Responsible Business Alliances

Objective

Opulent is committed to be responsible and to conduct sustainable business activities. The Responsible Business Alliance (RBA), Code of Conduct establishes standards to ensure that working conditions in Opulent is a key component and its supply chains are safe, and that business is conducted responsibly, ethically, and with respect for human rights and the environment.

Scope

This policy applies to all employees of Opulent and any other business partners operating at Opulent.

References and Internationally Recognised Standards

RBA - Responsible Business Alliance Code of Conduct

OECD Guidelines for Multinational Enterprises

UN Guiding Principles on Business and Human Rights

UN Universal Declaration of Human Rights

ILO Declaration on Fundamental Principles and Rights at Work

ILO Fundamental Conventions

SA 8000 – Social Accountability

ISO 14001 – Environmental Management System

OSHA 1994 Malaysia Law – Occupational Safety and Health Act

Employment Act 1955

HR00183026 Disciplinary Policy

HR00183015 Whistleblowing Policy

PQ100021 Part Approval Procedure

HR00182026 Grievance policy

FQ230009 Conflict of Interest Declaration Form

Term / Definitions

RBA – Responsible Business Alliance
SAQ – Supplier Assessment Questionnaire

Responsibilities

HR Manager: Owner.
Operation Director: Approver.
Department Head are to adhere and comply to RBA directive in all the five codes of conduct.

Procedure of Making a Disclosure

RBA CODE OF CONDUCT is made up of five sections.

A. Labor

B. Health and Safety

C. Environmental

D. Business Ethics

E. Management System

Labor

Opulent is committed to respect human rights of employees, and to treat them with dignity. This apply to direct and indirect suppliers, as well as all workers including temporary, migrant, students, contract, direct employees, and any other type of worker.

Prohibition of Forced Labor
1. Forced labor in any form, including but not limited to bonded or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of person are not to be used.
2. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company provided facilities.
3. As part of hiring process, all workers must be provided with a written employment agreement in their native language, or in a language the worker can understand.
4. All work shall be voluntary, and workers shall be free to leave upon reasonable notice, which shall be clearly stated in workers' contracts.
5. Personal documents not to be held by the company. Notwithstanding the foregoing, employers can only hold documentation if necessary to comply with the local law.
Young Workers
1. Child labor shall not to be used in any stage of operations. The term “child” refer to any person under the age of 15 or under the age of completing the compulsory education or under the minimum age for employment in the country, whichever is greatest.
2. Workers under the age of 18 (young workers) shall not perform work that is likely to jeopardize their health or safety, including night shift and overtime.
Working Hours
1. Working hours shall not exceed the maximum set by local law.
2. A workweek shall not be more than 60 hours per week including overtime, except in emergency or unusual situation.
3. Workers shall be allowed at least one day off every seven days
Wages and Benefits
1. Compensation paid to workers shall comply with Malaysia Labor Law by having legal minimum wages, overtime hours and legally mandated benefits.
2. All workers shall receive equal pay for equal work and qualification.
3. In compliances with Malaysia Labor Law, workers shall be compensated for overtime at pay rate greater than regular hourly rate.
4. Deduction from wages as a disciplinary measure shall not be permitted.
5. For each pay period, workers shall be provided with a timely and understandable wages statement that included sufficient information to verify accurate compensation for work performances.
6. All use of temporary, dispatch and outsourced labor shall be within the guidelines of Malaysia Labor Law.
Non-Discrimination/Non-Harassment/Humane Treatment
1. Opulent shall commit to a workplace free of harassment and unlawful discrimination.
2. There shall be no harsh and inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming or verbal abuse of workers.
3. Disciplinary policies in support of these requirements shall be clearly defined and communicated to the workers.
4. Opulent shall not engage in discrimination or harassment based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protecyed genetic information or marital status in hiring and employment practices such as wages, promotions rewards and access to training.
5. Workers shall be provided with reasonable accommodation for religious practices.
6. Workers or potential workers should not be subjected to medical tests or physical exam that could be use in a discriminatory way.
Freedom of Association and Collective Bargaining
1. Open communication and direct engagement between workers and management are most effective ways to resolve workplace and compensation issue.
2. In alignment with this principles, Opulent shall respect the rights of all workers to form and join trade union of their own choosing, to bargain collectively and to engage in peaceful assembly.
3. Workers and/ or their representative shall be able to openly communicate and share idea and concern to management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

Health and Safety

Occupational Health and Safety
1. Workers potential for exposure to safety hazard (e.g. chemical, electrical and others energy sources, fire, vehicles, and fall hazard) shall be identified, accessed and control through proper design, engineering and administrative controls, preventive maintenances and safe work procedure (lockout/tag out).
2. Where hazard cannot be adequately control by these means, workers shall to be provided with appropriate, well maintain, personal protective equipment and educational materials about risks to them associated to these hazard.
3. Gender-responsive measures shall be taken, such as not having pregnant women/ nursing mothers in working conditions with high hazard.
Emergency Preparedness
1. Potential emergency situations and events shall be identified and assessed and their impact minimized by implementing emergency plan and response procedure.
2. This include emergency reporting, employee notification and evaluation procedure, workers training and drill, appropriate fire detection and suppression equipment, clear and unobstructed adequate exit facilities and recovery plan.
3. This plan and procedure shall focus on minimizing harm to life, the environment and property.
4. Proper training shall be given to all employees.
Occupational Injury and Illness
1. Procedures and systems shall be in place to prevent, to manage, to track and to report occupational injuries and illnesses.
2. These include provision to encourage workers reporting, classified and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate these causes, and facilitate written employees to work.
3. Opulent shall allow workers to remove themselves from imminent harm, and not return until the situation is mitigated, without fear of retaliation.
Industrial Hygiene
1. Workers exposure to chemical, biological, and physical agents shall be identified, evaluated and controlled according to the Hierarchy of Controls.
2. When hazard cannot be adequately control by such means, workers shall be provided with and used appropriate, well maintain, personal protective equipment.
3. Opulent shall provide workers with safe and healthy working environments, which shall be maintained through ongoing, systematic monitoring of workers' health and working environments.
4. Opulent shall provide occupational health monitoring to routinely evaluate if workers' health is being harmed from occupational exposures.
5. Protective program shall include educational material about the risks associated with expose to workplace hazard.
Physically Demanding Work
Workers exposure to the hazard or physically demanding tasks including manual material handling and heavy or repetitive lifting, prolong standing and highly repetitive or forceful assembly tasks shall be identified, evaluated and controlled.
Machine Safeguarding
Production and others machinery shall be evaluated for safety hazard, physical guards, interlocks and barriers shall be provided and properly maintain where machinery present an injury hazard to workers.
Sanitation, Food and Housing
1. Workers shall be provided with ready access to the clean toilet facilities, portable water and sanitary food preparation, storage and eating facilities.
2. Foreign workers are provided dormitory by labor agents. These shall be maintained, to be clean and safe, and provided with water for showering.
3. Adequate lighting and adequate conditioned ventilation, individually secured accommodation for storing personal and valuable items, reasonable personal space along with reasonable entry and exit privileges.
Health and Safety Communication
1. Opulent shall provide workers with appropriate workplace health and safety information and training in the language of the workers or in a language the workers can understand.
2. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers.
3. Health information and training shall include content on specific risks to relevant demographics, such as gender and age, if applicable.
4. Training shall be provided to all workers prior to beginning of work and regularly thereafter.

Environmental

Environmental Permits and Reporting
All required environmental permits, approval and registration are to be obtained,
maintained and kept current and their operational and reporting requirements
are to be followed.
Pollution Prevention and Resources Conservation
1. Emissions and discharges of pollutants and generation of waste shall be minimized or eliminated at the sources or by practices such as adding pollution control equipment, modifying production, maintenance and facility processes.
2. The use of natural resources including water, fossil fuels, minerals and virgin forest products, shall be conserved; by practices such as modifying production, material substitution, reuse, conservation, recycling or others means.
Hazardous Substances
1. Chemical and others materials posing a hazard to human or the environment shall be identified, labelled and managed to ensure their safe handling, movement, storage, used, recycling or reuse and disposal.
2. Hazardous waste data shall be tracked and documented.
Solid Waste
1. Opulent shall implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle solid waste (non-hazardous).
2. Waste data shall be tracked and documented.
Air Emission
1. Air emission of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion bi-products generated from operations shall be characterized, routinely monitored, controlled and treated as required prior to discharge.
2. Opulent shall conduct routine monitoring of the performance of its air emission control system.
Material Restrictions
1. Opulent shall adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labelling for recycling and disposal.
2. Refer to PQ100021 Part Approval Procedure.
Water Management
1. Opulent shall implement a water management program that documents, characterizes, and monitor waste resources, used and discharged.
2. All waste water shall be characterizes, monitored, controlled and treated as required prior to discharges or disposal.
Energy Consumption and Greenhouse Gas Emissions
1. Energy consumption and all relevant scope 1, scope 2 and significant categories of scope 3 greenhouse gas emissions shall be tracked, documented and publicly reported against the greenhouse gas reduction goal.
2. Opulent shall look for cost effective method to improve energy and to minimize their energy consumption and greenhouse gas emissions.

Ethics

Business Integrity
1. The highest standards of integrity shall be upheld in all business interactions.
  Opulent shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortions, and embezzlement.
No Improper Advantage
1. Bribe or others means of obtaining undue or improper advantage shall not to be promised, offered, authorized, given or accepted.
2. This prohibition covers promising, offering, authorizing, giving or accepting anything of value exceeding RM100, either directly or indirectly through a third party, in order to obtain or retain business or otherwise gain an improper advantage.
3. Monitoring and enforcement activities shall be implemented to ensure compliances to disciplinary policy.
4. Refer to HR00183026 Disciplinary Policy.
Disclosure of Information
1. All business dealing shall be transparently performed and accurately reflected on the Opulent business books and records.
2. Information regarding Opulent labor, health and safety, environmental practices, business activities, structure, financial situation and performance shall be disclose in accordance with applicable regulations and prevailing industry practices.
3. Falsification of records of misrepresentation of conditions or practices in the supply chain are unacceptable.
4. Refer to HR00183026 Disciplinary Policy.
Intellectual Property
1. Intellectual property rights shall be respected.
2. This include transfer of technology, and know-how is to be done in a manner that protect intellectual property rights and customers and suppliers information shall be safeguarded.
Fair Business, Advertising and Competition
Standards of fair business, advertising and competition shall be upheld.
Protection of Identity and Non-Retaliation
1. Program that ensure confidentiality, anonymity and protection of suppliers and employee whistleblowers shall be maintain, unless prohibited by laws.
2. Opulent shall have a communicated process for their personnel to be able to raise any concern without fear of retaliation.
3. Refer to HR00183015 Whistleblowing Policy.'
Responsible Sourcing of Mineral
Opulent shall assure that the tantalum, tin, tungsten, gold and cobalt in the product they manufacture are sourced in a way consistent with the Organisation for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due dilligence framework.
Privacy
1. Opulent shall commit to protecting the reasonable privacy expectation of personal information of everyone they do business with, including suppliers, customers, consumers and employees.
2. Opulent shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted and shared.

Management System

Company Commitment
1. The RBA policy statements affirms, Opulent’s commitment to due dilligence and continual improvements, endorsed by executive management.
2. Policy statements shall be made public and communicated to workers in a language they understand via accessible channels.
Management Accountability and Responsibility
1. Opulent shall clearly identifies senior executive and company representative responsible for ensuring implementation of the management system and associated program.
2. Senior management review the status of the management system on regular basis.
Legal and Customer Requirements
Opulent shall adopt or establish a process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this code.
Risk Assessment and Risk Management
1. Opulent shall adopt or establish a process to identify the legal compliances, environmental, health and safety, labor practice and ethic risks, including the risks of severe human rights and environment impacts, associated with Opulent’s operations.
2. Opulent shall determine the relative significant for each risk and implement appropriate procedural and physical control to control the identified risks and ensure regulatory compliances.
Improvement Objective
Opulent shall establish written performance objectives, targets and implementation plans to improve Opulent’s social, environmental, and health and safety performance including a periodic assessment of Opulent's performance in achieving those objective.
Training
Opulent shall establish programs for training all employees to implement Opulent’s RBA policy, procedures and its improvement objectives to comply to all applicable legal and regulatory requirements.
Communication
Opulent shall establish process for communicating clear and accurate information
about Opulent’s policy, practices, expectations and performances to workers, suppliers
and customers.
Worker/Stakeholder Engagement and Access To Remedy
1. Opulent shall establish processes for ongoing two-way communication with workers, their representatives, and other stakeholders where relevant or necessary.
2. The process shall aim to obtain feedback on operational practices and conditions covered by this code, and to foster continuous improvement.
3. Ongoing processes including an effective grievance mechanism, to assess employees understanding and obtain feedback on violation against practices and conditions covered by this code and to foster continuous improvement.
4. Workers shall be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation
5. Yearly employee engagement plan in place to foster employees involvement, improve inter-department relationship and create positive working environment.
6. Refer to HR00182026 Grievance policy.
Audits and Assessment
Opulent shall conduct periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the code and customer contractual requirements related to social and environmental responsibilities.
Corrective Action Process
Opulent shall establish a process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
Documentation and Records
Opulent shall create and maintain documents and records to ensure regulatory compliances and conformity to company requirements along with appropriate confidentiality to protect privacy.
Supplier Responsibility
1. Opulent shall establish a process to communicate the RBA code of conducts requirement to suppliers and vendors.
2. Periodic audit shall be done through SAQ to monitor suppliers and vendors compliance to the codes.