1. Purpose and Scope of the Code

This Code of Business Conduct and Ethics (“Code”) applies to all employees and directors of Knowix Sdn Bhd (the “Company”), including full-time or permanent employees, part-time employees, employees on probation, trainees and interns, employees on fixed-term contracts (collectively, “Employees”).

This Code is intended to assist the Company’s employees to uphold Knowix ‘s Core Values, provide guidance to all employees in carrying out his/her duty for and on behalf of the Company, and provide guidance on how employees should conduct themselves at or outside the workplace where they can be identified as Knowix/Company employee.

2.  Compliance and Responsibility with the Code

This Code applies to all employees both on and off the job, subject to local laws and regulations of the countries of operation. Employees shall seek guidance from the relevant supervisor/manager of the Company when in doubt regarding the proper course of action to be taken in a given situation. The Code is developed based on the applicable laws and regulations within the country of operation in addition to any Company specific values or practices.

Non-compliance with this Code will be treated seriously and may result in disciplinary action, including the possibility of suspension or dismissal, and if warranted, legal proceedings against the Employee. Violation of applicable laws may subject Employee to civil and/or criminal penalties imposed by a governmental agency or a court, in addition to disciplinary action.

3. Workplace Culture and Environment

3.1 Workplace Health and Safety

Knowix is committed to providing a safe and healthy work environment to all Employees. Health and safety support and training will be provided to Employees so that they understand their occupational health and safety obligations and diligently comply with all health and safety requirements,policies and procedures set out by the Company. Safety is everyone’s responsibility.

3.2 Harassment, Threat and Violence

Knowix seeks to provide a work environment where Employees are treated with respect and free from any form of harassment, threat, intimidation, violence or any other inappropriate behaviour. Employees are responsible to report any harassment, intimidation, offensive or inappropriate behaviour. All complaints or grievances will be investigated and appropriate action will be taken to stop such conduct and prevent future occurrences.

3.3 Sexual Harassment

It is the policy of the Company to promote a safe and healthy working environment that fosters mutual respect where individual employees irrespective of status or position are treated with dignity and free from sexual harassment.

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

3.3.1 Definition of Sexual Harassment

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

i) That might, on reasonable grounds, be perceived by the recipient as placing a condition of a sexual nature on his/her employment.

ii) That might, on reasonable grounds, be perceived by the receipt as an offense or humiliation, or a threat to his/her wellbeing, but has no direct link to his/her employment.

3.3.2 Forms of Sexual Harassment

Sexual harassment encompasses various conducts of a sexual nature which can manifest themselves in five possible forms, namely:

i) Verbal harassment: e.g. offensive or suggestive remarks, comments, jokes, kidding, teasing, sounds, inquiries or discussions about sexual activities or other verbal abuse;

ii)Non-verbal / gestural harassment e.g. leering or ogling with suggestive overtones, licking lips,holding or eating food provocatively, hand signal or sign language denoting sexual activity, persistent flirting;

iii) Visual harassment e.g. showing pornographic materials, writing sexually suggestive letters or other written materials, sexual exposure;

iv) Psychological harassment e.g. repeated unwanted social invitations, proposals for dates or physical intimacy;

v) Physical harassment e.g. inappropriate touching, patting, pinching, stroking, grabbing, hugging, kissing, fondling, brushing up against the body, or coerced sexual intercourse sexual assault.

3.3.3 Disciplinary Action

All employees including supervisors and managers will be subject to disciplinary action up to and including dismissal for engaging in sexual harassment. Employees who make false and malicious complaints of sexual harassment as opposed to complaints that are made in good faith will also be subject to disciplinary action.

An independent and thorough investigation in a manner that is as confidential as possible under the circumstances will be carried out on all complaints received alleging sexual harassment.

3.4 Equal Opportunity and Non-discrimination

Knowix upholds the principle of diversity of workforce, equal  opportunity, non-discrimination and fair treatment in all aspects of employment, including recruitment and hiring, compensation and benefits, working conditions, training, rewards and recognition, career development and retirement. Employees must strive to create a workplace whereeveryone is treated fairly and equally.

4. Drugs, Alcohol and Prohibited Substances

Employees are expected to perform their job duties free from the influence of any substance that could impair job performance or pose unacceptable safety risk to the Employee or others.

Knowix prohibits working under the influence of alcohol, illegal drugs or controlled substances. In addition, the use, possession, distribution or sale of alcohol, illegal drugs or other controlled substances in the workplace (other than for approved medicinal purposes) is strictly prohibited.

There may be company-sponsored events or functions where the serving of alcoholic beverages is permitted. In these cases, all appropriate liquor laws must be followed.

5. Conflict of Interest

Employees have an obligation to act in the best interest of Knowix at all times. Employees are prohibited from using their position or knowledge gained directly or indirectly in the course of their duties and responsibilities or employment for private or personal advantage. If Employee at any time thinks that he/she may have a potential or actual conflict of interest, Employee is obliged to disclose the conflict promptly to the Chief Executive Officer so that a determination can be made as to the existence and seriousness of an actual conflict.

6. Company Information, Records and Assets

6.1 Proprietary and Confidential

Information Employees are required to protect Knowix’s confidential information and guard them against unauthorised disclosure or use.Employees are also required to protect confidential information of third party which Employees have access to in the course of their work.

Confidential information includes, but are not limited to, data and technical know-how, business plan and budget, product design, customer list and information, information on current and future projects and work processes, and any non-published financial or other data. Unless required by law or authorised by the Company, Employees shall not disclose confidential information or allow such disclosure or use confidential information for unauthorised purposes. This obligation continues beyond the termination of employment.

6.2 Data Integrity and DataProtection

Knowix has put in place the Personal Data Protection Policy, and Information Technology Policy. Employees shall record,manage, store and transfer all data and records in compliance with applicablelegal, tax, regulatory and accounting requirements.

6.3 Use of Company Resources and Protection of Assets

Employees shall be personally responsible for protecting the Company’s assets entrusted to them. Employees shall take all necessary steps to prevent theft, loss, damage or misuse of assets belonging to the Company, the occurrence of which shall be reported immediately to the relevant supervisor/manager in the Company. Company assets shall not be misused, taken, sold, lent, given away or otherwise disposed of, or used for personal purposes to the extent that it would affect the interest of the Company.

7. Social Media and Public Statement

All employee has the responsibility to protect the Company’s reputation and brand image. When using private social media accounts, employees should ensure that any posts reflect only personal posts and do not negatively affect the public perception of the Company. Employees shall also ensure that they do not share any confidential and/or proprietary business information on social media.

Employees are also not allowed to make any public statement which represents the Company without any prior approval or unless they are duly appointed or authorized to do so. “Public Statement” includes the making of any statement or comment to the press or to the magazines, or through email, instant messaging, forums or conferences and posting on social media.

In the event an employee is found to have posted comments and/or made public statements that are derogatory, inappropriate, disrespectful, etc., the employee concerned may be subject to appropriate disciplinary actions.

8.Grievance Procedure

Employee should, whenever possible try to resolve disputes and minor problems amicably and informally between themselves or together with their immediate supervisors. If such informal means do not bring a resolution, an employee may bring to the HR Manager’s attention any grievance or complaint of the event causing or giving rise to such grievance or complaint.

The filing of a formal grievance in writing should be done only if such grievances or complaints cannot be resolved through these informal discussions. Due consideration shall be given to all grievances and complaints and the CEO and/or COO shall make all efforts to resolve them promptly and fairly.