Blog

This applies to all employees of the Group excluding the executive Chairman and the Group CEO.

Group Human Resources is responsible for developing, implementing and communicating this policy.

The employee has primary responsibility for following the provisions of this policy.

The employee’s immediate Superior has the responsibility for determining whether the business expenses are reasonable and necessary and for approving such expenses.

The local BU’s Finance Manager is responsible for reviewing employee Business Expense Reports for proper documentation, accuracy, and compliance with the provisions of this policy.

Intentional misrepresentation of travel and entertainment expenses which diverts the Company funds or assets for personal use shall be construed either as an act of misappropriation or fraud which is subject to severe disciplinary action.

Travel Reservations

The employee must obtain approval prior to issuing of air-tickets and hotel confirmation.

If a travel agent is used, it must be an approved one to leverage discounts. Direct online booking is permissible to reduce cost.

Travel plans and reservations should be made as far in advance of the date of travel as possible and at least 7 days in advance to take advantage of less costly advance purchase fares. Any bookings less than 7 days will require reasonable justifications and must be signed off by respective travel approver.

Travel industry promotional program benefits (such as frequent flyer miles) may be retained by the traveler but must not be the basis for selecting a particular travel supplier.

Air Travel

• The Group’s standard class of airline service is Economy for all level of employees. Upgrade from Economy class to Business class travel may be granted for Head of Function at Group level and Head of Entity, by the Entity Head or the Group CEO for themselves only for long-haul travel exceeding 5 hours consecutive fly time and with arrival at destination on a workday.
• When several travel options are available, being carrier or routing, the most economical should be chosen, keeping in mind that reasonable transit time should be applied.
• Travel on budget airlines is highly recommended.
• If the airline ticket includes a personal side trip, the employee must pay the difference between the lowest fare class of business trip routing and the actual price of the tickets issued.
• The Protocol department (protocol@spa-mm.com) can assist and advise on all Visa related matters.

Hotel

Travelers are expected to select the lowest cost hotel type (limited service, economy, extended stay, and so forth).

• Employees should use standard-class rooms. If family members or friends travelling on the same trip, employees shall pay for the difference of occupancy rate and related taxes based on Single occupancy.
• Traveler’s (Employees and Candidate from abroad) into Yangon are advised to primarily use company service apartments either in Star City or Pun Hlaing Golf Estate unless other economical alternatives are available.
• To avoid no-show charges, it is the responsibility of the traveler to cancel hotel reservations and obtain a cancellation number as soon as it is known that the rooms are not needed.

Local Transportation

• Taxi fees, Uber, Grab / MRT / MTR / subway etc. fees are reimbursable.
• Hotel accommodation.
• The Standard class of service for train travel is second class/ economy, except where first class is mandated by local regulations.

Employee Travel Limitations

• Limited the number of The Group personnel travelling together.
• Transportation or business travel should be arranged such that no single event could create a catastrophic loss of key personal for the Corporation. This means that when possible, no more than five Executive of the Company should travel on the same aircraft (be it a commercial, private, or corporate flight) or other vehicle of transportation. Pre-approval from Human Resources is required if more than half of an organization, group, or entity functional management team will be on the same aircraft.

Expense Reporting

To request reimbursement for travel/business expense, the electronic or hard copy expense report should be completed in detail, providing of the business purpose of all expenses.

• All travel expenses should be submitted within [20] days from the date of return.
• In the event where no official receipt of foreign exchange rate is not available, employee shall use the exchange rate obtained from //www.xe.com/currencyconverter/ using the date of departure as reference.

Reimbursable Expenses

Travel expenses charged to the Group should represent typical or economical levels of service.

The Group will reimburse employee for reasonable and necessary business expense, as determined by the Group and in compliance with legal and tax regulations. Reimbursable expense incurred while travelling on company business including but are not limited to:

• Taxis, Ubers, Grab etc.
• Hotel accommodations please refer to 4.3.
• Doctor-prescribed medicine or immunization which are recommended for international travel. If the prescription or immunization expense is not covered by the traveler's own medical plan, the full coast paid may be reimbursed. Non – prescriptive over the- counter medicines are not reimbursable.
• Visa fees - Laundry fees ( if the business travelling exceeding 7 business days).
• Communication charges incurred to conduct Group business. Data roaming should be on need basis.
• Customer business entertainment.

Business Meals and Entertainment

The reasonable cost of business meals and entertainment will be reimbursed if it is "directly related to "or" associated with" the active conduct of the business.

Directly related. In general, a business meal or business entertainment is directly related if three conditions are met:

• The company has more than a general expectation of driving income or a specific benefit for the meal or entertainment. However, the company is not required to show that income or specific business benefit actually resulted.
• The company did, in fact, engage in business discussions during the meal or entertainment.
• The principle nature of the expense was the active conduct of a trade or business.

Daily allowance (Per diem)

The purpose of travel allowance is to ensure employee do not suffer a financial loss while traveling for business purpose and not to provide a cash incentive where employee can derive a monetary gain form

Staff are sent outside their base city/ overseas for conferences/ training/seminars paid for by the company with meals provided, no allowance will be paid.

The daily allowance is applicable for outside base city and regional travel to the countries as indicated in the table below. For countries not indicated, please seek guidance from HR department before trip.

This allowance is applicable for all staff except for Directors and Head of Departments.

Entertainment per diem (per day) shall be as follows:

• This policy covers the permanent stationed employees only.
• For claims outside this policy, please obtain guidance from your Entity Head and Management.
• Per diem is calculated based on days where employee is in that city/ country.
• For day trips where the time of departure and return is within 24 hours, it is considered 1 day for the purpose of calculating per diem.
• Business meals involving two or more Group participants. When a business meal involves two or more company personnel and when a company representatives is to pay for the meal, the individual with the highest level in the Group is to pay for the expenses for reimbursement.

Non- Reimbursable Expenses

The following are considered personal expenses and WILL NOT be reimbursed by the Company;

• Cost of photographs for passport application/renewal and visa applications
• Meals with colleagues other than those included in Business Entertainment
• Food or beverage for personal consumption other than those included in Business Entertainment
• Medicine bought over the pharmacy counter
• In – room movies
• Room services
• Barber/ hairstylist service
• Personal gifts
• Personal entertainment
• Any other expenses that are personal in nature

Lost or Stolen Personal Property

Employees shall be fully responsible for replacement cost for any lost / damaged of company properties due to negligence. Waiver or partial replacement cost should be reviewed on case by case basis by Group HR.

This policy is applicable all parties (including employees, job applicants, customers, suppliers, contractors etc.) who provide information to the Yoma Group. As part of our operations, the Yoma Group may need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, social security numbers, financial data etc.
The Yoma Group will collect this information in a transparent manner and with the full cooperation and knowledge of interested parties.

The Yoma Group will ensure that the personal data be:

• Collected fairly and for lawful purposes only
• Processed by the company within its legal and moral boundaries
• Protected against any unauthorized or illegal access by internal or external parties

Any personal data will not be:

• Communicated informally
• Stored for more than a specified amount of time

Transferred to organizations, states or countries that do not have adequate data protection policies.

Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities)

In the collection of personal information, the Yoma Group also undertakes to:

• Inform people that their data is collected
• Inform people about how data is processes
• Have provisions in case of lost, corrupted or compromised data

Allow people to request that any data provided in relation to themselves be modified erased, reduced or corrected in the databases.

Actions

The Yoma Group will:

• Restrict and monitor access to sensitive data
• Develop transparent data collection procedures
• Train employees in online privacy and security measures
• Build secure networks to protect online data from cyber attacks
• Establish clear procedures for reporting privacy breaches or data misuse
• Include contract clauses or communicate statements on how we handle data
• Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)

Disciplinary Consequences

All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.

1. Reporting Policy and Procedures

Reporting of Improprieties

The Company believes that it is in the best interests of the Group to promote an environment conducive for employees of the Group (the “Employees”) to, in confidence, raise or report concerns about Improprieties, without fear of Reprisals, and to put in place arrangements for the investigation of such concerns for appropriate follow-up action.

Publication of these Procedures

The Company shall disseminate and publish these Procedures to all Employees together with all updates and clarifications.

Authority to receive Complaints

All Complaints, including those involving a Director, member of senior management (having designation of “Head/Chief/Managing Director of a Division” and above) shall be addressed to the Non- Executive Director who may be reached at the following feedback communication channels:

Scan the following QR Code to report anonymously or report via whistleblowing@yoma.com.mm.

Right to file Complaint

Every Employee shall have an unfettered right to file a genuine and bona fide Complaint and shall not be restricted in the exercise of such right.

Prohibition of Obstruction

The Company objects to and does not tolerate nor condone any Obstruction cause against any Employee who wishes or intends to file, or who is in the process of filling, a Complaint, and may
institute such disciplinary action as it deems appropriate against any employee, officer or agent of the Group found to have caused or attempted to cause any such Obstruction.

Prohibition of Reprisals

The Company objects to and does not tolerate nor condone any Reprisals made against any Employee who has filed or attempted or intends to file a Complaint and may institute such disciplinary action as it deems appropriate against any Employee found to have made or attempted to make any such Reprisals.

Any Complaint alleging Obstruction or Reprisals shall be received, reviewed and investigated in the same manner as any Complaint alleging Improprieties.

2. Complaint Procedures

Procedures for handling Complaints

The procedures for the receipt, retention and treatment of a Compliant are set out below and shall be fully complied with.

Submission of Complaint

Every Complaint may be sent to or lodged in the manner described in paragraph 1.3 above.

Confidentiality of Identity

Employees are strongly encouraged to disclose their identity when lodging Complaints. The identity of all Employees who have lodged Complaints shall be kept confidential save where:

• the identity of the Employee, in the opinion of the Management, is material to any investigation; it is required by law, or by the order or direction of a court of law, regulatory body or by the Myanmar Exchange or such other body that has the jurisdiction and authority to require such identity to be revealed;
• the Management is if the opinion that it would be in the best interests of the Group to disclose the identity;
• it is determined that the Complaint was frivolous, in bad faith, or in abuse of these policies and procedures or lodged with malicious or mischievous intent; or
• the identity of such Employee is already public knowledge by reason other than disclosure under this paragraph 2.3.

Registration of Complaints

A Complaints Register shall be maintained or caused to be maintained for the purposes of recording details of all Complaints received, including the date of such Complaint and the nature of such Complaint. The Complaints Register shall be made available for inspection upon any request of the Management.

3. Investigation of Complaints

Review and Investigation of Complaints

All whistle-blowing reports, other than reports involving any Director, member of senior management (having designation of “Head/Chief/Managing Director of a Division” and above) shall be received by the Director who will log all reports into a register. The Director shall conduct an initial review of the report received and recommend the remedial, disciplinary or other action to be taken action taken by the Company. All investigations shall be reported to the Management for their attention and further action as necessary.

In the event that the whistle-blowing reports involve any Director, member of the senior management or the Non executive Director, the reports shall be escalated to the Chairman of Board, for his attention and further action as necessary.

Determination by Management

Upon receipt of any Complaint, the Management may:

• conduct its own investigation or review;
• instruct the internal auditors or external auditors other professionals to conduct further investigations or review;
• instruct management to take such remedial, disciplinary or other action as it deems appropriate;
• engage such third parties as the Management may determine, to commence or conduct further investigations or review;
• engage such third parties as the Management may determine to take such remedial, disciplinary or other action as it deems appropriate; and/or
• take any other action as Management may determine in the best interests of the Group.

The Company reserves the right to take such action as the Management deems appropriate against any such Employee.

Abuse of Policies and Procedures

The Group may, upon determination by Management, take or cause to be taken such action as is appropriate against any Employee who has made a Complaint frivolously, in bad faith, in abuse of the policies and procedure herein or lodged with malicious or mischievous intent.

4. Consistency with Laws and Regulations

These Procedures shall be read in conjunction with any laws, regulations, rules, directives or guidelines that may from time to time be prescribe or issued on the receipt, retention and/or treatment of complaints regarding the subject matter of these Procedures.

In the event that any of these Procedures is inconsistent or in conflict with any such laws, regulations, rules, directives, or guidelines or any part thereof, any such laws, regulation, rules, directives or guidelines shall prevail to the extent of such inconsistency or conflict.

5. Interpretation

The following terms used in these Procedure shall have the meaning ascribed here;

• “Complaint” means any complaints alleging Improprieties, Obstruction or Reprisals;
• “Complaint Register” means a register to record detail of all Complaints lodged;
• “Group” means the Company and its subsidiaries;
• “Improprieties” means any activity, conduct or omission by an employee, officer or agent of the Group or external advisers, consultants or professional firm (including auditing firms providing external or internal auditing services) engaged by the Group which relate to accounting, financial reporting, internal controls, internal accounting controls, financial, operational and compliance controls or risk management practices that are questionable or may not be in accordance with generally accepted accounting principles, standards or practices or which relate to issues of honestly or integrity or the commission or any act or activity which may be contrary to any law or regulation;
• “Obstruction” means the use or attempted use of force, authority, intimidation, threats, harassment, coercion, undue pressure or any other action or behavior which is intended or leads itself to or in fact does impede, obstruct, influence or otherwise interferes with an employee’s or officer’s exercise of his right to report any improprieties or Reprisals or which may discourage other from so doing in the future; and
• “Reprisals” means the use or the attempted use of force, authority, intimidation, threats, harassment, coercion, undue pressure or any act or omission or any negative or other inappropriate behavior by any employee or officer of the Group, against any person who has failed or intends to file a Complaint.

Download PDF

The Policy applies to all recruitment within the Group. It is to ensure there is a standardized process to assist managers in selecting and hiring the best candidate for the relevant position. Variations may exist to comply with local legal regulations, health and safety and operational requirement of the business. Where a variation is required, it must be reviewed and approved by Group HR. The Group undertakes to comply with relevant legislation that relate to the selection and hiring of candidates.

Recruitment of SPA / FMI / YSH employees will be based on merit in fair and open competition without patronage, favoritism or discrimination based an individual’s race, ethnicity, religion, creed, gender, national origin, age, disability, marital status, sexual orientation or any other status protected by applicable law.

Vacancies will be advertised internally, and internal employees given opportunity where they meet the relevant position requirements. External recruitment may be undertaken in parallel, as appropriate.

The Company will amend this policy on a regular basis, as required.

The Group Human Resources Talent Acquisition (Group HR) is responsible for developing, implementing and communicating the policy.

The Hiring Manager is responsible to ensure that necessary approvals including budget, determine the scope and requirements of the vacancy and provide a completed Employment Requisition Form (ERF) and Job Description (JD).

Group HR will manage executive and senior hires across the Group and functions within Corporate. Where appropriate, Group HR will assist recruitment within the entities however, Entity HR will generally manage entity level non- management positions. Both Group HR and Entity HR have the responsibility to ensure approvals are in place, to assist in determining the recruitment channels to be used, and to drive the sourcing of candidates, as well as ensuring that an appropriate recruitment panel is appointed.

Both Hiring Manager and Group HR/Entity HR will be responsible in assessing conflicts of interest and will be taken into consideration in hiring, transfer, or promotion staff.

To help create a working atmosphere in which all employees can function together as an efficient and effective team.
To develop individual responsibility and respect towards his/her work, the Yoma Group’s property, co-workers and superiors.

To define and established tangible penalties for various offense.

To disseminate the policy regarding the disciplinary action adopted by the Group for infractions against the Yoma Group’s rules and regulations and the procedures for the enforcement of the disciplinary actions.

This section applies to all employees irrespective of whether full-time, part-time or temporary workers.

The Human Resources Department will ensure that during orientation that all employees have access to a copy of the Employee Handbook.

It is the responsibility of the management to reinforce adherence to the contents of the Code by all employees under their direct supervision.

It is the responsibility of the Human Resources Department to conduct an independent and impartial investigation on the breach of discipline where dismissal or suspension is considered, to determine if the recommended disciplinary action is appropriate.

Enforcement, of the Yoma Group’s policies and disciplinary action are generally intended to educate the employees and are not intended as a punishment. Its main purpose is to correct, rehabilitate, and maintain general discipline in the organization. It is only in those cases where there is wilful and intentional desire to violate these rules and regulations, when the offense is very serious, or when prior attempts to correct have failed; that the Yoma Group will be compelled to dismiss an employee.

However, if disciplinary actions have to be imposed, the penalties shall be progressively applied depending on the gravity of the offence. The employees’ entire past record and performance shall also be taken into account. The management and the Human Resources Department will determine the offense or violation committed so that proper investigation can be made.

The above disciplines will depend on violation and following the regulation of Misconduct.
Misconduct

• Poor attendance / tardiness
• Poor job performance
• Poor attitude
• Discourtesy
• Disobedience of Health / Safety regulations (Where no damage to the Yoma Group’s property or injury to life is present)
• Breach of rules of a less serious offence other than those listed above.

The employee should be counseled, and the incident recorded in file. A verbal warning will be issued by the respective Section/Department Heads as deemed fit on repeated offence and/or any other offences committed. One verbal and two written warnings will be issued prior to a termination of service or dismissal from service.

Disciplinary action that may be undertaken by the Yoma Group include a deferral of promotion or demotion.
The following offences are classified under Gross Misconduct which may lead to dismissal, termination of service, suspension from work, demotion or any disciplinary action as may be deemed fit by the Management.

• Theft
• Falsification of documents
• Gambling/betting/soliciting
• Fighting and disorderly behaviour
• Vandalism
• Obscene or immoral conduct
• Possession or use of intoxicants/drugs
• Dishonesty
• Disobedience of Health/Safety regulations (where damage of property or injury to life is present)
• Unauthorised meeting/Gathering
• Sleeping whilst on duty
• Involvement in politics during working hour or time
• Unapproved Fund raising/Collection
• Loitering
• Absence from work for more than 3 consecutive working days or 72 hours any without notice. or a total 5 absent days within a month without valid leave or excuse.
• Breach of rules of a more serious offence other than those listed above.
• Breach of the Yoma Group’s confidentiality policies.

It is necessary to track each employee’s record of offenses/ disciplinary actions reference. When a certain disciplinary action is imposed, it will be recorded in the personnel file to facilitate the review of the employee’s disciplinary action.

Recognizing the value and importance of full discussion in clearing up misunderstandings and preserving harmonious relations, reasonable effort shall be made to dispose of any grievance at the lowest possible level.

Step (1) You should take the matter up with your section head. The direct section head will reply within seven (7) working days.

Step (2) If you still feel aggrieved, you may take it up with your Entity Head. The Entity Head will reply in writing within seven (7) working days.

Step (3) If you are still not satisfied, you may take it up to the CEO. The CEO will reply within seven (7) working days.

In addition to the Code, the Yoma Group expects employees to comply with all laws, regulations and legal requirements applicable to the different jurisdictions where it operates.

The Yoma Group, through our Group of Companies have been signatories to the UN Global Compact and its 10 principles since 2012. The ten principles are listed below and apply to all group businesses and staff. More information can be found at , https://www.unglobalcompact.org/what-is-gc/mission/principles

In becoming a signatory to the Global Compact, we express our intent to advance those principles within our sphere of influence.  We are committed to making the Global Compact and its principles part of the strategy, culture and day to day operations of our company, and to engage in collaborative projects which advance the broader goals of the United Nations, particularly the Millennium Development Goals, Yoma Strategic Holdings Ltd. will make a clear statement of this commitment to our stakeholders and the general public.

The Ten Principles of the United Nations Global Compact:

Human Rights

Principle 1 : Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2 :  Make sure that they are not complicit in human rights abuses.

Labour

Principle 3 : Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4 : The elimination of all forms of forced and compulsory labour;

Principle 5 : The effective abolition of child labour; and

Principle 6 : The elimination of discrimination in respect of employment and occupation.

Environment

Principle 7 : Businesses should support a precautionary approach to environmental challenges;

Principle 8 : Undertake initiatives to promote greater environmental responsibility; and

Principle 9 : Encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principle 10 : Businesses should work against corruption in all its forms, including extortion and bribery

The Yoma Group is committed to provide a healthy and safe work environment for employees, customers, business partners and visitors. Every employee has a personal responsibility to support this commitment.

Employees are obliged to carry out their work in a safe manner, without causing harm to themselves or others, and to report any potentially unsafe or unhealthy situations immediately, including near miss events.

They must observe and follow all safety and environmental regulations laid down in the operation instructions, including putting on the necessary safety equipment, where applicable.

This commitment is shared with employees, customers, business partners, visitors, contractors, suppliers and related third parties.

Employees are responsible for property of the Yoma Group that may be entrusted to them. This property includes, but is not limited to physical property (such as phones, Yoma Group vehicles or computers), records (such as data on customers and Yoma Group records), and intangible property (such as computer software and computer records). It is important that, whichever category the property falls into, employees must treat the Yoma Group’s property as they would their own and must not damage it, deface it or remove it for personal use, unless authorized to do so.

Similarly, they are responsible for the proper expenditure of the Yoma Group’s funds including expenses. While spending or committing Yoma Group funds, employees must be sure that the transaction is properly documented, and that the Yoma Group receives appropriate value in return.

The Yoma Group is committed to providing quality and efficient service to all customers, and every employee has an important role to play. They are required to perform tasks assigned in a responsible and reliable manner and to manage time at work efficiently, without wasting Yoma Group time and resources by taking part in unauthorized activities including, but not limited, to trading, gambling or political activities on the premises.

At all times, every employee has a responsibility to treat colleagues with respect and consideration. Improper behavior includes, but is not limited to, discrimination or harassment in any form such as bullying, intimidation, threats, ridicule, sexual, racial or verbal abuse, insults, gestures, willful or serious insubordination, physical violence etc. The Yoma Group will not tolerate these behaviors and will take disciplinary action including termination or dismissal.

While on duty, employees must not conduct themselves in such a manner that will interfere with or prevent other employees from carrying out their duties properly.

The Yoma Group aims to be an equal opportunity employer that does not unlawfully discriminate against employees on the basis of an individual’s race, ethnicity, religion, creed, gender, national origin, age, disability, marital status, sexual orientation 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. The Yoma Group seeks to provide equal pay for equal work.

In accordance with this policy the Group treats civil partnerships to have the same status as legal marriages. For these partnerships there is often no official documentation, so to clarify the Group regards these are permanent in intent. Any abuse of this to claim benefits to which an employee is not entitled will be regarded as fraud.

Honesty in all dealings with the Government, businesses and other organizations is essential. Making of payments or payments in kind such as gifts or favors to influence individuals to award business opportunities to the Yoma Group or to make a business decision in the Yoma Group’s favor is prohibited.

Employees must always seek any third party's confidential information through the proper authorities. If given such confidential information, employees must ensure that they are entitled to have it, and obey the rules of having such information, if any.

They must always maintain good relationships with customers which is vital to the success of the business. Customers must feel that they are getting the highest standard of service from a company which listens to them and is responsive to their needs.

Information about customers and business partners must remain confidential and should only be imparted with full authority to do so.

Drugs and/or alcohol can impair an individual's capacity to perform his/her job safely, efficiently and with respect for colleagues and customers. The use of such substances may result in injury or a threat to the well-being of an individual, colleagues, customers or members of the public.

An employee must attend work in a fit state and must not to be under the influence of alcohol or drugs during working hours.

Involvement with the manufacture, possession, use, distribution, sale, purchase, or transfer of illegal drugs is strictly prohibited.

Information is a valuable asset of the Yoma Group and its integrity depends on the honesty, completeness and accuracy of its records. This means that anyone preparing the Group's records and reports must be diligent in assuring the accuracy and completeness of all data, records, reports and expenditure connected with the Group.

Employees must keep copies of the Yoma Group records such as installation data, customer records and test data at a safe location. For financial record keeping purposes, employees must not engage in any practice or procedure which might conceal, facilitate or constitute bribery, kickbacks, improper gratuities or other illegal or improper payments or receipts, or which might appear as such.

Many employees have access to information, which includes the trade secrets, know-how used by the Yoma Group to distinguish its businesses and services from those of competitors, as well as sensitive private business information of a commercial, technical or financial nature such as prospects, agreements with customers, business partners, competitors, account plans, business proposals, negotiations and contracts.

It is important that all Group proprietary information is kept confidential. Employees have a duty to safeguard the Yoma Group information, bearing in mind ethical, legal ramifications and government regulations. Information of commercial value or of a sensitive nature must be tightly controlled. For example, when releasing information to a third party for a bid proposal, a Non-Disclosure Agreement (format provided by legal department) should be signed by the third parties, and information released is on a need-to-know basis.

Any trademark, copyrights, patents, designs, registered designs, proprietary information and all other intellectual property rights developed and commissioned by the Yoma Group belong to the Yoma Group. Employees are reminded not to infringe any third parties' rights including, but not limited to, any third party intellectual property rights, copyrights, patents and trademarks.

The Yoma Group will hold exclusive property of any invention, discovery, design or improvements made. This could also include inventions employees may create which relate to the Group’s business, regardless of whether the invention or designs are patentable or are capable of being registered or copyrighted.

Employees must report these inventions to the Yoma Group and shall, at the Yoma Group's request and expense, disclose information relating to the invention and do what is required to obtain patents or industrial rights relating to the invention. The patents will be in the name of the Yoma Group or its nominee and the employee will not be entitled to any payment for the invention. The Yoma Group's ownership of any intellectual property created by employees while with the Group continues after they have left service.

When employees leave the Yoma Group for any reason, including retirement, they must return all the Group’s property, including all documents and records in their possession; they must not disclose or misuse Yoma Group’s confidential information. Employees are also responsible for protecting information provided in confidence by any third party, such as a customer, supplier or a partner, after they leave the Yoma Group.

A ‘conflict of interest’ arises when employees have a competing professional or personal interest that would either make it difficult to fulfill their duties properly, or would create an appearance of impropriety that could undermine customer or public confidence.

Employees must do nothing that conflicts with the interests of the Yoma Group, or anything that could be construed as being in conflict, for example, participating in the evaluation/approval of award to a vendor in which an employee has a vested interest (either personally, or through close relatives). Employees should declare/disqualify themselves from handling transactions which put them, whether perceived or real, in a position of conflict.

Employees must avoid all situations which could result in conflicts of interest. They should comply with reporting and disclosure requirements of potential or actual conflicts of interest, and disclose any matters which could reasonably be expected to interfere with their professional duties.

Employees should not engage in any outside business dealings that involve or could appear to involve, a conflict between their personal interests and the interests of the Yoma Group (i.e. conflict of interests).

Employees must not have any direct or indirect financial or business interest in or dealings with competitors, suppliers, customers or anyone else with whom they are engaged in a business relationship on behalf of the Yoma Group, which might or might appear to, create a conflict of interest, or impair the judgments they make on behalf of the Yoma Group.

They should also not engage in any personal business dealings which detract from or conflict with their employment in the Yoma Group.

Employees must avoid situations where their loyalties may be divided between the Group's interest and those of a customer, supplier or competitor.

Employees must not take advantage of any opportunity for personal gain that rightfully belongs to the Yoma Group. They should avoid putting themselves in any situation which might, or might appear to put them at a personal advantage, and they must report any potentially compromising situation to their supervisors promptly.

Employees should not engage in any outside employment or hold any position without the prior written consent of Human Resources unless such employment has been arranged or is undertaken in connection with the performance of their responsibilities and duties as part of the enlarged Yoma Group.

If employees are considering accepting an external appointment, they must consider if accepting this position may give rise to the possibility of conflict. If they have been given permission to take on such employment or to have other business relationships, they must ensure that these activities do not negatively affect their ability to fully and effectively perform their role for the group or reputation and/or its services to customers or the Yoma Group’s current or future business plans.

Employees must not use "inside" information - information which has not been made available to the public and which may materially affect a corporation’s stock price - as the basis for purchasing, or selling, shares in the listed entities in the Yoma Group, or any other company with which they have dealings. Such information may include unannounced earnings, dividends or potential acquisitions. Employees must not engage in, or procure another person to engage in, any share transactions with respect to the shares of the corporation, whether it is for themselves, anyone else or for the Yoma Group, when in possession of inside information.

The acceptance of gifts from customers, existing and/or potential, business partners, suppliers, contractors, competitors or members of the public is prohibited as it may create a situation of conflict or potential conflict of interest.

Retention of Gift

Gifts not exceeding 100,000 kyats (or equivalent in a foreign currency) can be retained by the employee. All gifts exceeding 100,000 kyats must be recorded in a registry maintained by the relevant business head detailing the description of the gift, the name of the person providing the gift and the manner in which such gift was disposed of. Gifts exceeding 100,000 kyats can be retained by the employee if it has been declared to and approved by the relevant business head. It should be noted that retention of gifts is allowed only if they are received under non-obligatory circumstances.

As business lunches/dinners are an accepted mode of hospitality, these need not be declared but care must be exercised while accepting such meals. These should be infrequent. The sole purpose must be for enhancement of a business relationship and not for reciprocity.

It is important that news about all Yoma Group activities – from new partnerships to new services – be properly coordinated. All media requests for information and interviews should be referred to Group Communication and Investor Relations Division in Singapore and Yangon.

Statements made in any online forum (e.g. web logs or blogs) or social networking sites (e.g. Facebook) are considered to be public statements. No comments regarding the Yoma Group, its business, products, services, strategy or practices as well as employee should be made without prior approval from Management. Where employees do participate in blogs or any other online space, even personal sites maintained outside of work hours, they should take care to ensure not to in conflict with the best interests of the Yoma Group.

Where an employee has concerns, or receives information about any fraud in connection with the affairs of the Yoma Group, it is the employee's responsibility to report those concerns or information.

The Yoma Group adopts a "zero tolerance" approach to fraud and has implemented a formal policy, the Whistleblower Protection Policy which sets out the procedures for reporting and investigating fraud in connection with the business and affairs of the Yoma Group.

Breaches of this Code could result in disciplinary action up to and including termination, as well as compensation for damage caused

Social media is a place where people exchange information, opinions and experiences to learn, develop and have fun. The Yoma Group’s Social Media Policy provides a framework for using social media.

This Policy provides employees with clear guidelines on the acceptable use of social media and practical advice to avoid issues that might arise by careless use of social media in the workplace and private space.

“Social media” refers to all types of social media platforms and communication tools that exist and provides for the sharing of information to user groups or the public at large. Online communications may include posting or publishing information via social media applications, uploading and/or sharing tweets, photos, images or videos, direct messaging, status updates or any other form of interaction and/or communication facilitated by social media.

The tools include, but are not limited to, the following:

• Social networks such as Facebook, Instagram, TikTok and Twitter;
• Blogs including corporate blogs and personal blogs, and blogs hosted by media outlets;
• Online forums, discussion boards, podcasts and groups;
• User generated media sites such as YouTube and Snapchat.

Note that an employees’ behavior reflects the Group even when the employee is not speaking on the company’s behalf and/or what they post and share on their personal social media.

How a Yoma Group employee should behave when participating in social media is covered in detail below and all employees are required to understand and adhere to this Policy. The company may monitor postings and review for compliance with the Group’s policies. Any breach of company policies may result in disciplinary actions being taken and may include termination.

Employees are advised to:

Before they post, ask if the post would embarrass themself or other people or harm the reputation of the company. Keep in mind the impact their comments may have on others and the Group.

Use appropriate language. It should be polite and respectful, and no vulgar, coarse language or swear words should be used at all times.

Do not post or upload anything defamatory, threatening, harmful, sexually or racially offensive and obscene, disparaging, vulgar or otherwise objectionable. Avoid posting any material that:

• constitutes harassment, hate speech, or libel;
• violates the privacy rights of fellow employees; or
• is disruptive to the work environment because it impairs workplace discipline or control, impairs or erodes working relationships, creates dispute or strong disagreement among co-workers, interferes with job performance, or obstructs operations.

Do not bully, harass, humiliate, abuse, impersonate or intimidate others. Avoid any defamatory, offensive or derogatory content. It may be considered as a violation of our company’s anti-harassment policy, if directed towards colleagues, clients or partners.

Do not post photos and videos that could negatively affect any employee, their job, their co-workers or the company.

Do not misrepresent themself or their role in the Group. Ensure others know that their personal account or statements do not represent our company by stating that it is their opinion. Employees should not state or imply that their personal opinions and content are authorized or endorsed by the company. We advise using a disclaimer such as “opinions are my own” to avoid misunderstandings.

Be mindful of privacy: Safety is our No. 1 priority. Do not give out any personal information about themself or anyone else (eg. home address, telephone numbers or any confidential information.)

Confidentiality policies and laws always apply. Do not share intellectual property such as trademarks on a personal account without approval.

The Yoma Connect and Workplace platforms are set up for internal communication purposes. Do not share content posted on this platform unless the employee has received permission from the person who posted or from HR.

If employees neglect their job duties to spend time on social media, their decline in productivity will show on their performance reviews. Whether employees are handling a corporate account or use one of their own, they should remain productive. The Yoma Group will differentiate between an employee’s use of personal social media at work and the use of corporate accounts as may be required in the performance of the duties.

Employees representing our company :

Some employees represent our company by handling corporate social media accounts or speak on our company’s behalf. We expect all employees to act carefully and responsibly to protect our company’s image and reputation.

Employees should:

Be respectful, polite and patient when engaging in conversations on our company’s behalf. Be extra careful when making declarations or promises towards customers and stakeholders.

Avoid speaking on matters outside their field of expertise when possible. Everyone should be careful not to answer questions or make statements that fall under somebody else’s responsibility.

Follow our  confidentiality policy and  data protection policy and observe laws on copyright, trademarks, plagiarism and fair use.

Do not use company logos without approval from Group Communications or relevant Marketing and Communications team.

Inform Group Communications or relevant Marketing department when employees are about to share any major-impact content.

Avoid deleting or ignoring comments for no reason. They should listen and reply to criticism.

Never post discriminatory, offensive or libellous content and commentary.

Correct or remove any misleading or false content as quickly as possible.

Disciplinary Consequences

The Yoma Group will monitor all social media postings on its corporate account.

Disciplinary action may be taken if employees do not follow this policy’s guidelines. Examples of non-conformity with the employee social media policy include but are not limited to:

• Disregarding job responsibilities and deadlines to use social media.
• Disclosing confidential information through personal or corporate accounts.
• Directing offensive comments (defamatory, threatening, harmful, sexually or racially offensive and obscene, disparaging, vulgar or otherwise objectionable) towards other members of the online community.

Yoma Group reserves the right to direct an employee to immediately and permanently remove content published on any Social Media channel if the content is in breach of this policy or if it is deemed inappropriate.

An employee’s responsibilities are not only to comply and act in an appropriate fashion but to also report inappropriate posts and behaviour they may observe on social media platforms.

Every employee owns the consequences of their actions. Disciplinary action may be taken not just for posts on the corporate account, but more generally for actions that do not reflect the company’s mission and values.

Disclosure of Official Documents, Information and Trade Secrets

All documents, papers and information acquired in an employee’s official capacity or otherwise should be treated as confidential and trade secrets of the Yoma Group. Employees must not copy, reproduce, extract, translate or in any way deal with them in a manner that is not authorized or allow others to do so, or disclose, publish or communicate them to the Press or to individuals whether directly or indirectly unless it is in the course of their official duties or if it is lawfully required or authorized by any Court of law or with authorization from the Management. This clause shall continue to apply even after they are no longer employed by the Yoma Group.This policy affects all employees, including board members, investors, contractors and volunteers, who may have access to confidential information.
Confidential and proprietary information is secret, valuable, expensive and/or easily replicated. Common examples of confidential information are:

• Unpublished financial information
• Data of Customers/Partners/Vendors
• Patents, formulas or new technologies
• Customer lists (existing and prospective)
• Data entrusted to our company by external parties
• Pricing/marketing and other undisclosed strategies
• Documents and processes explicitly marked as confidential
• Unpublished goals, forecasts and initiatives marked as confidential
• Employees may have various levels of authorized access to confidential information.

What employees should do:

• Lock or secure confidential information at all times
• Shred confidential documents when they’re no longer needed
• Make sure they only view confidential information on secure devices
• Only disclose information to other employees when it’s necessary and authorized
• Keep confidential documents within the Yoma Group’s premises unless it’s absolutely necessary to move them

What employees shouldn’t do:

• Use confidential information for any personal benefit or profit
• Disclose confidential information to anyone outside of our company

Replicate confidential documents within the Yoma Group’s and files and store them on insecure devices
Upon termination or expiry of the employee’s employment with the Yoma Group, employees are obliged to return any confidential files and delete them from their personal devices.

Confidentiality Measures

The Yoma Group takes measures to ensure that confidential information is well protected, including but not limited to:

• Storing and locking paper documents
• Encrypting electronic information and safeguarding databases
• Requiring employees to sign non-compete and/or non-disclosure agreements (NDAs)
• Requesting for authorization by senior management to allow employees to access certain confidential information
• Exceptions
• Confidential information may occasionally have to be disclosed for legitimate reasons. Examples are:
  If a regulatory body requests it as part of an investigation or audit
• If our company examines a venture or partnership that requires disclosing some information (within legal boundaries)
• In such cases, employees involved should document their disclosure procedure and collect all needed authorizations, and should not disclose more information than required.

Disciplinary Consequences

Every breach of the confidentiality policy will be investigated. Employees who do not comply with the confidentiality policy will face disciplinary and possibly, legal action. In the event that any employee willfully or regularly breaches the confidentiality policies for personal benefit, the Yoma Group reserve the right to terminate the employment of such employee immediately. This policy is binding even after termination or expiry separation of employment.

Individual goals are defined at the beginning of the performance cycle. Performance progress will be reviewed at the end of every quarter to have formal feedback discussions and focus on development areas in more regular basis to achieve the annual goals.

Annual Performance Appraisal is conducted at the end of March. Individual performance progress will be assessed from two perspectives: The what: Achievements and the How: Behavior.

“We invest in our people to build careers around a shared culture of fairness, diversity, empowerment and recognition”

As such we believe that employees should have a Career Plan which is determined and reviewed from time to time with their Manager.

Training programmes for skills relevant to the employee’s job and other skills will be made available to employees from time to time. Attendance and participation may be mandatory and employees may be required to attend such programmes whenever scheduled.

The Yoma Group also encourages employees to learn new skills related to their present position or to positions within the Yoma Group through cross training programmes and developmental programmes.

Training Programmes in Leadership Development, Professional Development (Hard Skill / Soft Skill) , Product & Service Development & Financial Awareness will be provided. Programmes are available for employees in both online (Digital learning) & offline (classroom learning) formats.

The employee is encouraged to discuss such interests with their immediate superior or the Human Resources Department before signing up for any course of study or training.

Mandatory deductions (such as personal income tax and social security board) shall be made from the employee’s monthly salary. All deductions from an employee’s wage shall be in accordance with applicable laws, and reflected in the monthly employee’s salary slip.

Any deductions from wages / salary shall be in compliance with the relevant legislation. and will be reflected in the monthly employee’s salary slip. Respective HR department will inform the employee of the deduction to the employee’s salary before the payroll period.

Salary structures are reviewed annually to ensure that they remain competitive. In addition, employee’s performance is also reviewed on an annual basis and employee’s salary may be reviewed or increment may be given at the discretion of the Yoma Group Management.