EMPLOYEE HANDBOOK

SINGAPORE – 2018

Document History

Version Date approved Approved by Description Preparer/Reviewer1 CEO/CCO First Draft Kiranjit /Chetna2 4 January 2019 CEO Second Draft Kiranjit3 01 July 2019 CEO Third Draft Kiranjit

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Table of Contents

1. WELCOME TO THE FAMILY...........................................................................................................7

1.1 CEO’s Message..................................................................................................................................................... 7

1.2 What we do......................................................................................................................................................... 8

1.3 Our Mission......................................................................................................................................................... 9

1.4 Our Vision............................................................................................................................................................ 9

2 NATURE OF EMPLOYEMENT.......................................................................................................10

2.1 Equal Employment Opportunity......................................................................................................................... 10

2.2 Open Door Policy............................................................................................................................................... 11

2.3 Employee Classification...................................................................................................................................... 11

2.4 Employee Career Progression............................................................................................................................. 12

3 YOUR JOURNEY AND SETTLING IN..............................................................................................13

3.1 Employee Headcount Requisition....................................................................................................................... 13

3.2 Application........................................................................................................................................................ 13

3.3 Selection............................................................................................................................................................ 13

3.4 Pre-employment checks..................................................................................................................................... 14

3.5 Appointment..................................................................................................................................................... 14

3.6 Hiring of relatives............................................................................................................................................... 14

3.7 Hiring of former employees................................................................................................................................ 14

3.8 Hiring of foreign candidates............................................................................................................................... 15

3.9 Probationary Period........................................................................................................................................... 15

3.10 Employee personal files..................................................................................................................................... 16

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3.11 Transfer............................................................................................................................................................. 16

3.12 Conversion of contract employees...................................................................................................................... 16

3.13 Internal Referral................................................................................................................................................. 16

3.14 Internship.......................................................................................................................................................... 17

3.15 New Hire(s) Orientation Program....................................................................................................................... 17

4 IN.TERESTING DEAL....................................................................................................................18

4.1 Wages and Salary............................................................................................................................................... 18

4.2 Monthly salary payment.................................................................................................................................... 19

4.3 Benefit and Allowance Guidelines...................................................................................................................... 19

4.4 Medical insurance.............................................................................................................................................. 20

4.5 Hospitalization................................................................................................................................................... 204.5.1 Out-Patient.............................................................................................................................................................204.5.2 In-Patient................................................................................................................................................................21

5 CONDUCT AND POLICY...............................................................................................................22

5.1 Professional Conduct.......................................................................................................................................... 22

5.2 General Code of Conduct.................................................................................................................................... 22

5.3 Ethical Conduct.................................................................................................................................................. 22

5.4 Dress Code......................................................................................................................................................... 23

5.5 Confidential Information.................................................................................................................................... 23

5.6 Fraud................................................................................................................................................................. 24

5.7 Conflict of Interest............................................................................................................................................. 24

5.8 Safety and Security rules.................................................................................................................................... 25

5.9 Office Security.................................................................................................................................................... 25

5.10 Personnel Records.............................................................................................................................................. 25

5.11 Internet Usage................................................................................................................................................... 26

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5.12 Use of social media & Personal mobile phone.....................................................................................................26

5.13 Client Relationship............................................................................................................................................. 26

5.14 Politics............................................................................................................................................................... 27

5.15 Personal Data Protection.................................................................................................................................... 275.15.1 Use of Personal Data..........................................................................................................................................275.15.2 Disclosure of Personal Data to Third Parties.......................................................................................................275.15.3 Security and Protection of Personal Data...........................................................................................................285.15.4 Data Protection Officer.......................................................................................................................................28

5.16 Usage of IT Facilities........................................................................................................................................... 28

5.17 Harassment........................................................................................................................................................ 28

5.18 Grievance Policy................................................................................................................................................. 29

5.19 Whistleblower Policy......................................................................................................................................... 295.19.1 Reporting Responsibility.....................................................................................................................................305.19.2 Authority of Management..................................................................................................................................305.19.3 Reporting Concerns............................................................................................................................................305.19.4 Handling of Reported Violations.........................................................................................................................305.19.5 Acting in Good Faith...........................................................................................................................................31

5.20 Disciplinary Policy.............................................................................................................................................. 315.20.1 Misconduct – Minor & Major.............................................................................................................................325.20.2 Disciplinary Procedure........................................................................................................................................335.20.3 Punishment........................................................................................................................................................345.20.4 Grounds for appeal.............................................................................................................................................34

5.21 Usage of Corporate Logo.................................................................................................................................... 34

5.22 Other Company Property................................................................................................................................... 35

6 WORK, HOURS AND THE OFFICE.................................................................................................36

6.1 Working Hours................................................................................................................................................... 36

6.2 Timesheets........................................................................................................................................................ 36

6.3 Access Card........................................................................................................................................................ 37

6.4 In.Corp Client Management System (Portal)....................................................................................................... 37

6.5 Office Facilities................................................................................................................................................... 37

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7 YOUR ENTITLEMENTS.................................................................................................................38

7.1 Leave Policy....................................................................................................................................................... 38

7.2 Annual Leave..................................................................................................................................................... 38

7.3 Sick leave........................................................................................................................................................... 39

7.4 Hospitalization leave.......................................................................................................................................... 39

7.5 Maternity leave................................................................................................................................................. 397.5.1 Employment Act.....................................................................................................................................................39

7.6 Paternity leave & shared parental leave............................................................................................................. 40

7.7 Adoption leave................................................................................................................................................... 40

7.8 Child care leave.................................................................................................................................................. 41

7.9 Unpaid infant care leave.................................................................................................................................... 41

7.10 Leave for performing National Service................................................................................................................ 41

7.11 Public Holidays................................................................................................................................................... 42

7.12 Leave without Pay.............................................................................................................................................. 42

7.13 Unapproved leave.............................................................................................................................................. 42

7.14 Marriage leave................................................................................................................................................... 42

7.15 Birthday Leave................................................................................................................................................... 42

7.16 Compassionate leave......................................................................................................................................... 43

7.17 Study leave........................................................................................................................................................ 43

7.18 Other type of leave............................................................................................................................................ 43

8 YOU ALSO NEED TO KNOW........................................................................................................44

8.1 Client Onboarding Policy.................................................................................................................................... 44

8.2 Gift & Entertainment policy................................................................................................................................ 44

8.3 Travel Policy....................................................................................................................................................... 44

8.4 Taxi Allowance Policy......................................................................................................................................... 44

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8.5 Learning and Development................................................................................................................................ 448.5.1 Training Needs Analysis..........................................................................................................................................458.5.2 Professional Exam Subsidy......................................................................................................................................458.5.3 Training Bond..........................................................................................................................................................45

9 YOUR PEERS AND YOUR PERFORMANCE....................................................................................46

9.1 Key Performance Indicator (KPI)......................................................................................................................... 469.1.1 Promotion...............................................................................................................................................................479.1.2 Performance Bonus................................................................................................................................................47

9.2 Performance Evaluation Discussions................................................................................................................... 47

10 THE DAY OF DEPARTURE............................................................................................................48

10.1 Resignation........................................................................................................................................................ 4810.1.1 Notice of Resignation.........................................................................................................................................4810.1.2 Notice Period......................................................................................................................................................48

10.2 Breach of contract.............................................................................................................................................. 48

10.3 Leave balance.................................................................................................................................................... 48

10.4 Exit Interview..................................................................................................................................................... 49

10.5 Retirement & Re-employment............................................................................................................................ 49

Appendix

RIKVIN

SUMMIT PLANNERS

KITTLESON AND CARPO CONSULTING

JMA CONSULTANTS

ARDENT

CEKINDO

RHT CORPORATE ADVISORY

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1. WELCOME TO THE FAMILY1.1 CEO’s Message

You have gone through the interview process, you have signed the contracts, and you’re finally here at

In.Corp.

Congratulations, and welcome. I am delighted to welcome you to In.Corp family and I look forward to

working with you as part of the team.

This book isn’t about fringe benefits or how to set up your workstation – it is about the choices you’re going

to be making and how to think about them. It’s also about how not to freak out now that you’re here. We

want to become the region’s leading corporate solutions provider and we have set out to create a

Customer focused and a compliant services organization, but we know that it starts by creating an

environment that fosters greatness. A place where incredibly talented individuals are empowered to put

their best work and relying on their best judgment – day in and day out.

Every company will tell you that “the customer is king,” but here that statement has weight. There’s

NOTHING stopping you from figuring out for yourself what our customers want, and then giving it to them.

Any time we interview a potential hire, we not only assess if they’re talented or collaborative but also if

they’re capable of literally running this company, because they will be.

As In.Corp continues to grow, we hope that these principles will serve each new person joining our ranks.

Once again – Welcome aboard! I look forward to a lasting and beneficial association.

Sincerely

Atin Bhutani

Chief Executive Officer

In.Corp Global Pte. Ltd.

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1.2 What we do

In.Corp is a Singapore headquartered corporate solutions provider specializing in corporate compliance, accounting, taxation, incorporation and expansion advisory services.

Our Mission is to be a leading Pan-Asian corporate solutions provider and a partner of choice to our customers for their business expansion needs internationally. Our Vision is to become an organization that:

Is knowledge centric and offers expert advice to our clients, Facilitates intelligent and informed decision making for our clients, Delivers value to its shareholders, Values its people and rewards their performance

Our portfolio of services and solutions includes the following:

Our clients select us as their partner because we:

Are a knowledge centric, one stop solution provider – From incorporation to consulting Are managed by a professionally diverse team with deep knowledge of industry & compliance Have a Value-added services portfolio and a Regional service offering. Are Responsive, diligent and collaborative

For more information, visit our website at www.incorp.asia

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1.3 Our Mission

Be an organization that:

Is knowledge centric and offers expert advice to our clients Facilitates intelligent and informed decision making for our clients Delivers value to its shareholders Values its people and rewards their performance

1.4 Our Vision

To be a leading Pan-Asian corporate solutions provider and a partner of choice to our customers for their business expansion needs internationally.

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2 NATURE OF EMPLOYEMENT

1.2.

Employment at this company is at-will. An at-will employment relationship can be terminated at any time, with or without reason or notice by either the employer or the employee. This at-will employment relationship exists regardless of any statements by office personnel to the contrary.

2.1 Equal Employment Opportunity

This company is an equal opportunity employer and does not unlawfully discriminate against employees or applicants for employment on the basis of an individual’s race, color, religion, creed, sex, national origin, age, disability, marital status, veteran status or any other status protected by applicable law. This policy applies to all terms, conditions and privileges of employment, including recruitment, hiring, placement, compensation, promotion, discipline and termination

In.Corp is committed to encouraging equality and diversity among our workforce, and eliminating unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.

The organisation - in providing our services - is also committed against unlawful discrimination of customers or the public

The policy’s purpose is to:

provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time

not unlawfully discriminate on account of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex (gender) and sexual orientation

Oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, selection for employment, promotion, training or other developmental opportunities

The organisation commits to:

encourage equality and diversity in the workplace as they are good practice and make business sense create a working environment free of bullying, harassment, victimisation and unlawful discrimination,

promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued

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This commitment includes informing and training (through a formal HR orientation module) managers and all other employees about their rights and responsibilities under the equality policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public

take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities

Such acts will be dealt with as misconduct under the organisation’s grievance procedures, and any appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice

Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations.

review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law

monitor the make-up of the workforce regarding information such as age, gender, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality and diversity, and in meeting the aims and commitments set out in the equality policy

Monitoring will also include assessing how the equality policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues

2.2 Open Door Policy

The company has an open-door policy and takes employee concerns and problems seriously. The company values each employee and strives to provide a positive work experience. Employees are encouraged to bring any workplace concerns or problems they might have or know about to their supervisor or some other member of management.

2.3 Employee Classification

Employment classifications have been defined so that all employees can understand the policy applicability and benefits eligibility. All employees of are classified as follows:

a) Permanent Employees : employees who are full time employees directly on the rolls of the Company on a permanent basis with an open duration and no specific completion date.

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b) Contract Employees : employees who are directly on the roles of the Company on a contractual basis with specific contract expiry dates.

2.4 Employee Career Progression Click on the link for career progression flow for Service Delivery Teams (SDT)

Career Progression Chart - SDT

SDT Departments are:

Accounts Business Advisory Corporate Secretarial Immigration Payroll Tax

Click on the link for career progression flow for Head Quarter Function Teams (HQ Functions)

Career Progression Chart - HQ Functions

HQ Function Departments are:

Business Development Client Due Diligence Client Management Credit Control/ Accounts Receivables Digital Marketing Finance Human Resources & Administration Information Technology & Business Analytics Mergers and Acquisitions Training & Development

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3 YOUR JOURNEY AND SETTLING IN

3.1 Employee Headcount Requisition

All requests for expansion / backfill of all permanent and contract positions including internship placement must be submitted to Human Resource Department with an approved Headcount Requisition Form (HRF). Incomplete and unapproved HRF shall not be processed.

All HRFs must be approved by the CEO/CCO/COO:

a) HRFs must include the following information: Job Description, education level, field of study and salary range. Types of employment hiring (i.e. Permanent, contract) Reason for hiring (i.e. new position, replacement hiring)

b) Sourcing for a backfill for new hire who resign within 2 weeks after commencement, shall be without going through the initial approval stage.

c) HRF format is available on the Group Portal.

3.2 Application

Sourcing Channels of potential candidates will include but not limited to the following:

a) internal advertisementb) external advertisementc) through referral by individuals known to the Company

3.3 Selection

Selection of potential candidate shall be based on skills, experience, qualifications, personal attributes and overall suitability to the position, organization culture, work expectations and environment as well as salary expectation.

All applicants are required to complete the Employee profile form, to be submitted with a copy of the highest qualification certificate obtained. Mandatory sighting of qualification certifications as listed in application plus salary slip shall be conducted by the HR representative.

Selection process will be performed by the hiring Manager and HR representative(s). All interview arrangement(s) will be coordinated by the Human Resource Department.

The Interview Evaluation Form must be completed with relevant details and signed by the panel of interviewers for the preparation of offer letter and other hiring formalities.

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3.4 Pre-employment checks

HR has the right to conduct reference check(s) of the selected candidate’s background and previous record/performance with previous employer.

Additional background checks will also be conducted.

All successful candidates may be required to undergo pre-employment medical check-up at an identified medical practitioner and be declared medically fit for employment. Candidates who are not declared medically fit will not be accepted for employment.

3.5 Appointment

All offers of employment shall be prepared and issued by Human Resource Department upon completion of the whole selection process with relevant checks and completed documentations.

The employment contract (offer letter) can only be signed by the following Authorised Executives:

a) Group Head of the Departmentb) Group Head – Human Resourcesc) CEO/CCO/COO

3.6 Hiring of relatives

Hiring of existing employee’s immediate family member is discouraged. The immediate family members shall be defined as the employee’s spouse, brother, sister, brothers or sisters-in-law.

In order to avoid any possible conflict of interest, it is the Company policy to prohibit the employment of two (2) or more persons who are related to each other in positions with direct reporting relationship, where they could exercise control or in any way influence the position, progress or supervision of another relative.

Any exception to the above prohibitions can only be made with prior written approval of the CEO/CCO/COO.

3.7 Hiring of former employees

Re-hiring of an ex-employee of In.Corp may be considered However, if need arises, appointment shall be based on the following conditions:-

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a) The employee should not have any disciplinary or legal issues (including termination) during the previous employment with the Company.

b) In addition to the normal recruitment clearance process, the following are required: Justification and positive feedback from previous immediate superior during the previous

employment with In.Corp Probation is mandatory. New role/position requirement shall be according to HRF.

3.8 Hiring of foreign candidates

All foreign hires will only be able to commence work once they have received approval of the relevant work pass from Immigration and other local authorities.

Compensation package must be in line with Company’s compensation and benefit scheme.

Company will bear all the cost of the employment pass applications, processing fees and related charges. Company does not reimburse the cost of passport application, renewal or replacement.

The company assists with the application under Spouse Program for employees’ family members. Dependent visa for other than foreign hires spouse & children is strictly not allowed.

3.9 Probationary Period

All new hires will be required to undergo a probationary period of three (3) months and will be informed in writing in regards to their confirmation status.

The respective immediate manager shall assess the performance throughout the probationary period and recommend the confirmation, extension or termination.

During the probation period, this Agreement may be terminated by either party. Employee may terminate the agreement by providing the employer with fourteen (14) working days’ prior written notice of his/her intention to terminate. However, employer may terminate the agreement by providing the employee only seven (07) working days’ prior notice.

Where necessary, salary adjustment shall be awarded but will be subject to approval from the CEO/CCO/COO.

The probationary period may be extended for another period of not more than three (3) months if the employee’s performance does not meet with the position’s and Company’s expectations.

Confirmation Letters will be issued by the Human Resource Department.

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3.10 Employee personal files

To avoid losing of information and unauthorized parties accessing to employee’s information, the HR Department shall manage, organize and keep track of all employee personal files and related employment information through a proper personal file for each employees.

All employees are required to ensure their personal details are correct and current. Any updates to their personal record can be done by sending an email to HR.

3.11 Transfer

The Company may at its discretion transfer any employee to any location within the Company in Singapore, Group or subsidiary companies in line with the Company’s operational requirements or for the purpose of job enrichments or career development of the employee.

In executing its right to transfer an employee, the Company will ensure that it complies with prevailing laws and regulations with regards to movement of an employee.

3.12 Conversion of contract employees

A contract employee may be offered a permanent employment based on the following conditions:

a) There has to be a business need and approved headcount requisition for the permanent positionb) The employee should not have had any disciplinary or legal issues during the contract employment.c) For conversion to a same position, the probation period may be WAIVED.d) Leave during contract period shall not be carried forward to the permanent position.

3.13 Internal Referral

The Company encourages employee participations in the Company recruitment efforts through recommendation of suitable candidates for any open position.

All referred candidates shall be put through the standard selection process and evaluated based on their own merit. Acceptance of referral in no way obligates the Company to guarantee the candidate an employment.

All employees are eligible except employees at Managerial level (Group Heads) as well as Management.

The said referral fee payment shall be made via the proposer’s salary account shall only be paid upon confirmation of the referred new employee and issuance of confirmation letter has been made.

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To be eligible for the reward, the proposer must be on the Company’s payroll when the reward payment is due.

Each successful referral shall receive an award as follows:

Classification Country Award per Referral

Tier 1Indonesia, Vietnam, Thailand, Malaysia, Philippines, Cambodia, Myanmar, Laos, Brunei, India, China & Hong Kong

SGD 250/-

Tier 2 Singapore & Other Parts of Asia SGD 400/-

Tier 3 Outside Asia SGD 750/-

Note:

a) Hiring Manger shall not refer a candidate for a position he/she is hiring for. b) No referral bonus will be offered to an employee, if the referral candidate is in their direct family

relation (such as, siblings, spouse etc.)c) Employee referring a candidate will get referral bonus only after the confirmation of referred

candidate.

d)e) Employee referring a candidate will get referral bonus only after the confirmation of referred

candidate. Internship In building its talent pool, the Company may from to time provides internship opportunities to students

from relevant field(s) of studies.

Upon successful completion of the internship program, interns may be offered as permanent employees subject to the vacancy availability.

Intern(s) from schools shall be eligible for the following benefits during their attachment period:

a) First month there will be no leave entitlement. b) Thereafter, one (1) day paid leave per month will be added.

3.14 New Hire(s) Orientation Program

As part of new hire onboarding program, a session with Human Resource Department will be conducted with the respective new hires where the following information shall be shared:

a) Company profile and business overviewb) Corporate Human Resource Discipline & Conduct

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c) Employee Benefits (leave, holidays and medical)d) Employment terms

HR will inform about the session and it is mandatory to attend.

Each department may have their own on-the job training mechanism which the new hires will undergo based on the Department/Group head’s instructions.

2.3.4.

4.1.1.

4 IN.TERESTING DEAL2.3.4.

4.1 Wages and Salary

All employees of In.Corp will be on company’s payroll. For the purpose of payroll, the work month will begin on the first working day of the month and will end on the last working day of the same month. The salary for the month is credited on the last day of every month. No employee will be paid directly out of petty cash or any other such fund. For your convenience, your salary is paid into your bank account. The Company is required to make standard deductions from your salary as per the regulations of the revenue department.

Filing of tax returns is the responsibility of the employee. You will be required to file for your personal Income Tax, once the tax assessment order is received from IRAS (Inland Revenue Authority of Singapore. We encourage you to apply for your Sing Pass ID and password. Details are available at www.singpass.gov.sg. Once you have your ID and password, you may create your profile. This will allow you to access various government portals, including the “My Tax Portal” where you can receive online information useful in resolving your tax related queries.

For more information on personal taxation in Singapore, log on to: www.IRAS.gov.sg

For more information on Central Provident Fund (CPF) in Singapore, log on to: www.cpf.gov.sg

Claims & Reimbursements: All claims with receipts, approved by your manager/supervisor/clients are required to be submitted to the HR department, by the 20th of every month and will be processed with the monthly salary. Any claims received after the 20th will be processed with the payroll of the following month.

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All salaries are paid net of statutory deductions and any other allowable deductions (if any).

The employee’s salary shall be paid into his bank account at the last day of each month and a statement of salary (pay-slip) can be obtained via portal. The Company reserves the right to choose any mode of salary payment (Cheque or Bank transfer) as it deems necessary.

An employee is required to notify the HR department immediately if there is any change in his salary payment mode. The Company reserves the right to recover any amount in excess of any salary paid to the employee.

The Company shall comply with all mandatory contribution(s) and deduction(s) prescribed by the relevant authorities and/or statutory government bodies. In the event that exceptions to the standards are to be executed, the statutory bodies must be informed via stipulated channels/forms.

All information pertaining to salary and compensation shall be kept in strict confidence by all employees. The Company may decide to institute actions on any employee who is found to be in breach (see Disciplinary Policy).

4.2 Monthly salary payment

Salary shall be paid on the last day of each month along with the relevant monthly allowance(s) and claim(s), if any.

All action items affecting salary payment must be submitted to the HR Department duly approved by your group head. Any items submitted after the mentioned respective due date shall be paid in the following month.

4.3 Benefit and Allowance Guidelines

All claims (on the respective employee benefits and allowances) must be approved by the respective Group Head, who are responsible to exercise proper control and verification on all claims made by the respective employees subject to submission of relevant receipt/invoices or bills.

Falsifying a claim, making a claim more than once or overlapping claims on a single receipt is a serious matter and shall be subjected to a disciplinary action.

Employees are responsible to pay the difference of the respective allowances entitlement if a higher rate incurs. Any exceptions shall require approval from the CEO/CCO/COO.

All Claims must be submitted to Human Resource Department using the Company Employee Expense Claim Form within two (2) months from the date of incurred. Claim forms are available on the Group Portal and Group IT team will continue to communicate the changes made on the system from time to time.

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The Company reserves the right to check details of claims made by the employee and reject any claims that have incurred outside the scope of the Company’s official business, unauthorised, in extreme excess or frivolous in nature.

Where an expense is reimbursable by clients, employees are required to specify accordingly in the Employee Expense Claim Form with the respective client information clearly stated to facilitate invoicing. Approving manager is fully accountable for the reimbursement of the expenses from the respective client(s).

The Management reserves the right to provide any employee (or employee categories) with any allowance(s)/incentives other than mentioned in this policy on a case-to-case basis subject to approval by the CEO/CCO/COO and the respective employee shall be advised in writing. The provision shall not be taken as precedence and may be revoked according to the requirements of the Company.

4.4 Medical insurance

The objective of the policy is to provide guidelines and procedures on medical benefits entitlements to all employees of the Company.

Medical Coverage provided by the Company shall be limited to curative treatment only. The company shall not be responsible for preventive or wellness programs undertaken by the employees.

Coverage provided shall be limited to treatment by certified medical practitioners. Traditional treatment shall not be covered by the Company. Traditional treatment shall include homeopathy and treatment accorded through religious or spiritual channels.

The coverage takes effect from the date of confirmation until the last service date of employment.

The Management reserves the right to make any decision in regard to the selection of the Insurance Provider for the Company at its own discretion.

4.5.

4.5 Hospitalization

5.6.7.

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7.1.7.2.7.3.7.4.7.5.7.6.

4.5.1 Out-Patient

Our company provides Out-patient medical coverage to our employee from appointed panel clinics provided by PRUDENTIALPRUDENT Insurance Company.

Employees can avail this benefit immediately after their confirmation within the Company.

After the confirmation, HR will apply medical insurance for individual employee. Each employee will have to download “Alliance Healthcare App” from where employee can download e-card. This e-card can be presented at the clinics listed in Medical Service Provider panel list.

For non-panel claims, reimbursements shall be made through the appointed Medical Service Provider by submitting the hard copy claims.

Case 1 – If an employee visits to a clinic listed in panel, the cost per visit per day is “As Charged” or borne by company

Case 2 – If an employee visits to a non-panel clinic, the company will only reimburse the total cost up-to $35 (per visit per day)

Note:

a) Co-payment or up-front payment of additional $SGD10/- in both the above mentioned cases, are borne by employees.

b) Visit to TCM is not covered under this policy

Special Treatment shall be deemed necessary when the patient can no longer be effectively treated by a general practitioner, subject to the annual entitlement limit (check with HR for your annual entitlement, as PRUDENTIALPRUDENT Insurance Company, keep updating their policy). Any amount in excess of your entitlement shall be borne by employee itself.

(In order to get more clarity on claims, eligibility, panel list, coverage, more benefits etc., please get in touch with Human Resource Department)

4.5.2 In-Patient

The Company provides hospitalization medical coverage for all permanent employees. Contract employees are not covered with this benefit.

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The annual limit for the coverage shall be based on individual medical insurance.

Please get in touch with HR Department for more details.

5 CONDUCT AND POLICY

5.1 Professional Conduct

This company expects its employees to adhere to a standard of professional conduct and integrity. This ensures that the work environment is safe, comfortable and productive. Employees should be respectful, courteous, and mindful of others’ feelings and needs. General cooperation between coworkers and supervisors is expected. Individuals who act in an unprofessional manner may be subject to disciplinary action.

5.2 General Code of Conduct

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Employees should adhere to laws, regulations, do not use any unauthorized software or breach any external licensing / copyright / cyber laws acts and requirements.

5.3 Ethical Conduct

In.Corp Code of Conduct (hereinafter referred to as the Code) requires directors, consultants, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the organization must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.

Supervisory Relationships:

Supervisor shall at all times treat staff in a fair and unbiased manner. Treatment of staff shall not be influenced by personal ties between the supervisor and the staff member, nor shall it be influenced by the race, nationality, sex, religion, political opinions or sexual orientation of the supervisor or staff member

Instructions and Remuneration from outside sources:

Except as otherwise required to perform the company assignments involving service to other entities, staff member owe their duty entirely to the company and to no other authority. Accordingly, staff members may not accept instructions relation to the performance of their duties with the company from any other external entities or persons except where performing duties for others pursuant to:

a) Client where the employee is placed.b) The terms of secondmentc) Benefits, Favours, Gifts

Official duties will bring staff members into contact with organization and other officials or members of the public who may wish to offer gifts or hospitality. While such contact is a necessary part of conduction the company’s business it is essential that staff members and their families be and be seen to be, free from any form of bribery or corruption. The offering of gifts and/or other benefits may be seen as an attempt to influence a decision which a staff member is required to take and therefore must be avoided.

For these reasons, staff may not accept gifts or hospitality of any kind except in cases where:

a) The gift is of an inexpensive nature such as souvenir, calendar or diary given in the spirit of harmonious business relations and of a value not to exceed SGD 50 or equivalent.

b) Refusal of the gift would cause offence on cultural groundsc) The gift is offered in a public forum where refusal would cause embarrassment: ord) The hospitality is associated with the demands of work, for example working meals or legitimate

representational functions to meet and discuss business, and the scope and cost of the hospitality

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do not appear excessive, in case of doubt, the staff member should seek the advice of her/his manager

In case where an item in excess of SGD 50 is accepted for cultural or protocol reasons as provided in the preceding paragraph, the item must be surrendered promptly to the Company and must not be regarded as the personal property of the staff member.

5.4 Dress Code

An employee’s personal appearance and hygiene is a reflection on the company’s character. Employees are expected to dress appropriately for their individual work responsibilities and position.

Take care of personal hygiene and cleanliness.

As representatives of a reputable company, your appearance should therefore be neat and pleasant and attire suitable for conducting business on the company’s behalf at all times.

a) Mondays-Thursdays: Business Formal Attire b) Fridays: Business Casual Attire (for gentlemen – polo t-shirt)c) Employees are expected to dress appropriately for their individual work responsibilities and

position.

Attire that is not appropriate includes the following:

Too revealing, miniskirts, spaghetti straps, sheer sundresses, strappy dresses, torn/ripped jeans etc.

5.5 Confidential Information

From time to time you will be privy to Confidential Information regarding the company. You agree that all such Confidential Information is the property of the Company and is for exclusive benefit for the Company. You also agree both during your employment and at all times thereafter, you will not directly or indirectly use or disclose any Confidential Information except to the extent required by law or with specific approval, in writing, from the Company. Upon the completion of your employment, you will promptly return, to the Company, all documents and information (including computer generated or stored matters) concerning the Company or its customers or employees.

“Confidential Information” means such information which is proprietary or confidential to the Company including but not limited to the terms and conditions of this Agreement, information concerning or relating in anyway whatsoever to its distributorship, franchise or other arrangements, principals, any of the trade secrets or confidential operations, processes or inventions carried on or used, any information concerning the organization, business, finances, transactions or affairs of the Company, its dealings, secret or confidential information which relates to its business or any of its principals’, clients’ or customers’ transactions or affairs, its technology, designs, documentation, manuals, budgets, financial

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statements or information, accounts, dealers’ lists, customer lists, marketing studies, drawings, notes, memoranda and the information contained therein, any information therein in respect of trade secrets, technology and technical or other information relating to the development, manufacture, clinical testing, analysis, marketing, sale or supply or proposed development, manufacture, clinical testing, analysis, marketing, sale or supply of any products or services by the Company, and plans for the development or marketing of such products or services and information and material which is either marked confidential or is by its nature intended to be exclusively for the knowledge of the recipient alone.

The protection of confidential information and trade secrets is vital to the interest and success of In.Corp. It is the responsibility of each employee to safeguard this interest. Protect the Company’s assets – its people, property and proprietary information with good security practices. Your manager will be able to discuss security as it relates to your job.

You will be required to sign a non-disclosure agreement as a condition of employment. Employees who make improper use of information or disclose trade secrets or confidential business information will be subject to legal action.

5.6 Fraud

Management is responsible for the detection and prevention of fraud, misappropriations, and other irregularities. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity. Any irregularity that is detected or suspected must be reported immediately to the CEO/CCO/COO who coordinates all investigations with the Legal Department and other affected areas, both internal and external.

5.7 Conflict of Interest

You are responsible for performing your duties in good faith and in the best interests of the Company. A conflict of interest exists when an employee or a family member is in a position to benefit personally, directly or indirectly, from his or her relationship with a person or entity conducting business with the Company. All employees have an obligation to avoid conflict, or the appearance of conflict, between their personal interests and the interests of the Company and to avoid any situation that affects, or

Potentially could affect, his or her independent, unbiased judgment in the discharge of his or her duties to the Company. To say that one has a conflict of interest does not necessarily mean that the individual involved acted or is expected to act inappropriately. However, if a competing interest exists that creates a conflict of interest concern, certain actions by the individual is required.

As an employee, it is your responsibility to declare if you have any interests in areas competing with the company. If an employee believes he or she may have a conflict of interest, the employee shall report

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such concerns in writing to HR and refrain from further participation until such time as the conflict can be reviewed and resolved.

5.8 Safety and Security rules

It is the endeavor of the Company to provide a safe and healthy environment for all employees. Safety is a two-way street. You are expected to take an active part in maintaining this environment. Familiarize yourself with the location of all alarms, firefighting equipment and exits. Learn the safety practice of your job and follow them. The security of the office premises, documents, confidential information and all assets are the responsibility of every employee. Correct or report all safety and fire hazards promptly. Report workplace accidents to your manager immediately. If you have any doubt about the safety of your job or working environment, consult your manager or HR at once.

5.9 Office Security

Staffs are to ensure main/back doors are closed at all times. Staff is to ensure that guest and maintenance staffs are attended to and send them to the door after meeting or services. If you are the last to leave office at the end of the day, please ensure the following:

There are at least 2 persons in office at night if you are staying late and leave together when close for the day;

Inform director(s) of your departure that you are the last staff to leave if they are around; Remember to switch off all air-conditioners, air purifiers and lights especially in the conference

rooms, directors’ rooms and toilets; and No one is left behind before locking up.

5.10 Personnel Records

All Personnel records will be maintained with HR and kept confidential. Keep HR updated by sending the Employee Details Update Form (see Appendix 1), whenever there is a change in the following:

a) Legal name b) Residential status (conversion from Employment Pass holder to PR/Citizen) c) Addresses and contact numbers d) Marital statuse) Number of childrenf) Academic qualificationsg) Additional skills acquiredh) Emergency contact person and number

Any legal document will be deemed to have been served when sent to the address in Personnel File.

5.11 Internet Usage

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All Internet data that is composed, transmitted, or received via our computer communications systems is considered to be part of the official records of In.Corp and, as such, is subject to disclosure to law enforcement or other third parties. You should expect only the level of privacy that is warranted by existing law. Consequently, you should always ensure that the business information contained in Internet e-mail messages and other transmissions is accurate, appropriate, ethical, and lawful.

Any questions regarding the legal effect of a message or transmission should be brought to your manager’s notice. Data that is composed, transmitted, accessed, or received via the Internet must not contain content that could be considered discriminatory, offensive, obscene, threatening, harassing, intimidating, or disruptive to any employee or other person. The unauthorized use, installation, copying, or distribution of copyrighted, trademarked, or patented material on the Internet is expressly prohibited. Internet users should take the necessary anti-virus precautions before downloading or copying any file from the Internet. All downloaded files are to be checked for viruses; all compressed files are to be checked before and after decompression.

5.12 Use of social media & Personal mobile phone

All employees are also strictly prohibited from spreading any kind of pictures or caricatures or write-ups about any employee and/or the Company to the mass media (including all forms of electronic media such as Facebook, Twitter, blogs etc.) that may cause or injure the reputation or the image of the employee concerned and or the Company, unless written consent is obtained from the Company.

5.13 Client Relationship

We shall at all times maintain professional relationship with our clients and their staff. We would not harass or offer personal business services.

All feedback (negative or positive) by client and their staff have to be reported immediately to management. A clear channel of response has to be decided by management and attended to with continuous monitoring. A summary on the sequence of event is to be documented for future reference and/or improvement, where applicable.

5.14 Politics

Employees participate in politics as private citizens. Regardless of your political affiliation, employees should conduct themselves by the highest standards of professional integrity and never compromise the firm’s interests. All employees should not use the firm’s resources to advance their political interests nor perform any acts that may be detrimental to the firm’s professional

Personal Data Protection

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Staff will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified. We may also collect, use or disclose personal data if it is required or authorized under applicable laws.

5.14.1 Use of Personal Data

Personal data should only be used for the following purposes:

a) Staff will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified. We may also collect, use or disclose personal data if it is required or authorized under applicable laws.

Personal data should only be used for the following purposes:

a) to provide our servicesb) to respond to the individual’s request or for the purposes for which it was provided to us as stated

at the time of the collection (or as is obvious from the context of collection)c) to maintain contact with clients and other contactsd) to keep clients and other contacts informed of the services we offer, industry developments,

service offerings, seminars and other events we are holding, that may be of interest to theme) for general management and reporting purposes, such as invoicing and account managementf) for recruitment purposesg) for purposes related to the employment of our personnel and providing internal services to our

personnelh) all other purposes related to our business.

5.14.2 Disclosure of Personal Data to Third Parties

All employees should not disclose personal data to third parties except when required by law, when we have their consent or deemed consent or in cases where we have engaged the third party such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.

We may disclose personal data to other member firms in the InCorp network of firms, where it is necessary.

5.14.3 Security and Protection of Personal Data

We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All staff is to follow the network-wide security policy. Only authorised In.Corp personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.

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5.14.4 Data Protection Officer

If you have concerns or further queries about how we are handling your personal data, or any problem or complaint about such matters, please contact our Data Protection Officer David Lee, at david@incorp. asia

Note: These policies are subject to change and in case of any changes; HR will communicate with the employees about the revisions.

5.15 Usage of IT Facilities

All Personal Computers, IT Network, E-Mail, Internet and other IT facilities provided by the Company are for Company's approved business use only.

An employee should refrain from using these facilities for their personal benefit such as sending greeting cards, disseminating computer games software and sending screensaver/graphics through the Group's IT Network to fellow employees and friends.

An employee is required to comply with Copyright Act/Cyber Law Acts concerning the use and application of computer software at all times.

The usage of IT facilities is governed by the Group IT Security – Information Security Policy. A copy of Information Security Policy is available on the Group Portal.

5.16 Harassment

Harassment is unwelcome and unwanted conduct and the Company is fully committed to prevent and eradicate sexual harassment in the workplace, thus creating a positive and conducive working environment in the Company.

Harassment may be:

a) Verbal (such as inappropriate jokes or threats),b) Visual (such as harassing emails or displaying offensive cartoons) orc) Physical (excessively lengthy handshakes or physical attacks).

All employees are strictly prohibited from engaging in any form of harassment, humiliation and intimidation of sexual nature.

For the purpose of this code, sexual harassment is defined as:

a) A request for sex together with an implied or overt promise of preferential treatment or a treat of detrimental treatment.

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b) Sexual behavior, language or visual material which is unwelcome or offensive and either repeated or significant enough to have a detrimental effect on the person subjected to it.

c) Therefore, harassment or discrimination on any ground protected by human or civil rights law will not be condoned.

5.17 Grievance Policy

In.Corp recognizes the importance of a positive work environment and one in which employees have a right to voice their concerns about issues that affect them at work. Grievance Resolution procedure outlines the framework available to all the employees to escalate grievances. The key points of this are procedural fairness, respect for the individual, straightforward communication and compliance with external requirements.

An employee who believes that they have been aggrieved should contact their supervisor for resolution. If the complaint is against the immediate supervisor, the employee should discuss the matter with the next managerial level. The manager will ensure that the grievance is responded to within seven (7) working days. The manager needs to document this grievance to track the progress. If the grievance is not resolved, the employee may bring it up to the next managerial level or to the HR Manager. The employee has the right to appeal until the grievance is resolved or escalate the issue to the CEO, whose decision will be final.

5.18 Whistleblower Policy

The objectives of the Whistleblower Policy are to establish policies and procedures for:

a) The submission of concerns regarding questionable accounting or audit matters and internal controls by employees, directors, officers, and other stakeholders of the organization, on a confidential and anonymous basis.

b) The receipt, retention, and treatment of complaints received by the organization regarding accounting, internal controls, or auditing matters.

c) The protection of directors, consultants and employees reporting concerns from retaliatory actions.

5.18.1 Reporting Responsibility

a) Each director, consultant, and employee of In.Corp has an obligation to report in accordance with this Whistleblower Policy

b) Questionable or improper accounting or auditing matters, and c) Violations and suspected violations of In.Corp Code (hereinafter collectively referred to as

Concerns).

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5.18.2 Authority of Management

a) All reported concerns will be forwarded to the Management in accordance with the procedures set forth herein. The Management shall be responsible for investigating, and making appropriate recommendations to the Board of Directors, with respect to all reported concerns.

b) No Retaliationc) This Whistleblower Policy is intended to encourage and enable directors, consultants, and

employees to raise concerns within the Organization for investigation and appropriate action. With this goal in mind, no director, consultant, or employee who, in good faith, reports a concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. Moreover, a volunteer or employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.

5.18.3 Reporting Concerns

a) Employees, Consultants or Directors should first discuss their concern with their immediate supervisor. If, after speaking with his or her supervisor, the individual continues to have reasonable grounds to believe the Concern is valid, the individual should report the concern to the Group HR Head.

b) In addition, if the individual is uncomfortable speaking with his or her supervisor, or the supervisor is a subject of the concern, the individual should report his or her concern directly to the HR Head.

c) If the concern was reported verbally to the Group HR Head, the reporting individual, with assistance from the Group HR Head, shall reduce the Concern to writing. The Group HR Head is required to promptly report the concern to the Management, who has specific and responsibility to investigate all concerns.

5.18.4 Handling of Reported Violations

a) The Management shall address all reported concerns. The management shall immediately notify the CEO (Chief Executive Officer), the CCO (Chief Commercial Officer) and the COO (Chief Operating Officer) of any such report. The Management will notify the sender and acknowledge receipt of the concern within five business days, if possible.

b) All reports will be promptly investigated by the Management, and appropriate corrective action will be recommended to the Board of Directors, if warranted by the investigation. In addition, action taken must include a conclusion and/or follow-up with the complainant for complete closure of the concern.

c) The Management has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations.

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5.18.5 Acting in Good Faith

Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation of the Codes. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the volunteer position or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

5.19 Disciplinary Policy

The purpose of the disciplinary policy is to ensure the Company maintains its high standard of discipline and integrity of its employees in achieving the Company objectives.

The disciplinary procedures are designed to provide a fair and effective mechanism in dealing with disciplinary matters.

The employer is deemed to have waived his right to punish an employee for the misconduct if there is unreasonable delay in taking the action against an employee. The lack of action or inaction may be interpreted by Industrial Court as an indication that the Company condones or permits the wrongdoing.

Copies of all documentation related to investigation notes, show cause letters and any other related documents in relation to disciplinary process shall be coordinated and kept by Corporate Human Resource.

While the Human Resource Department is responsible to provide advisory services, the Heads of Departments/Units as well as Head of Company are directly responsible on discipline matters of their respective employees.

Respective Immediate Managers are accountable in ensuring that appropriate actions are taken towards maintaining high standards of discipline and integrity amongst their employees at all times.

The Human Resource Department shall act as the central reference as well as to undertake appropriate actions when necessary.

5.19.1 Misconduct – Minor & Major

Misconduct

Misconduct refers to an act which is inconsistent with the laws of the country or an act which is inconsistent with the express or implied conditions of an employee’s contract of service which results in a failure to perform his/ her job, or is not in compliance with the expected norms or standards of behavior in relation to his/her employment.

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Misconduct is classified into two categories i.e. minor and major. Misconducts can be divided into two categories:

I. Minor misconductII. Major misconduct

I. Minor Misconduct

Minor misconduct, if repeatedly committed will become a major misconduct. As such it is of utmost importance that misconducts are counselled in the first instance.

The following acts or omission on the part of an employee are examples of minor misconduct (and are by no means exhaustive)

a) Latenessb) Inappropriate use of company telephone, emails and internet facilitiesc) Use of company facilities for personal use (e.g. telephone, emails, courier)d) Not taking proper care of company tools and/or equipment

II. Major Misconduct

Major misconduct is defines as a conduct whose sanction justified punishment of dismissal.

The following acts or omission on the part of an employee are examples of minor misconduct (and are by no means exhaustive)

a) Willful insubordination or disobedience or otherwise to any lawful and/or reasonable order;b) Theft, fraud or dishonest practice including attempted theft, attempted fraud or attempted

dishonesty in connection with the company’s business or property, or that of the company’s client/ customer;

c) Conducting private business in the company premises (e.g. direct selling, insurance, etc.)d) Acts of violence, abusing or assaulting other employees or superiors or company’s clients/

customer;e) Habitual absence without leave/ absence without leave for more than two consecutive working

days;f) Buying and selling of drugs during work hours within the company’s premises;g) Committing any act subversive to the discipline of the company or general behavior;h) Forging or falsifying medical certificates or any other official documents or defrauding the company

in any way;i) Vandalism;j) Sexual Harassment;k) Absenting without permission or valid reason;l) Leaving the workplace/ office during working hours without permission;m) Use of vulgar/ derogatory language on a team member/ superior/ customer;

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n) False declaration;o) Malingering;p) Willful damage to Company’s goods or property;q) Taking or giving bribes;r) Habitual or substantial negligence of duties;s) Willful slowing down of work or inciting others to do so;t) Stealing other employees' property within the company’s premises;

5.19.2 Disciplinary Procedure

Disciplinary procedure and punishment taken by the Company shall depend on the seriousness of the offence and nature of the misconduct.

Minor misconduct at first offence should be verbally counselled immediately, as repeated minor misconduct will become major misconduct.

If the minor misconduct persists after verbal counselling, the next counselling session should be recorded and submitted to Human Resource Department for record purposes.

When a minor misconduct persists and/or major misconduct is discovered, a preliminary investigation will be carried out by the immediate supervisor and/or Corporate Human Resource. Where the misconduct directly involves the supervisor, the investigation should be carried out by the next level manager and/or Human Resource Department.

Upon confirmation of the facts of the case, a show cause letter will be issued by the Group Corporate Human Resource to the employee. The employee will be given a maximum of five (5) working days to submit a written explanation/reply to Human Resource Department.

In the event that the employee fails to submit his written explanation, a decision on the disciplinary action to be taken shall be made based on the decision made by the Executive Director.

Human Resource Department shall discuss on the reasonableness of the employee’s response with the respective Immediate Managers and/or Head of Company and any decision of the disciplinary action shall be made by the Executive Director.

If the Company is not satisfied with the explanation provided by the employee, a first warning will be issued. If it is a continuous repeated misconduct on the same nature, second/final warning will be issued. The Company may also decide to remove the employee from the work place by suspension of duty for a maximum period of two (2) weeks with half pay for further investigation of the misconduct. The affected employee shall be informed accordingly.

Depending on the nature of the misconduct, the Corporate Human Resource Department may call for a formal Domestic Inquiry before deciding on the disciplinary action to be taken against the employee.

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5.19.3 Punishment

Upon completion of investigation on any types of misconduct, the Company may impose relevant punishment such as follows:

i. Dismiss without notice the employee, orii. Downgrade the employee, oriii. Impose any other lesser punishment as he deems just and fit and where a punishment of

suspension without wages is imposed, it shall not exceed a period of two weeks.

The decision on the punishment of the misconduct shall be decided by the Executive Director.

5.19.4 Grounds for appeal

The employee has the right to appeal to the Human Resources against any penalty issued for misconduct on following grounds: -

i. There was procedure irregularityii. The finding was unjustifiable in that it was one that no reasonable person could have reached on

the available evidenceiii. The availability of new evidence, which could affect the outcome reached. The employee needs to

demonstrate why such evidence was not presented at the relevant stage of this procedure.

The decision of the CEO shall be final.

5.20 Usage of Corporate Logo

The Company’s logo, letterhead and forms are issued and maintained by the Marketing Department.

All official letters and forms should appropriately bear the Company’s logo, name, address and contact numbers as specified by the Communications guidelines issued from time to time.

An employee is prohibited from changing or altering the book and format of the logo, letterhead and forms for any purpose unless authorised by the CEO/CCO/COO.

An employee is prohibited from using any document bearing the Company’s logo and name for personal matters unless authorised by the Authorising Executive.

2.3.4.

5.21 Other Company Property

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All employees are responsible for the condition of the Company property in his care. Any loss or damage to such property shall be made good by the employee, to the same category, type or function of the item lost or damaged.

An employee is also responsible for the safe return of any and/or all items in his care to the appropriate person, area or department, in the event of employment separation and/or at the request of the Company.

The Management reserves the right to inspect any of the Company properties including lockers and drawers which may contain personal items of the employee at any time without prior notice to the employee to which the property is assigned to.

All software, processes, manuals developed by the Employees in relation to their Employment will be considered company property.

In the event of loss or damage on the company property assigned to an employee, he/she shall be liable to repay the Company for any loss or damage as below:

Company Property Penalty imposed

Laptop Replacement Cost

Company Access card SGD 10/-

Building Access card SGD 20/-

Any other property Replacement Cost

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6 WORK, HOURS AND THE OFFICE

6.1 Working Hours

Employees working hours are 9, Mondays to Fridays. You are entitled to 1 hour of lunch break per day between 11:30am to 02:00pm, unless or otherwise any other arrangement is agreed with your Manager/ Group Head. It can be wisely used for meals and smoke breaks.

We have flexi timings for all employees; where employees can come to office anytime between 8.00 am to 9.30 am (only if the Manager/Group Head is agreeable to the arrangement; manager/group head may choose to decline or ask the employee to come in at a different time in case of business/client’s needs) however the minimum number of hours to spend remains the same i.e. 9 hours.

Employees are required to clock-in when reporting to work and clock-out when leaving for the day. Using the biometric keypads located at the entrance of the office.

Employees are required to inform the HR and Team Head whenever they miss punching in/out, to avoid any discrepancies in their salary

You may be required to work beyond the normal working hours to discharge your duties at the sole discretion of the Company. The Company reserves the right, at its sole discretion, to revise, amend or extend the working hours should the need arise. You are not entitled to any overtime payment except as required by law.

The Group Head endeavors to be as flexible and accommodating as reasonably possible in the event that you need to attend to personal affairs during regular work hours. In such circumstances, you will be required to attain prior approval from the Group Head and will be expected to make up any time missed in the remainder of that month.

6.2 Timesheets

Timesheet requirement will be decided by the Group Head level and above.

Employees’ timesheets should be submitted by the end of every Tuesday for the previous week. All seniors/managers/partners are to review the timesheets on a weekly basis.

Reconciliation of fees: budgeted hours vs actual hours incurred vs amount billable

Timeline & Actions

Number of actual hours – no fixed chargeable hours per day (at least 40 hours per day)

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Employees have to provide reason(s) if the actual chargeable hours incurred exceed more than 15% of budgeted time for assignment during billing process.

6.3 Access Card

Employees will be issued with an access card to enter the premises. Employees are advised not to lend their cards to any third party. Employees must immediately report to Human Resources Department if the card is lost, and Employees will be charged a replacement fee for a new card.

6.4 In.Corp Client Management System (Portal)

Employees will be given a username and password to access the Web Portal. The Web Portal is a system used for bringing all relevant information together and providing access to such information from one place. All work is usually processed through this portal.

Furthermore, the Leave Management application allows Employees to submit their leave applications via this application and Employees can also monitor their attendance records.

6.5 Office Facilities

Employees are required to keep their work stations neat and tidy at all times. Employees must refrain from displaying any personal effects or pin-ups which may be considered offensive to fellow Employees.

Common facilities such as meeting rooms, washrooms, kitchen facilities must be kept clean.

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7 YOUR ENTITLEMENTS

7.1 Leave Policy

All employees are required to ensure that approval for the leave has been given before proceeding with the leave plan. Failure to obtain approval is a serious matter and shall be subjected to a disciplinary action.

Depending on the type of leave, acceptable period of advance notice is required before any utilisation of leave (except medical leave).

7.2 Annual Leave

The Company reserves the right to recall an employee from their annual leave or cancel such leaves if their services are urgently required and the number of leave cancelled will be credited to their leave balance/entitlement.

All Employees are entitled to 18 days of paid annual leave after successful completion of the probation period with the company. Employees holding position of a Director and above level and those employees, who have completed 10 years of service in the company, are entitled to 21 days of paid annual leave.

Only five (5) unused accrued annual leave entitlement will be carried forward to the next calendar year for one (1) year and leave cannot be encashed. Five (5) carry forward leaves from preceding year shall be consumed within the first quarter of following year.

During any notice of termination, unused accrued annual leave cannot be taken except with the consent of the Company, and must be taken if required by the Company. Any balance of unused accrued annual leave will be paid out upon termination except in the case of termination for cause.

Annual Leave will be pro-rated for all Employees who have not completed a full year of service. For example, if a new employee has an annual leave entitlement of 18 days and has worked 9 months of the first calendar year, the Employee will be entitled to 14 days annual leave for that year.

All Employees are required to submit their leave applications via the Web Portal at least 5 days in advance.

All annual leave taken in the year shall be first deducted against the brought forward annual leave, if any, and thereafter against the current year’s entitlement.

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Any unutilized annual leave calculated during cessation of employment shall be either;

a) Offset against notice period subject to approval by the respective Authorised Executives.b) Paid to employee (if not utilized) based on the salary when the leave was accrued.

7.3 Sick leave

All Employees are entitled for 14 days of paid sick leave. Employees can only claim it by producing a medical certificate from a registered medical practitioner covering the period of their absence.

Employees are required to get their Group Head signature on the Medical Certificate before uploading it on Portal.

Employee sick leave entitlement is not cumulative from year to year.

7.4 Hospitalization leave

If hospitalization is necessary on a doctor’s written order, employees are entitled for paid sick leave for the days on which you are hospitalized, up to 46 additional days of paid sick leave per calendar year.

7.5 Maternity leave

All female employees are eligible for Maternity Leave as provided by the Government of Singapore. Maternity Leave will be administered as per the rules, regulations and guidelines stated by MOM. Please contact the HR department for details.

The employee must be on the services of the Company for at least 180 days before the child’s birth.

Childcare Development Co-Savings Act (“CDCSA")

The CDCSA entitles all female employees to 16 weeks of paid maternity leave provided she satisfies the following criteria:

a) Her child is a Singapore citizen;b) She is lawfully married to the child’s father; andc) She has worked for the Company for at least 90 days before the child’s birth.

7.5.1 Employment Act

Female employees who do not meet the above criteria but are covered by the EA are entitled to 12 weeks’ maternity leave provided she satisfies the following criteria:

a) She has worked for at least 3 continuous months before the birth.

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b) She has fewer than 2 children of her own at the time of delivery. In the case of multiple births (e.g. twins, triplets, etc.) during the first pregnancy, your employer is still required to pay 8 weeks of maternity leave for the next pregnancy.

The first 8 weeks of maternity leave will be paid and last 4 weeks of the maternity leave is unpaid.

An Employee will be entitled to her full maternity leave if she has a still birth. Maternity leave benefits do not apply to miscarriages or abortions, but the Employee may claim sick leave.

Employees who are not covered by either the CDCSA or EA are entitled to maternity leave as agreed in their employment contract.

Approval is required from the Reporting Manager at least 30 days prior to the date of commencement of leave.

All details of Maternity leave must be updated to HR.

7.6 Paternity leave & shared parental leave

Male Employees are entitled to 2 week paternity leave provided they satisfy the following criteria:

a) The child is a Singapore Citizen;b) The child’s parents are lawfully married; andc) Father has at least 3 months’ service.

An Employee will be entitled to his full paternity leave if his wife had a still birth; however paternity leave benefits do not apply to miscarriages or abortions.

Employees must submit the leave application at least 5 days in advance.

Your leaves must be approved by your reporting manager.

7.7 Adoption leave

Female employees are entitled to 4 weeks’ adoption leave and male employees are entitled to 1 week leave, provided they meet the following criteria:

a) The adopted child is below the age of 12 months at the point of ‘formal intent to adopt’, i.e. Court Application to adopt (for local child) or issuance of in-principle approval for Dependent’s Pass (for foreign child);

b) The adopted child is a Singaporean Citizen;

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c) For a foreign child, the child must become a Singapore Citizen within 6 months of the child’s adoption;

d) The adoptive mother and father are lawfully married;

Employee must complete at least 3 months’ service respectively.

The Adoption Order is passed within 1 year from the point of ‘formal intent to adopt. All details of adoption leave must be updated to HR.

Your leaves must be approved by your reporting manager.

7.8 Child care leave

Child Care Leave / Extended Child Care Leave (Singaporean)

a) The CCL & ECCL will be administered as per the rules, regulations and guidelines stated by the government of Singapore.

b) Your leaves must be approved by your reporting manager

Child Care Leave / Extended Child Care Leave (Foreigner)

a) As per the Singapore government, parent of the foreigner child are eligible for 2 (two) days’ child care leave.

b) Employees get to enjoy additional 2 (two) day of CCL given by the companyc) The CCL can be pro-rated if the employee has worked for less than a year or if the employee leaves

the company.d) Employees get to enjoy 2 (two) days of ECCL given by the companye) Your leaves must be approved by your reporting manager

7.9 Unpaid infant care leave

Employees covered under the CDCSA are entitled to 6 days’ unpaid infant care leave, provided they satisfy the following criteria:

a) The child (including adopted and stepchildren) is below 2 years of age;b) The child is a Singapore Citizen; andc) The parent has completed at least 3 months’ service.

Unpaid infant care leave is capped at 6 days regardless the number of children the parent has, and is pro-rated for new-hire employees in their first year of service.

Your leaves must be approved by your reporting manager.

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7.10 Leave for performing National Service

Employees are entitled to take leave to perform their National Service under the Enlistment Act. Employees are required to submit the ‘In camp training letter’ from MINDEF to HR before proceeding on leave for National Service.

Your leaves must be approved by your reporting manager.

7.11 Public Holidays

All Employees are entitled to customary legal holidays as recognized by the Company. The list of such holidays will be published and circulated via email, at the beginning of each year.

Under the Employment Act, if a public holiday falls on a Saturday, an employee who is not required to work on a Saturday is entitled to another day off or an extra day’s salary in lieu of that public holiday.

Under the Employment Act, if a public holiday falls on a Sunday, following Monday will be a public holiday.

7.12 Leave without Pay

Employees are eligible to take unpaid time off from work under specific circumstances.

The approving authority will be your Reporting Manager and HR Group Head

The event the leave without pay period is more than 30 days, the approving authority will be the CEO.

7.13 Unapproved leave

If an employee takes leave that was requested but not approved.

The employee’s absence will be designated as unauthorised and the employee will not be paid for the leave time.

Availing any unapproved leaves will be subjected to disciplinary action and can lead to dismissal.

7.14 Marriage leave

Employees must have completed their probation period.

Employee is entitled to 3 (three) days paid leave.

Employee should provide marriage certificate and this applies only for the first marriage.

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Reporting Manager and HR should be informed.

7.15 Birthday Leave

All employees shall be entitled to birthday off. For birthday which falls on weekend (Saturday or Sunday), the Friday of that week shall be the birthday off (to be taken on that Friday, no carry backward or forward).

If the birthday falls on a public holiday, the employee may apply to take his/her birthday off on either the day before, unless otherwise approved by Management.

Even after the birthday off is approved, it may be cancelled or rescheduled at the management’s discretion if committed project timelines need to be met.

7.16 Compassionate leave

Employees must have completed their probation period.

Leave should be taken in single continuous 3 (three) days period.

This applies to immediate family only.

Reporting Manager and HR should be informed.

7.17 Study leave

Employees must have completed their probation period.

Employee is entitled to 3 (three) days paid leave, including one day on the date of the actual exam.

Employee should provide evidence and must be work related course.

Reporting Manager and HR should be informed.

7.18 Other type of leave

The management at its discretion may grant a Leave of Absence or Sabbatical leave on a written application of employees in accordance with merits of each individual case.

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8 YOU ALSO NEED TO KNOW

8.1 Client Onboarding Policy

In.Corp has internally approved and externally audited INTERNAL POLICIES, PROCEDURES AND CONTROLS (IPPC) MANUAL FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING ACTIVITIES. All the employees working for In.Corp will be provided a copy of the IPPC Manual and will have to undergo a mandatory training program upon joining as well as annually. This is an important regulatory requirement that all employees must adhere to and adopt the processes as listed in the manual.

8.2 Gift & Entertainment policy

Note: Please refer to our G&E policy by clicking on the link Gifts & Entertainment Policy , alternatively visit our web portal >>Human Resources >> Policies.

8.3 Travel Policy

Approval process and payment;

a) Employee must obtain prior approval from their respective Manager/HOD before performing overtime.

b) Overtime claim cannot be accumulated for more than 2 months. Any overtime claim after 2 months period is not payable. (For example, overtime claim for 1st February, submitted and approved after 31st March is not payable).

c) The overtime payment is payable at every month end along with salary payment. Payment subjected to and Tax deduction.

Note: Please refer to our policy by clicking on the link Company Travel Policy Error! Hyperlink reference not valid. , alternatively visit our web portal >>Human Resources >> Policies.

8.4 Taxi Allowance Policy

Note: Please refer to our Taxi allowance policy by clicking on the link Taxi Allowance Policy alternatively visit our web portal >>Human Resources >> Policies.

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8.5 Learning and Development

One of the most important resources of the Firm is its people.

Thus, the Firm’s greatest concern is also with the growth and development of each employee in the particular field of profession they are currently in. The Firm provides in-house and outsourced training to all employees which they have to meet at the end of the year.

8.5.1 Training Needs Analysis

A Training Needs Analysis (TNA) is a review of learning and development requirements for all employees regardless of position and department within the Firm. It considers technical skills, knowledge and behaviour that the employee needs and how to be developed effectively.

An annual assessment of learning needs will be conducted by the Partners to meet the required training hours set to each employee. The Firm believes that people’s career ambitions and personal development objectives are important.

The Firm considers several methods on how to meet the learning needs set out to each employee. The following methods are being considered:

In-House Courses/Training External Training Courses Conferences and Events Professional Courses and Qualifications

8.5.2 Professional Exam Subsidy

Click on the link Professional Exam Subsidy Policy

8.5.3 Training Bond

Click on the link Training Bond policy

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9 YOUR PEERS AND YOUR PERFORMANCE

9.1 Key Performance Indicator (KPI)

The company is committed to support every employee to reach his/her potential and achieve their goals, which in turn will assist the organization to achieve its objective. The appraisal process aims to improve the effectiveness of the organization by contributing in achieving a well-motivated and competent workforce. It’s an ongoing process based on KPI (Key Performance Indicators).

The evaluation of performance will be based on two categories i.e. Financial Performance & Non-Financial Performance.

Annual Performance Discussion will start in End of every year, which will be linked to career progression; Management is going to follow the 5-point rating scale to evaluate the individual appraisal.

Bonus will be also paid between April to July every year based on final approved rating you got in the previous calendar year.

Management, Line Managers and HR will be involved in discussions for the Appraisal and Bonus Process and your direct supervisor would share your formal KPIs with you.

The implementation of performance management through timely appraisals is the responsibility of managers across all levels of the organization. It is your responsibility to work to attain and maintain acceptable standards of performance.

The Company may initiate a Performance Improvement Plan for some employees and re-evaluate the performance after stipulated period of time. In.Corp may see fit to additionally do a compensation review from time to time on gauging market trends, legislative changes, and economic fluctuations.

All promotions, changes in designation or any other changes in the terms and conditions of appointment will be intimated to you by the Company. Apart from receiving an equitable salary and equal opportunity for professional development and advancement, you will enjoy other benefits as specified under the Employee Benefit policies.

Listening to employees' insights and suggestions for improvement will provide the organization with valuable information that can be acted upon to increase the level of employee engagement in the workplace. Employee surveys are an important tool to solicit employee feedback. We perform these surveys once a year.

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These surveys are administered internally and all responses remain anonymous. Employee engagement surveys provide a way to improve productivity and emotional commitment by identifying the root causes of workplace issues.

9.1.1 Promotion

a) An employee may be considered for a promotion, subject to the following, based on the Annual Performance Management:

i. A higher level job vacancy is availableii. The employee demonstrates good performance as indicated through the Performance

management exercise

b) The Company may promote an employee at its absolute discretion and approval from the CEO.

9.1.2 Performance Bonus

a) The Company may at its absolute discretion pay a performance bonus to confirmed employees based on their performance as well as the financial performance of the Company during the year under review based on the Annual Performance Management Process.

b) Confirmed employee who has less than 12 months of service with the Company and has joined the company before September 1st may be paid pro-rated bonus, at the discretion of the Company provided that the employee is still in employment as at the end of the Financial Year of the year under review.

c) Payment of bonus to any employee who are serving their notice of resignation as well as employees who are under disciplinary action shall be at the discretion of the Company.

9.2 Performance Evaluation Discussions

The purpose of the discussions is to provide an opportunity (for both Immediate Superior and their respective employee) to discuss the job performance during the period under review as well as to plan for future performances objectives as well as development program of the employee. The session will require careful planning and preparation of the Immediate Superior as well as the employee.

Immediate superior should make relevant preparation prior to the discussion (with relevant input and/or feedback) in regards to the employee’s performance evaluation. If the employee disagrees with the performance evaluation review, they should be given ample opportunity to explain their rationale.

At the end of the discussion, the employee should review the performance evaluation, provide any comments and sign the form indicating the results that have been discussed. If the employee refuses to sign the evaluation form, the Immediate Superior should indicate this on the form.

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Click on the link for Annual Performance Evaluation Process

10 THE DAY OF DEPARTUREExits of employment for all employees will be handled and managed by Human Resource department in compliance with the prevailing laws and regulations.

10.1 Resignation10.1.1 Notice of Resignation

a) An employee who voluntarily intends to resign from the services of the Company is required to serve the stipulated notice period.

b) Notice of resignation shall be dated and signed, addressed and directed to the Immediate Manager and copied to Human Resource specifying the last working day in the Company.

c) Once HR receives your resignation, HR will pass the acceptance of resignation to the employee.

10.1.2 Notice Period

a) Either party may terminate the contract of service by giving the other party the following notice in writing, or payment in lieu of notice.

Assistant Level up to Team Lead 2 months Manager/Director and above 3 months

b) The required notice period will be mentioned in your offer letter.

10.2 Breach of contract

An employee who has been absent from work for a consecutive period of more than two (2) consecutive days without reasonable excuse or without having informed or attempted to inform his/her superior is deemed to have breach the contract of service and shall be deemed to have terminated/abandoned his employment with the Company.

The immediate Manager is responsible to report such incident immediately to the Head of Company and Human Resource.

Based on report, Human Resource Department will take the necessary actions which may result in the termination of the employee concerned. Such decision shall be discussed with the respective the Head of Company and/or Executive Director

10.3 Leave balance

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Any leave balance of a resigned employee may be used to offset against the notice period or compensated (to the employee), subject to the approval by the respective Group Head. The Management may permit the unutilised annual leave or part thereof to be deducted against the required notice period at its absolute discretion.

10.4 Exit Interview

Employees who voluntarily resign from the services of the Company will undergo an exit interview session conducted by the Human Resource Department. The session shall be documented using Exit Interview Form

10.5 Retirement & Re-employment

In line with the Minimum Retirement Age as per Retirement & Re-employment Act (RRA), the normal retirement age for all employees shall be sixty two (62) years old.

Employee retires the same day he/she turns sixty two (62).

At the discretion of the Company and employee fulfilling the eligibility criteria of re-employment as per RRA, an employee may continue to remain in employment beyond the normal retirement age on a fixed term contract for a period not more than two (2) years. The Company may at its absolute discretion extend the contractual period of employment if necessary.

Your re-employment contract should be for at least 1 year, renewable every year up to age 67.

Note: Kindly refer to the web link http://www.mom.gov.sg/employment-practices/re-employment for updated information on retirement and re-employment.

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