NO GIFT POLICY

1. INTRODUCTION

ZAIYADAL KELUARGA SDN BHD (“ZKSB” or “the Company”) and its group of subsidiaries
(collectively, “ZKSB Group”) embraces a ZERO TOLERANCE POLICY against all forms of
bribery and corruption. ZKSB Group’s No Gift Policy (“Policy”) elaborates upon those principles,
providing guidance to employees concerning how to deal with situations relating to the receiving
and/or providing gifts that may arise in the course of business. ZKSB Group also expects that
contractors, subcontractors, consultants, agents, representatives and others performing work or
services for or on behalf of ZKSB Group will comply with the relevant parts of this Policy when
performing such work or services

2. APPLICATION

This Policy shall apply to every employee of the ZKSB Group.

Directors, contractors, sub-contractors, consultants, agents, representatives and others performing
work or services for or on behalf of ZKSB Group shall comply with it in relevant part when performing
such work or services.

3. DEFINITIONS

“Employee” means any person who is in the employment of ZKSB Group including but not limited
to executives, non-executives, and individuals on direct hire;

“Gift” or “Gratification” means anything of value, including – but not limited to – meals, lodging,
loans, cash, favourable terms or discounts on any product or service, services, equipment, prizes,
products, transportation, use of vehicles, vacation or other facilities, stocks or other securities, home
improvements, tickets, gift certificates, gift cards, discount cards, memberships and employment or
consulting relationships. The above are not exhaustive but are merely examples;

“Management” means the management level of ZKSB.

4. POLICY OWNER

The ZKSB Group’s Risk & Compliance Department is the owner of this Policy.

5. NO GIFT POLICY

5.1 Employees, or agents acting for or on behalf of ZKSB Group and Directors are prohibited
from, directly or indirectly, receiving or providing gifts.

5.2 It shall be mandatory for Directors, Employees, contractors and agents to abide by this
Policy to avoid conflict of interest or the appearance of conflict of interest for either party in
on-going or potential business dealing between ZKSB Group and external parties as a gift
can be seen as a bribe that may tarnish ZKSB Group’s reputation or be in violation of
antibribery and corruption laws.

5.3 A conflict of interest arises in a situation in which an individual is in a position to take
advantage of his or her role in ZKSB Group for his or her personal benefit, including the
benefit of his or her acquaintances and friends. This would undermine the duties of good
faith, fidelity, diligence and integrity as expected by ZKSB Group from its employees and
directors in the performance of their duties and obligations.

5.4 It is the responsibility of Employees and Directors to inform external parties involved in any
business dealings with ZKSB Group that ZKSB Group practices a “No Gift Policy” and to
request the external party’s understanding for and adherence with this Policy.

6. RECEIVING GIFTS

6.1 ZKSB acknowledges that the exchange of gifts can be a very delicate matter where, in
certain cultures or situations, gift giving is a central part of business etiquette. Despite
acknowledging ZKSB Group’s “No Gift Policy”, some external parties may still insist in
providing gifts to Employees and/or Directors in certain situations which do not fall within the
general exceptions.

6.2 Although the general principle is to immediately refuse or return such gifts save and except
in circumstances which is customary in nature, accepting a gift on behalf of ZKSB Group is
allowed only in very limited circumstances, whereby refusing the gift is likely to seriously
offend and may sever ZKSB Group’s business relationship with the Third Party.
Notwithstanding the above, in no circumstances may an Employee accept gifts in the
form of cash or cash equivalent.

6.3 In these limited circumstances, Directors and/or Employees shall surrender the gift
immediately to Group Risk & Compliance Department for record purposes. Group Legal
Department with the consultation with the Management will then decide whether to approve
the acceptance of the gift or require it to be returned.

6.4 Even if it may appear disrespectful to refuse a gift from an external party, nevertheless, if
there is a conflict of interest situation (e.g. bidding is in progress and the company that gave
the gift is one of the bidders) then the Head of Department cannot approve the acceptance
of said gift In this situation, the gift must be politely returned with a note of explanation about
this Policy.

7. PROVIDING GIFTS

Save and except for circumstances which are customary in nature, Employees and Directors are
not allowed to provide gifts to third parties without the prior written approval from the Group
Executive Director.

8. EXCEPTIONS TO THE NO GIFT POLICY

8.1 Although ZKSB Group practices a “No Gift Policy”, there are certain exceptions to the general rule whereby the receiving and provision of gifts are permitted in the following situations:-

Exchange of gifts at the company-to-company level (e.g. gifts exchanged between
companies as part of an official company visit/courtesy call and thereafter said gift is
treated as company property);
Gifts from the ZKSB Group to external institutions or individuals in relation to the
Company’s official functions, events and celebrations (e.g. commemorative gifts or
door gifts offered to all guests attending the event;
Gifts from ZKSB Group to Employees and Directors in relation to an internal or
externally recognised by ZKSB as an official function, event and celebration (e.g. in
recognition of an employee’s/director’s service to ZKSB Group);
Token gifts bearing ZKSB’s logo or (e.g. t-shirts, pens, diaries, calendars and other
small promotional items) that are given out equally to members of the public,
delegates, customers, partners and key stakeholders attending events such as
conferences, exhibitions, training, trade shows etc. and deemed as part of ZKSB’s
brand building and or promotional activities;
Gifts to / or from external parties who have no business dealings with ZKSB Group
(e.g. monetary gifts or gifts in-kind to charitable organisations);
Gifts to / or from Employees and/or Directors which are customary in nature.

8.2 Even in the above exceptional circumstances, Employees and Directors are expected to
exercise proper judgment in handling gift activities and behave in a manner consistent with
the general principles set out below :

conscientiously maintain the highest degree of integrity;
exercising proper care and judgment;
avoiding conflicts of interest;
refrain from taking advantage of your position or exercising your authority to further
your own personal interest at the expense of ZKSB Group; and
comply with applicable laws, regulations and ZKSB Group’s existing policies and
procedures.

9. CONSEQUENCES OF BREACH

Any breach of the principles set out in this Policy shall subject to the disciplinary action which may
result in the suspension or termination of employment, amongst others. In addition, offenders may
also face separate criminal/civil charges for such breach.

10. FURTHER CLARIFICATIONS

10.1 Should you require any further clarifications concerning this Policy, kindly contact Group Risk
& Compliance Department.

10.2 ZKSB reserves the right to make any amendments, modifications or variations to this Policy
from time to time