Code of Conduct

---

Purpose

Golden
Cougar’s Code of Conduct is the standards and values that we set ourselves as a responsible corporate citizen with transparency and ethical business conduct. Our code of conduct contains the fundamental policies, statements and commitments for our employees and other stakeholders.
Golden Cougar’s code of conduct is an integral part of the employment, provide structure and guidance for value-based decision making and inform rights and entitlements of employees.
The Codes apply to all entities within Golden Cougar and every employee need to understand, comply and not to tolerate misconduct.

Policies

• Anti-Corruption and Anti-Bribery Policy
  • We adopt zero tolerance policy on any form of corruption or bribery.
  • We do not give (or) we do not accept bribe or improper inducement to anyone for any purpose.
  • Golden Cougar uphold all laws and regulations for corruption and bribery on which we operate both local and other territories.
  • Gifts, Hospitality, Charitable Donations and Facilitation Payments must comply in accordance with our Anti-Corruption and Anti-Bribery Policy.
  • Anti-Corruption and Anti-Bribery Policy apply to all entities of Golden Cougar including every employee, shareholders, contractors, agents, regulators and governments.

• Human Rights Policy
  • Golden Cougar respect Human Rights and Labor Standards.
  • Golden Cougar’s Human Rights Policy is based on the International Bill of Human Rights, including Universal Declaration of Human Rights, The United Nations Guiding Principles on Business and Human Rights and International Labor Organization’s Declaration on Fundamental Rights and Principles at Work.
  • Golden Cougar’s aim to create a capacity team with our precious employees by treating mutual respect, trust and integrity.
  • Our Human Rights Policy include –
    • Protection of key Issues of Human Rights
    • Protection of key Issues of Labor Rights
    • Protection of Rights of Children
    • Protection of Rights of Community
    • Due diligence in implementation and protection of Human Rights policy are our core commitment.
    • Human Resource department and Legal and Compliance department are responsible for employment and jurisdiction concerns for every employee.
    • Violation of Human Rights will take immediate action

• Health, Safety and Environment Policy
  • Safety is our core value and our commitment is to provide health and safety environment.
  • Golden Cougar provide a strong Health, Safety and Environment Policy with Health, Safety and Environment manual and training to every person in Golden Cougar’s Premise.
  • Golden Cougar comply with all environmental legislations and practices in a standard of Reduce, Reuse and Recycle of resources or materials.
  • Golden Cougar support Healthy and Safety Environment, Work system and equipment and every person have share responsibility need to comply.

• Grievance Policy
  • As a responsible corporate citizen with honest manner and ethical business conduct, we treat every person of employee or community in a fair, justice and dignity culture.
  • Any grievance that deal with in our workplace or in local vicinity can raise to our local managers, Head of Legal and Compliance (or) Human Resource department.
  • Grievance will resolve with transparent, fair and justice manner and immediate action.

• Land Acquisition Policy
  • Even we have no previous history of problems or reports in Land Acquisition, we commit to comply with principles and performances in line with regional laws and regulations and International standard of United Nations Declaration on the Rights of Indigenous People (UNDRIP/ Article 10)
  • As on our Grievance policy, Legal and Compliance department is appointed to raise any concerns and resolve them.

• Whistle Blowing Policy
  • Every person can raise concern through the communication channels in Whistle Blowing Policy.
  • These concerns may be any grievance, or wrong doing activities to our policies and code of conduct or suspicion of malpractice activities deem to be illegal.
  • Any Whistle Blower who make in good faith and without malice will be protected without any risk.

Organizational Transparency

• Golden Cougar is transparent in complying with laws, regulations and policies and also in dealing with all stakeholders.
• Our adopted policies, principles and the code of conduct are published in our Employee Handbook and also accessible in our company website both in MYANMAR and ENGLISH languages.
• All accessible communication channels are also included in handbook and website. (Address, Phone, Fax, Mail, Website)
• Our organizational structure, our responsible bodies and our annual reports are also available in our website.

Our Responsible Bodies

Golden Cougar set up the responsible bodies for management and regulations of the company.

• The Executive Committee
• Management Committee
• Legal and Compliance Department
• Human Resource Department

Confidentiality and Safeguard

• All employees have a duty to protect company’s interest, intellectual property, and information.
• Information which are commercial or confidential are maintained under the code of conduct and not be released without permission by the Management.
• Disclosure of any confidentiality and information without permission may lead to disciplinary action.

Violation of the Code

• All employees are expected to act honestly and deal fairly by complying the code of conduct and policies in all their activities.
• Violation of the code may lead to disciplinary action up to termination.
• If any employee is uncertain how to conduct, they can freely and openly discuss or contact to Human Resource Department or Legal and Compliance Department.