies with this legislation. 

* Illegal payments cannot be made in any circumstances to any government officials in any country in return for favorable treatments or services. 

Political contributions and related policies: 

* Awba respects and supports the rights of employees, officials and directors to participate in political activities. However, these activities cannot be conducted on company time nor involve the use of any company funds or resources such as telephones, computers or office supplies except as permitted by company policy or as an integral part of our business. Personal political contributions will not be reimbursed. 

Accuracy of company records: 

* All official records concerning the conduct of Awba business must be accurate, honest and complete, without any restriction or qualification of any kind. All of our operations anywhere in the world must comply with every applicable local, domestic, national and international law, rule or regulation relating to the accurate and complete maintenance of financial books and records and to the retention of documents. 

1.4 Shareholders Responsible corporate governance: 

* Awba applies responsible corporate governance to improve transparency in the management of the company and to optimize shareholder value in terms of both capital growth and return on investment. 

Complete, accurate and timely disclosure: 

* The Group is privately owned and are making various timely and accurate disclosures to relevant tax and other authorities. We are committed to providing full and accurate financial and other information in compliance with our disclosure obligations. We have implemented procedures to ensure that all our disclosures are timely, compliant and, in every respect, full, fair, accurate and understandable. If you are responsible for the preparation of the public statement, or you supply information as part of that process, you have a responsibility to ensure that what you provide is accurate and complete. If you have financial reporting obligations, you also have additional responsibilities outlined in Appendix 2. 

1.5 Citizenship and General Public Citizenship: 

* We have the responsibility to the community and general public to deploy our human and financial resources as well as we can. We recognize the importance of contribution to the quality of life in all of the local communities where we do business. 

Charitable work: 

* We are committed to supporting charities and funds that are devoted to the prevention and cure of disease, and to the promotion of health in Myanmar. 

2. Conduct in the workplace 

2.1 Diversity 

* Awba, as a multicultural company, recognizes the power, wealth, talent and energy generated by people of diverse backgrounds, education and experience working towards a common goal. 

2.2 Work environment 

* Personal and individual behavior in the workplace is based on mutual respect between employees. We aim to provide a safe, healthy and productive work environment. You have a personal responsibility to make sure you actions do not undermine the quality of work environment for your colleagues. 

2.3 Fair employment practices 

* The Group is committed to comply with all applicable legislation and regulations about equal employment opportunities, non-discrimination and other employment-related matters. 

* We totally repudiate any form of discrimination in the terms or conditions of employment, or of harassment or intimidation, because of race, color, religion, gender, age, national origin, sexual orientation, disability or other legally protected classification. We are committed to providing a fair work environment that treats each individual with respect and dignity. 

* Awba expects you to support both these commitments and our continuing efforts towards equal employment opportunities for all. 

2.4 Drug-free workplace 

* Awba prohibits the distribution, sale, purchase, transfer, possession or use of illegal drugs in the workplace. 

2.5 Confidentiality of company data and documents 

* Employees, officers and directors may not disclose or make public confidential information entrusted to them by the company or its clients, except when the disclosure is either expressly authorized by Awba or required by the law. You may not disclose, reveal or discuss with anyone outside the company or use it for your own direct or indirect benefit, or for the direct or indirect benefit of anyone else. 

* This obligation to keep company information confidential continues even after the end of your employment or any other relationship with the company. We reserve the right to pursue every legal avenue to prevent any former employee, officer or director from using confidential Awba information to the disadvantage of the Group. 

* Some examples of confidential information are: 

* Non-public earnings reports and other financial information. 

* Cost, pricing, marketing or service strategies. 

* Clients and supplier lists. 

* Non-public information regarding divestitures, mergers and acquisitions. 

* Employee salary and benefits data or medical information. 

2.6 Purchase and sale of Awba and client securities; insider trading 

* Applicable securities legislation strictly forbids employees, officers and directors from buying or selling Awba and clients' securities while in possession of sensitive or material information about the company not available to the public. Likewise, you may not provide a family member, friend or any other person with material information about Awba that is not publicly available. Either of these actions could amount to insider trading and both are strictly prohibited and may result in civil liabilities and criminal prosecution. This is currently not applicable to Awba being a privately owned Group. 

2.7 Conflicts of interest 

* Awba respects the rights of employees, officers and directors to manage their personal affairs and investments. We have no wish to intrude on your personal lives. At the same time, we expect you always to act in the best interests of Awba and to avoid situations that present a potential or actual (or even apparent) conflicts between your interests and those of the company. 

A 'conflict of interest' arises when your personal interests interferes in any way (or even appears to interfere) with those of Awba, for example when you do anything in your personal life that might make it difficult to perform your company work effectively and objectively. Conflicts of interest arises when you, or any member of your family, receive improper personal benefit as a result of your position with Awba. 

Appendix 1 gives some examples of specific conflicts of interest, as an illustrative list. 

2.8 Protection and proper use of company assets 

* You must endeavor to protect company assets and ensure their efficient use at all times. Theft, carelessness and waste have a direct impact on Awba's profitability. Any suspected incident of fraud or theft should be reported immediately for investigation. Company equipment should not be used for non-company business, though incidental personal use may be permitted. 

2.9 Levels of authority 

* You are expected to know what decisions are within your authority and which require additional approvals. In the event of any doubt, please seek advice from your supervisor. 

2.10 Loans 

* Awba prohibits the making of any personal loans, or the arrangement of loans by a third party, to any Awba director or executive officer. 

3. Sustainable Development 

* Economic progress, social responsibility and environmental concern must be harnessed together to achieve sustainable development. Sustainable development also contributes to the quality of consumers' lives, now and for future generations. 

* Sustainability is therefore an essential ingredient of Awba's business conduct: meeting the needs of our clients, and building sales and profitability, while contributing to the prosperity of employees and shareholders. * We are directly involved in sustainable development by providing products and services that enhance customers' lives, whether in terms of health, hygiene, economics or convenience. 

* Through our activities, we contribute to the economic and social well-being of a whole range of other stockholders, and the local communities in which we operate. More widely we make an impact on regional, national and international development. 

4. Compliance with Standards and Practice 

Understanding and complying with the rules: 

* Managers will be reviewing this Code with their staff, informing every one of their obligations in practical terms. Training or awareness programs will be organized as necessary to ensure that this Code is well understood and applied throughout the company. 

* You should always adhere to this Code, as well as the law and Awba policies. If an applicable law conflicts with a policy in this Code, you must comply with the Law. However, if a local custom or policy conflicts with this Code, you must comply with this code. It is important to understand that if you violate the policies in this Code you will be subject to disciplinary action, up to and including a termination of employment and, where appropriate, civil liability and criminal prosecution. 

* Anyone who has questions about this Code should turn to their immediate supervisors in the first instance. Awba open door policy gives you the right to approach any member of management with ethical questions and concerns. 

Reporting any violation of this Code: 

* If you believe that something is happening that is actual or potential violation of this Code, you must bring this to the attention of your supervisor or manager. If, after raising your concern, the issue is not resolved, or it may not be appropriate to speak to your supervisor, please raise the matter with one of the other contact lists below Locally within your business 

* Your supervisor or manager 

* Company legal counsel 

* Next level of management 

Awba HQ: Group Chief Financial Officer/ Group Chief Executive Officer 

Tel +95 1 663399 

95-A, Kyaik Wine Pagoda Road, 8th Mile, 

Mayangone Township, 

Yangon, Union of Myanmar 

You can raise your concern orally or in writing by mail. All reported concerns will be treated in confidence except as necessary to conduct investigations or comply with applicable law. 

Although you are encouraged to identify yourself to assist the company in effectively addressing your concern, you may choose to remain anonymous, and we will respect your choice. All employee communications made in good faith will be dealt with promptly, professionally and consistently (taking into account different circumstances). 

Retaliation for reports of misconduct made in good faith will not be tolerated. Anyone who engages in retaliation will be subject to disciplinary action, up to and including a termination of employment and, where appropriate, civil liability and criminal prosecution. 

Appendix 3 provides additional information about the administration of this Code. 

Appendix 1: 

Examples of conflicts of interest 

i. Specific relationships with a competing business and other entities: Engaging in a competing business with Awba is a conflict of interest. Some relationships with a competing business or a client, supplier or other body that has a material financial or adverse relationship with Awba are also conflicts of interest. For that reason without the prior approval of the Awba Board of Directors or management, you may not: 

* Engage in any competing business with Awba; or 

* Engage in any of the following activities: 

* Serving as a director, officer or employee, 

* Owning more than 10% of the shares or other equity interest, or 

* Providing direct consulting, legal, advisory or other services, in any competing business with client, supplier or any other body that has a material financial relationship with the company, or any entity whose interests are significantly adverse to, or in conflict with, those of the company. 

The determination of whether a material financial relationship exists, or whether an interest is significantly adverse to or in conflict with the interests of Awba will be made on a case-by-case basis. The best policy is to avoid any direct or indirect business connection with our competitors, clients or suppliers, except on behalf of the company. 

ii. Outside or additional part-time work: You may wish to take on additional part-time work with organizations that are not our competitors, clients or suppliers or which do not have a material financial or adverse relationship with us. While this does not in itself constitute a conflict of interest, your second job must be strictly separated from your work at Awba, and is subject to the following restrictions: 

* Outside work must not be carried out on company time, nor involve the use of company equipment or supplies. 

* You should not attempt to sell products or services from you second job to Awba. 

Appendix 2: 

Special ethics obligations of employees with financial reporting obligations 

Awba requires honest, accurate and prompt recording and reporting of information in order to make responsible business decisions and to provide full, fair accurate and timely disclosures. All of our books, records, accounts and financial statements must be maintained in appropriate detail must appropriately reflect our transactions, and must conform both to applicable legal and accounting requirements and to our own system of internal controls. 

Unrecorded or 'off the books' funds or assets should not be maintained under any circumstances. 

The reporting of our financial results and financial condition, both accurately and on time, requires that all financial information is recorded promptly and correctly, and that our systems for recording and reporting this information are functioning properly and subject to regular and thorough evaluations. While not all of us may be familiar with accounting procedure, we do need to make sure that all of our business records are accurate, complete and reliable. 

You are therefore responsible for reporting to Awba any issues relating to internal controls (or the lack thereof), or any concerns that you may have about questionable accounting or auditing practices or any other related matters that may come to your attention. This also applies to all operating reports or records prepared for internal or external purposes, such as environmental data, product test results, quality control reports, or sales projections. 

False, misleading or incomplete information impairs our ability to make good decisions, undermines trust in the long term, and may in some cases be illegal. Internal memos, e-mail, and formal reports often become public, and when writing you should avoid all exaggeration, derogatory remarks, guesswork, or inappropriate characterizations of people and companies that can be misunderstood. Records should always be retained or destroyed according to our record retention policies. 

In the event of any litigation or government investigation, these policies require you to consult company legal personnel about what you should do. If you have financial reporting obligations you bear a special responsibility for promoting integrity throughout the organization, with responsibilities to stakeholders both inside and outside Awba. 

The Group Chief Executive Officer, the Group Chief Financial Officer, chief executives and finance officers at individual company levels, and all other staff with financial reporting obligations have a special obligation both to adhere to good accounting and financial reporting practice. 

Because of this special role, the Group Chief Executive Officer, the Group Chief Financial Officer, chief executives and finance officers at individual company levels, and all other staff with financial reporting obligations are required to: 

* Act with honesty and integrity, avoiding actual or apparent conflicts of interest involving personal and professional relationships. 

* Provide in the company's public filings and other public communications, and in communications to other Awba officers, information that is full, fair, accurate, complete, objective, timely and understandable. 

* Comply with the applicable rules and regulations of all government bodies, as well as any other private and public regulatory agencies to which Awba is subject, including any exchanges on which Awba shares may be listed. 

* Act at all times in good faith, responsibly, with due care, competence and diligence, and without any misrepresentation of material facts and without seeking improperly to influence or hinder the company's independent auditors in any way in the performance of their engagement. 

* Act objectively, without allowing their independent judgment to be subordinated. 

* Maintain the confidentiality of company information, except when authorized or otherwise required to make any disclosure, and avoid the use of any company information for personal advantage. 

* Share their knowledge and skills with others to improve Awba communications to its shareholders and other constituents. 

* Promote ethical behavior among staff under their supervision. 

* Ensure responsible use of and control over all company assets and resources with which they are entrusted. If you believe that a violation of this Financial Officer Code of Ethics has occurred, please contact Awba Group Chief Financial Officer/ Group Chief Executive Officer at: 

Tel +95 1 663399 

95-A, Kyaik Wine Pagoda Road, 8th Mile, 

Mayangone Township, 

Yangon, Union of Myanmar 

You may also contact the Audit Committee of the Awba Board of Directors. 

If you would like to maintain anonymity, you may mail correspondence to the following address: 

Mr. Chairman, Officer Audit Committee 

Myanma Awba Group 

95-A, Kyaik Wine Pagoda Road, 8th Mile, 

Mayangone Township, 

Yangon, Union of Myanmar 

All reported concerns will be treated in confidence except as necessary to conduct investigations or comply with applicable law. Although you are encouraged to identify yourself to assist the company in effectively addressing your concern, you may choose to remain anonymous, and we will respect your choice. 

All employee communications made in good faith will be dealt with promptly, professionally and consistently (taking into account different circumstances). Retaliation for reports of misconduct made in good faith will not be tolerated. Anyone who engages in retaliation will be subject to disciplinary actions, up to and including a termination of employment and, where appropriate, civil liability and criminal prosecution. 

Appendix 3: 

Administration 

* The Audit Committee of the Awba Board of Directors is responsible for the annual review of the implementation of the Code of Ethics and its associated procedures. Whenever necessary the Committee will recommend amendments or clarifications of the Code of the Board of Directors for approval. 

Waivers: 

* No waiver of the Code for executive officers or directors may be made, other than by the Awba Board.

Environmental and Sustainability Policy

Pending... Please check back soon.

Anti-Bribery and Anti-Corruption Policy

Pending.... Please check back soon.

Related Party Policy

POLICY ON RELATED PARTY TRANSACTIONS 

1. PREAMBLE 
The Board of Directors (the 'Board') of Myanma Awba Group (the 'Company') has adopted this Policy upon the recommendation of the Audit Committee and the said Policy includes the materiality threshold and the manner of dealing with Related Party Transactions ('Policy'). Amendments, from time to time, to the Policy, if any, shall be considered by the Board based on the recommendations of the Audit Committee. In addition to this policy, the company will comply with any other provisions regarding related party transactions that exist in any valid shareholder agreements. This Policy applies to transactions between the Company and one or more of its Related Parties. It provides a framework for governance and reporting of Related Party Transactions including material transactions. The policy applies to all subsidiaries and affiliates in the Group. 

2. OBJECTIVE 
This Policy is intended to ensure due and timely identification, approval, disclosure and reporting of transactions between the Company and any of its Related Parties in compliance with the applicable laws and regulations as may be amended from time to time. The provisions of this Policy are designed to govern the approval process and disclosure requirements to ensure transparency in the conduct of Related Party Transactions in the best interest of the Company and its shareholders and to comply with the statutory provisions in this regard. 

3. DEFINITIONS 
Audit Committee or Committee means the Committee of the Board constituted from time to time with terms of reference as laid down by Board. Board means the Board of Directors of the Company. Key Managerial Personnel means Key Managerial Personnel including directors, business unit heads, or other employees or officers in positions key to the continuing business operations of the Company. Material Related Party Transaction means a Related Party Transaction which individually or taken together with previous transactions during the financial year, exceeds ten percent of the annual consolidated turnover of the Company as per the last audited financial statements of the Company or such limits as may be prescribed from time to time. Related Party means any Person: (a) that holds a material interest in the Company; (b) in which the Company or any of its Subsidiaries holds a material interest; (c) that is otherwise an Affiliate of the Company; (d) who serves (or has within the past 12 (twelve) months served) as a director, Key Managerial Personnel of the Company; or (e) who is a member of the family (including spouse, child, parents, siblings, in-laws, brother in-law, sister in-law) of any individual included in any of the foregoing. For the purpose of this definition, "material interest" shall mean a direct or indirect ownership of shares representing at least five per cent (5%) of the outstanding voting power or equity of the Company or any of its Subsidiaries. For the avoidance of doubt, it is hereby clarified that the Affiliated Companies shall be deemed to be a "Related Party" 
'Related Party Transaction' means any transaction between the Company and any Related Party for transfer of resources, services or obligations, regardless of whether a price is charged and includes 
a. Sale, purchase or supply of any goods or materials; 
b. Selling or otherwise disposing of, or buying property of any kind; 
c. Leasing of property of any kind; 
d. Availing or rendering of any services; 
e. Appointment of any agent for the purchase or sale of goods, materials, services or property; 
f. Such related party's appointment to any office or place of profit in the Company, its subsidiary Company or associate Company; 
g. Underwriting the subscription of any securities or derivatives thereof, of the Company; 
h. Financing (including loans and equity contributions in cash or kind); 
i. Providing or obtaining guarantees and collaterals; and 
j. Deputation of employees. (The above is an indicative list and not an exhaustive one). 
'Relative' means a relative and includes anyone who is related in any of the following manner; 
a. Husband or wife; 
b. Father (including step-father); 
c. Mother (including step-mother); 
d. Son (including step-son); 
e. Son's wife; 
f. Daughter; 
g. Daughter's husband; 
h. Brother (including step-brother); or 
i. Sister (including step-sister). 'Transaction' with a related party shall be construed to include a single transaction or a group of transactions. The term Director, shall have the same meaning as assigned under the Myanmar Companies Act 

4. POLICY 
The Audit Committee shall review and provide a recommendation to the Board with whom rests the ultimate authority for approval of Related Party Transactions based on this Policy. All proposed Related Party Transactions must be reported to the Audit Committee for prior approval by the Committee in accordance with this Policy. In the case of frequent / regular / repetitive transactions which are in the normal course of business of the Company, the Committee may grant standing pre-approval / omnibus approval, details whereof are given in a separate section of this Policy. In exceptional cases, where a prior approval is not taken due to an inadvertent omission or due to  unforeseen circumstances, the Committee may ratify the transactions in accordance with this Policy. 

4.1 REVIEW AND UPDATE OF THE POLICY 
Revisions of this Policy are the principal way of implementing and communicating changes that may arise in response to the changing needs and requirements of the Company. This Policy should be reviewed at least annually for updates by the GCFO. Any employee may recommend changes to the Policy by using the appropriate direct reporting line authority and process. All amendments, additions or deletions to the Policy should be properly documented and authorized/ approved prior to implementation. 

4.2 IDENTIFICATION OF RELATED PARTY TRANSACTIONS 
Every Director and Key Managerial Personnel will be responsible for providing a declaration in the format as per Annexure 1 containing the following information to the Board/ Company Secretary on an annual basis: 
1. Names of his / her Relatives; 
2. Partnership firms in which he/ she or his / her Relative is a partner; 
3. Private Companies in which he/ she is a member or Director; 
4. Public Companies in which he/ she is a Director and holds along with his/her Relatives more than 2% of paid up share capital; 
5. Any Body Corporate whose Board of Directors, Managing Director or Manager is accustomed to act in accordance with his/ her advice, directions or instructions; and 
6. Persons on whose advice, directions or instructions, he/ she is accustomed to act (other than advice, directions or instructions obtained from a person in professional capacity). 
Every Director and the Key Managerial Personnel will also be responsible to update the Board/ Company Secretary of any changes in the above relationships, directorships, holdings, interests and/ or controls immediately on him/ her becoming aware of such changes. The Board/ Company Secretary shall be responsible to maintain an updated database of information pertaining to Related Parties reflecting details of:
1. All Directors and Key Managerial Personnel; 
2. All individuals, partnership firms, companies and other persons as declared and updated by Directors and Key Managerial Personnel; 
3. Company's holding company, subsidiary companies and associate companies; 
4. Subsidiaries of holding company; 
5. Director or Key Managerial Personnel of the holding company or their Relatives; 
6. All Awba Group entities; and 
7. Any other entity which is a Related Party as defined under Myanmar Companies Act or the relevant Accounting Standard. 

The database shall be updated whenever necessary and shall be reviewed at least once a year jointly by the Company Secretary and Group Chief Financial Officer. The functional/ business heads/ Group Chief Financial Officer /Company Secretary/ shall have access to the updated database. Every Director, Key Managerial Personnel, Functional/ Business heads/ Group Chief Financial Officer will be responsible for providing prior Notice to the Board/ Company Secretary of any potential Related Party Transaction. They will also be responsible for providing additional information about the transaction that the Board/ Committee may request, for being placed before the Committee and the Board. The suggested details and list of records and supporting documents which are required to be provided along with the Notice of the proposed transaction are provided in Annexure 2 to this Policy. The Company Secretary in consultation with the Group Chief Financial Officer may refer any potential related party transaction to any external legal/ transfer pricing expert and the outcome or opinion of such exercise shall be brought to the notice of the Audit Committee. Based on this Notice, the Company Secretary will take it up for necessary approvals under this Policy. 

4.3 REVIEW AND APPROVAL OF RELATED PARTY TRANSACTION 
All Related Party Transactions shall be subject to the prior approval of the Audit Committee whether at a meeting or by resolution by circulation or through electronic mode. A member of the Committee who (if) has a potential interest in any Related Party Transaction will not remain present at the meeting or abstain from discussion and voting on such Related Party Transaction and shall not be counted in determining the presence of a quorum when such Transaction is considered. 

4.3.1 CONSIDERATION BY THE COMMITTEE IN APPROVING THE PROPOSED TRANSACTIONS 
While considering any transaction, the Committee shall take into account all relevant facts and circumstances including the terms of the transaction, the business purpose of the transaction, the benefits to the Company and to the Related Party, and any other relevant matters. Prior to the approval, the Committee shall, inter-alia, consider the following factors to the extent relevant to the transaction: 
a. Whether the terms of the Related Party Transaction are in the ordinary course of the Company's business and are on an arm's length basis; 
b. The business reasons for the Company to enter into the Related Party Transaction and the nature of alternative transactions, if any; 
c. Whether the Related Party Transaction includes any potential reputational risks that may arise as a result of or in connection with the proposed Transaction; and 
d. Whether the Related Party Transaction would affect the independence or present a conflict of interest for any Director or Key Managerial Personnel of the Company, taking into account the size of the transaction, the overall financial position of the Director, Key Managerial Personnel or other Related Party, the direct or indirect nature of the Director's interest, Key Managerial Personnel's or other Related Party's interest in the transaction and the ongoing nature of any proposed relationship and any other factors the Committee deems relevant. While considering the arm's length nature of the transaction, the Committee shall take into account the facts and circumstances as were applicable at the time of entering into the transaction with the Related Party. The Committee shall take into consideration that subsequent events (i.e., events after the initial transactions have commenced) like evolving business strategies / short term commercial decisions to improve / sustain market share, changing market dynamics, local competitive scenario, economic / regulatory conditions affecting the global / domestic industry, may impact profitability but may not have a bearing on the otherwise arm's length nature of the transaction. For clarity on Arm's length principle: The following, indicative list, should be considered while determining The Arm's length principle issues while reviewing an RPT: 
a) Does the related party transaction make commercial sense for the Company? 
b) Has the transaction been entered on terms and conditions no more favorable than those for third parties in similar circumstances? 
c) Was there a transparent, properly managed bidding or negotiation process? 
d) Does the methodology of determining relevant valuations or prices make sense? e) Is the size of the related party's interest in the transaction reasonable and justifiable? 
f) Is the timing of the transaction beneficial to the Company? 
g) Are the provisions or limits imposed by the Company on the transaction sufficient? h) Has there been an appropriate assessment of the risks of the transaction to the Company? 

4.3.2 APPROVAL BY CIRCULAR RESOLUTION OF THE COMMITTEE 
In the event the Company Management determines that it is impractical or undesirable to wait until a meeting of the Committee to enter into a Related Party Transaction, such transaction may be recommended by the Committee by way of circular resolution in accordance with this Policy and statutory provisions for the time being in force. Any such approval must be ratified by the Board at its next scheduled meeting. 

4.3.3 APPROVAL BY THE BOARD 
The Committee shall recommend all Related Party Transactions to the Board for approval. If the Board elects to review and approve any such matter or it is mandatory under any law for Board to approve the Related Party Transaction, then the Board shall consider and approve the Related Party Transaction at a meeting and the considerations set forth above shall apply to the Board's review and approval of the matter, with such modification as may be necessary or appropriate under the circumstances, even without prior recommendation from the Committee. 

4.3.4 STANDING PRE-APPROVAL / OMNIBUS APPROVAL BY THE COMMITTEE 
In the case of frequent/ regular/ repetitive transactions which are in the normal course of business of the Company, the Committee may grant standing pre-approval/ omnibus approval. While granting the approval the Audit Committee shall satisfy itself of the need for the omnibus approval and that same is in the interest of the Company. The omnibus approval shall specify the following: 
a. Name of the related party 
b. Nature of the transaction 
c. Period of the transaction 
d. Maximum amount of the transactions that can be entered into 
e. Indicative base price/ current contracted price and formula for variation in price, if any 
f. Such other conditions as the Audit Committee may deem fit.  
Such transactions will be deemed to be pre-approved and may not require any further approval of the Audit Committee for each specific transaction unless the price, value or material terms of the contract or arrangement, as mentioned from (a) to (f) above, have been varied/ amended. 

Any proposed variations/ amendments to these factors shall require a prior approval of the Committee. 

4.3.5 APPROVAL OF MATERIAL RELATED PARTY TRANSACTIONS 
All Material Related Party Transactions shall require approval of the shareholders through special resolution and the Related Parties shall abstain from voting on such resolution. 

4.3.6 TRANSACTIONS NOT IN ORDINARY COURSE OF BUSINESS OR NOT AT ARM'S LENGTH 
All Related Party Transactions which are not in the Ordinary Course of Business or not at Arm's Length, or otherwise contravene the RPT Policy shall also require the prior approval of the shareholders through special resolution and the Related Parties shall abstain from voting on such resolution. 

4.3.7 RELATED PARTY TRANSACTIONS NOT PREVIOUSLY APPROVED 
In the event the Company becomes aware of a Related Party Transaction that has not been approved or ratified under this Policy, the transaction shall be placed as promptly as practicable before the Committee or Board or the Shareholders as may be required in accordance with this Policy for review and ratification. The Committee or the Board or the Shareholders shall consider all relevant facts and circumstances respecting such transaction and shall evaluate all options available to the Company, including but not limited to ratification, revision, or termination of such transaction, and the Company shall take such action as the Committee deems appropriate under the circumstances. 

4.3.8 REVIEW OF RELATED PARTY TRANSACTIONS BY INTERNAL AND EXTERNAL AUDITORS 
a) Internal Audit shall review the adequacy of the company's processes for identifying, managing and reporting related party transactions. Internal Audit shall report any concerns it has regarding related party transactions or the company's framework for managing related party transactions directly to Audit Committee. 
b) The External Auditors shall also review the RPTs and share their opinion on them with the Audit Committee. 

4.4 DISCLOSURE AND REPORTING OF RELATED PARTY TRANSACTIONS 
Every Related Party Transaction entered into by the Company shall be referred to in the Board's report to the shareholders along with justification for entering into such transaction. The Company Secretary and the Group Chief Financial Officer shall be, responsible for such disclosure. The Company Secretary shall also make necessary entries in the Register of Contracts required to be maintained by the Company. GCFO shall provide all shareholders with a certification that all Related Party transactions including all the transactions between the Company and/or its Subsidiaries and/or the Affiliated Companies and each of their respective Affiliates, if any, during that Financial Year, were on the basis of arm's-length arrangements. 


5. SCOPE LIMITATION 
In the event of any conflict between the provisions of this Policy and any other statutory enactments, rules, the provisions of such statutory enactments, rules shall prevail over this Policy. 

6. DISSEMINATION OF POLICY Either this Policy or the important provisions of this policy shall be disseminated to all functional and operational employees and other concerned persons of the Company and shall be hosted on the intranet and website of the Company and web link thereto shall be provided in the annual report of the Company.  

ANNEXURE 1 
NOTICE OF INTEREST BY DIRECTOR / KEY MANAGERIAL PERSONNEL 
To, 
The Company Secretary/ Compliance Officer 
Myanma Awba Group Company Limited 
95-A, Kyaik Wine Pagoda Road, 8th Mile, 
Mayangone Township, 
Yangon, Union of Myanmar 
Dear Sir, 
I -------, son/daughter/spouse of -------- resident of --------.., holding ---------- Shares (equity or preference) of Kyat ______/- each (======.. percent of the paid-up Capital) in the Company in my name, being a --------- in the Company, hereby give notice that I am interested directly/ through my Relatives (Schedule) in the following company or companies, body corporate, firms or other association of individuals: 
Sr. 
No. 
Name of the Nature of Interest or Shareholding 
Date on which Companies/ Bodies concern / Change in Interest or Concern Corporate/Firms/ Interest or Concern arose/changed Association of Individuals 

B. The Following are the Bodies Corporate whose Board of Directors, Managing Director or Manager is accustomed to act in accordance with any advice, directions or instructions; 
Sr. 
No. 
Name of the Body Corporate 

C. I am accustomed to act on the advice, directions or instructions of the following persons (other than advice, directions or instructions obtained in professional capacity). 
Sr. 
No. 
Name of the person 
Relation 
Signature: 

Name: 
Designation: 
Place: 
Date: 

SCHEDULE LIST OF RELATIVES 
No. 
Relationship 
Full Name 
Address Shareholding in Awba Limited 
1 Spouse 
2 Father (including Step-Father) 
3 Son (including Stepson) 
4 Daughter 
5 Daughter's Husband 
6 Brother (Including Step-Brother) 
7 Sister (Including Step-Sister) 
8 Mother (including Step-Mother) 
9 Son's Wife 

ANNEXURE 2 
INFORMATION TO BE PROVIDED TO THE AUDIT COMMITTEE / BOARD IN RELATION TO THE PROPOSED RELATED PARTY TRANSACTION (TO THE EXTENT RELEVANT TO THE TRANSACTION): 
1. Name of the Related Party and nature of relationship; 
2. Nature and duration of the contract/ transaction and particulars thereof; 
3. Material terms of the contract or arrangement or transaction including the value, if any; 
4. In case of existing or approved contracts, transactions, details of proposed variations to the duration, current price / value and / or material terms of the contract or arrangement including a justification to the proposed variations; 
5. Any advance paid / received or to be paid / received for the contract or arrangement, if any; 
6. Manner of determining the pricing and other commercial terms, whether or not included as part of contract; 
7. Copy of the draft MOU, agreement, contract, purchase order or correspondence etc. if any. 
8. Applicable statutory provisions, if any; 
9. Valuation reports in case of sale or purchase or leasing / renting of capital assets or securities; 
10. Justification as to the arm’s length nature of the proposed transaction; 
11. Declaration whether the transaction is in the ordinary course of business; 
12. Persons / authority approving the transaction; and 
13. Any other information relevant or important for the Committee / Board to take a decision on the proposed transaction. 

Advisory Board Charter

ADVISORY BOARD CHARTER 

1. PREAMBLE 
The Board of Directors (the 'Board') of Myanma Awba Group (the 'Company') will utilize an Advisory Board as part of its governance framework, the role of which is to support the Board in fulfilling its responsibilities of providing strategic guidance and oversight of the Company. The Board has adopted this Charter for functioning of Advisory Board. 

2. DUTIES AND RESPONSIBILITIES 
The role of the Advisory Board is to provide advice and recommendations to the Board on various strategic issues. It will perform many of the same functions as a typical Board of Directors; however, the ultimate decision-making authority rests with the official Board of Directors, as defined per Myanmar Law. More specifically, the Advisory Board will assist the Board of the Company by: 
* Participating in the setting and monitoring of the Company's long-term strategic objectives and business plans of management; 
* Participating in the setting the risk appetite for the Company; 
* Supporting the Board in monitoring the overall performance of the Company's progress towards its strategic objectives and in line with its defined risk appetite; 
* Supporting the Board in overseeing and approving the risk management framework and associated policies and procedures used by management to effectively manage risk. 
* Recommending to the Board the approval of the appointment and dismissal of the Chief Internal Auditor. 
* Supporting the Board in overseeing the integrity of the financial statements, the compliance with legal and regulatory requirements, the performance, qualifications, and independence of the External Auditor, and the performance of the internal audit function. 
* Supporting the Board in overseeing the internal control framework used by management and ensuring it is efficient and effective. 
* Support the Board in overseeing and providing recommendations for approving the human resource policies and framework of the Company. 
* Providing recommendations to the Board to take decisions on major business matters. 
* Recommending to the Board the appointment and, as necessary, dismissal of the Chief Executive Officer of the Company. 
* Recommending to the Board a framework for the remuneration and incentive schemes, including key performance indicators, for senior executives. 
* Supporting the Board in evaluating the overall performance of key senior executives and taking corrective actions as needed. 
* Developing succession plans and developmental objectives for senior executive positions.  Identifying and recommending potential new board members. 
* Setting up and recommending the Board of Directors remuneration charter. 
* Supporting the Board in overseeing the Company's corporate governance framework and ensuring compliance with approved policies. 

3. DUTIES OF ADVISORY BOARD MEMBERS 
In performing their activities, each member of the Advisory Board shall uphold the highest standards of ethics and conduct. Specifically, he/she shall adhere to the following duties: 
* He/she shall exercise fully duty of loyalty to the Company, by NOT: 
- Conducting transactions in which they have a personal interest; disclosing confidential information; 
- Entering into contractual relations with a competing company; using assets and facilities of the company for personal benefit/gain; or 
- Using information and business opportunities received in their official capacity for personal gain. 
* He/she shall exercise fully duty of care to the company, including: 
- Supporting the Board of Directors in directing and governing the affairs of the company in a manner oriented towards the long-term interest of the entire company; 
- Displaying maximum care, diligence, and prudence in carrying out his/her duties. 

4. ADVISORY BOARD COMPOSITION 
* The Advisory Board shall be appointed by a majority vote of the Board. The Advisory Board shall consist of at least three members, the exact number to be determined by the Board. The Advisory Board may include Company Executives and Board Directors. At least one independent director shall be appointed to the Advisory Board, where possible. 
* The members of the Advisory Board shall serve for as long as the Board of Directors deems necessary. 
*  The members of the Advisory Board shall have relevant financial expertise and other skillsets as determined by the Board. 
* The Advisory Board shall designate one its members to act as its Chairman. 

5. ADVISORY BOARD WORK PROCEDURES 
5.1 MEETING FREQUENCY 
The Advisory Board shall meet as needed, but at least four (4) times a year and preferably six (06) times per year. If possible, meetings shall be scheduled in advance according to an annual calendar and adjusted as needed, but not more than two (2) weeks from the original schedule.  

5.2 MEETING NOTICE AND AGENDA 
Meetings of the Advisory Board are called by the Chairman of this Board. Except in urgent cases, as determined by the Chairman, the agenda and related documentation for a meeting shall be sent to all members at least three to five days before the meeting. 

5.3 MEETING MATERIAL 
All members of the Advisory Board are provided with a concise, but comprehensive set of information by the Company Secretary in a timely manner, as much in advance as possible (target three to five days in advance). This includes: an Agenda; Minutes of the prior Advisory Board Meeting; Issue papers to be discussed, and other Reports prepared by management. Issue papers should be clear, succinct, insightful, and include recommendations for action based on proper analysis. The Advisory Board shall keep detailed minutes of its meetings that adequately reflect discussions, signed by the Chairman of the Advisory Board. 

5.4 MEETING VENUE 
The meetings are generally held at the offices of the Company, but may also take place elsewhere. In addition, meetings may be held by conference call, video conference or by any other means of communication, provided all participants can communicate with each other simultaneously. 

5.5 ATTENDENCE OF AND ADMITTANCE TO MEETINGS 
Members of the Advisory Board shall attend all meetings and may not be represented (by proxy) at meetings by another member. Non-members (Executives or other outside individuals) may attend the meetings at the permission of the Advisory Board Chairman. The Advisory Board may request that any Director, Officer, Member of the Internal Audit function or other employee of the Company, or any other persons whose advice and counsel are sought by the Advisory Board, attend any meeting and provide such pertinent information as the Advisory Board requests. 

5.6 QUORUM AND VOTING 
A majority of members shall constitute a quorum (personally and not by proxy). Each member of the Advisory Board shall have one vote. In case of any deadlock, Chairman would have an additional deciding vote. The Advisory Board does not take decisions that can result in actions to be implemented, rather, the Advisory Board decisions are considered as recommendations to be brought before the Board of Directors of the Company which is has the authority to approve these recommendations and pass resolutions. 

5.7 MINUTES OF MEETINGS 
Minutes of the meetings shall be kept and circulated to members for objections and approval. If no objection is lodged within ten business days, the minutes shall be approved. Once approved, such minutes shall be provided to the Board and then added to the Company's records and circulated in the next meeting. Each member shall receive a copy of the minutes. 

6. OTHER PRACTICES 
6.1 ACCESS TO INDEPEDENT ADVISORS 
The Advisory Board may engage and obtain advice and assistance from internal or external legal, accounting or other advisors, after obtaining the Board of Directors' approval and at the Company's expense. 

6.2 REPORTING OBLIGATIONS AND DISCLOSURE 
The Advisory Board shall maintain minutes of its meetings and shall give regular reports to the Board of Directors. 
6.3 PERFORMANCE EVALUATION 
The Advisory Board shall review its own performance at least annually in such manner as it deems appropriate, and submit such evaluation, including any recommendations for change, to the full Board for review, discussion and approval. 
6.4 TRAINING 
Members of the Advisory Board shall receive appropriate training on taking office and on an ongoing and timely basis to ensure that they can carry out their functions. 
6.5 AMENDMENT 
This Charter will come into force upon its adoption by the Board of Directors, except where expressly mentioned otherwise. It can be amended at any time by a decision of the Board of Directors. 

7. DISSEMINATION OF CHARTER 
Either this Charter or the important provisions of this Charter shall be disseminated to all functional and operational employees and other concerned persons of the Company and shall be hosted on the intra-net and website of the Company and web link thereto shall be provided in the annual report of the Company.

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