SUSTAINABILITY POLICY

The Group recognizes the importance of sustainability development to businesses and is committed to ensure attention is given to environmental, social, economic and governance aspects as an integral part of its business operations.

This Policy is based upon the following principles:

• To observe and comply with all relevant legislation, regulations and codes of practice.
• To consider sustainability issues and integrate these considerations into our business decisions.
• To promote and ensure that all employees are aware of and are committed to implementing and measuring sustainability activities considering environment, social, economic and governance factors.
• To annually report, review and to continuously strive to improve our sustainability performance.

The Group practices its Sustainability Policy on the following approach:-

1. The Business

The Group places the utmost importance on the approaches to achieving a viable and sustainable business that will grow and sustain even during the changes and challenges in the current global economic environment. Emphasis is placed not only for the current financial period but over the future as well. In arriving at this, the Group had drawn up a 3-year plan on the positioning of the Group and this dynamic strategy will be reviewed and measured every year via an annual budget together with the bases and assumptions thereon

The Group has invested in advanced machineries to increase production capacity, to improve the quality of our product and to enhance the efficiency of the manufacturing process. Better production efficiency increases the recovery of logs resulting in lower production cost. Using smaller logs has also resulted in lower cost of raw material and broadens the source of log supply for its production.

Besides, setting up a power plant which reuses bulk waste to generate biomass energy to supply electricity to the office, hostel, and production plant has also significantly reduced our dependency on fossil fuel and enhanced cost mitigation.

2. The Workplace

The Group has the responsibility to provide and maintain a safe and healthy working environment for all its employees. Regular inspections and upgrades were carried out to ensure canteen cleanliness, kitchen and sewerage facilities were well maintained. Food hygienic standards are applied to ensure safety and health in the workplace. Recreation activities are organized, such as football and badminton tournaments and festive celebrations for employees and management staff to participate and interact. The establishment of a

Safety and Health Committee for its manufacturing facilities is to ensure a safe and conducive working environment for its employees. The Group also adopts a Diversity Policy which will provide equal opportunities in respect to employment and training, and for its workplace in regardless of age, gender, ethnicity, cultural background or other personal factors. This is to ensure the Company having a diverse mix of skills and talent among employees in order to enhance Company performance and achieve Company’s goals.

3. The Environment

The Group is committed to reduce environmental impact of its operation and firmly believes in adopting waste management and recycling programs such as the wood waste of which generated from the manufacturing process are used as material for the biomass power plant for regeneration of electricity supply for its operation. We are also committed to be in compliance with the relevant laws relating to sustainable forestry, emission standards and plant effluent management.

The Group has complied the following legislation in reducing the environment impact:-

1. Lacey Compliance Verification (LCV) Program in affirming the legality of sourced forest products used in the manufacture of our products, which will give a high level of confidence to our customers of our fulfilment of the requirements of the Lacey Act for the US market.
2. The Group is certified as a CARB Certified Manufacturer by Benchmark Holdings, LLC. The CARB standards regulate formaldehyde emissions from wood products sold in California or used to make finished good for sale in California.
3. JAS Certification for General Plywood under the Law Concerning Standardization and Proper Labelling of Agriculture and Forestry Products (Law No. 175 of 1950) which is granted by Benchmark Holdings, LLC.

4. The Community

The Group has been contributing to the community by donating to the needy and contributing to the charitable events organized by the governmental and private organization.

5. The Stakeholders

The CommunityThe Group will continue with its focus to enhance and maximize its shareholders’ value. The Group believes in enhancing the relationship with all stakeholders including shareholders, regulatory authorities, business associates, bankers and suppliers.

CODE OF CONDUCT AND ETHICS

INTRODUCTION

The Board of Directors ("Board") of Cymao Holdings Berhad ("Cymaoâ" or "Companyâ") recognises the importance of good corporate governance. The Company is committed to engage in continuous efforts to identify best practices which support the Company in building a culture of good corporate governance. The Company has established, implemented and promulgated this Code of Conduct and Ethics (“Code”) to demonstrate the Company’s commitment in upholding appropriate standards of ethical conduct and behavior at all levels of the Company’s businesses. Such commitment is based on the belief that good corporate governance practices, appropriate standards of conduct, and ethical behavior are fundamental towards enhancing long term shareholder value, increasing investor confidence, and protecting stakeholders’ interests.

The Malaysian Code on Corporate Governance 2017 recommends the Board of every listed Company to formalize a Code of Conduct that engenders ethical standards throughout the Company. This Code of Conduct & Ethics (The Code) is applicable to all our employees and its connected person(s).

The “Connected Person(s)” means the following persons:-

The Code describes the behavior expected of our employees and how they relate to our Business Principles and core values. The Code is a common reference point for anyone who is unclear about what is expected of them in a specific situation.

If you need advice and help on topics in The Code, you can speak to:- • Your Manager / Superior, or • Your HR focal point.

GUIDELINES FOR CONDUCT

Every employee shall use due care in the performance of his/her duties, be loyal to the Company and act in good faith and in a manner he/she reasonably believes to be in and/or not opposed to the best interests of the Company.

CONFLICTS OF INTEREST

Employees must avoid conflict of interest between their private interest and their duty to the Company.

An employee who has an actual or potential conflict of interest must disclose to the Managing Director / Financial Controller the existence and nature of the actual or potential conflict of interest and all facts known to him/her regarding the transaction that may be material to judgment whether to proceed with the transaction or not. The Managing Director may proceed with the transaction only after receiving approval from the Board.

Abuse of Power Abuse of power includes any abusive behaviour (physical, psychological, sexual or emotional) by a person in a position of authority and trust against someone in a position of vulnerability and/or dependency

Employees must not use their position or knowledge gained directly/indirectly in the course of their duties for private or personal advantage

Employee who wish to lodge a complaint about an alleged abusive of power by a FLB’s staff should lodge their complaint to her/his line manager (or designated complaint focal point in accordance with FLB’s Whistle-Blowing Policy) as soon as possible after s/he becomes aware of the concern.

Corruption

All our business partners, our suppliers, customers, joint venture partners, contractors and distributors, must be dealt with fairly.

FLB expects the same from its business partners. Our relations with all business partners shall be based solely on objective criteria, quality, reliability, competitive prices, as well as compliance with environmental, social and corporate governance standards.

FLB is strictly committed to fighting any kind of corruption. Therefore, FLB prohibits its employees, agents, and other third parties acting on FLB’s behalf from engaging in any form of bribery. While dealing with business partners or government officials, they must never demand or accept anything of value (e.g. cash, gifts, entertainment or any other personal benefits) which could be construed as an attempt to influence or induce business decisions. Likewise, employees of other companies or government officials must never be promised or granted any personal benefits with the intent to obtain or retain business or to gain any improper advantage for FLB.

We require all employees to inform their manager if a business partner or governmental official offers or demands any personal benefits.

Insider Trading

As an employee, you may have access to material, non-public information about FLB or the affairs of a third party which, if disclosed, could impact the value of publicly-traded securities, in particular the FLB share. Insider trading laws prohibit making personal use of such information and/or disclosing it to third parties, including friends or family. Examples include information relating to the intended sale of substantial parts of the company, the acquisition or merger of businesses, undisclosed data on profits or particularly promising research results.

Money Laundering

No employee, either alone or in collaboration with third parties, may take measures that violate applicable regulations on money laundering

Where questionable financial transactions involving transfers of cash or cash equivalents are requested, prior review by and approval from the treasurer is required.

GIFTS AND ENTERTAINMENT

When acting on behalf of the Company, employees should never request gifts, entertainment or any other business courtesies from people doing business with the Company (including suppliers, customers, competitors, contractors and consultants).

Unsolicited gifts are permissible if they are customary and commonly accepted business courtesies; not excessive in value; and given and accepted without an express or implied understanding that the employee is in any way obligated by acceptance of the gift.

Only in exceptional circumstances does the Company allow the acceptance of certain Gifts and/or Hospitality to support business relationships. These require a strict process of approvals by the Board. Gifts and/or Hospitality must never influence business decisions or cause others to perceive an influence.

Meals in the ordinary course of business and infrequent meals and entertainment, such as cultural or sporting events, that are attended by both the employee and the giver are not considered gifts.

IGifts of cash or cash equivalents (including gift certificates, securities, below-market loans, etc.) of any amount are prohibited.

COMPANY PROPERTY

Employees have responsibility to safeguard and properly use Company’s assets and resources, as well as assets of other organization that have been entrusted to the Company. Except as specifically authorized, Company assets, including Company equipment, materials, resources and proprietary information, must be used for Company business purposes only.

Fraud, theft, abuse or misuses of the Company’s assets is unacceptable.

CONFIDENTIAL INFORMATION

confidential and proprietary information shall not be inappropriately disclosed or used for personal gain or advantage of the employee or anyone other than the Company.

FAIR DEALING

Employees shall endeavor to deal fairly with the Company’s Customers, Suppliers, Competitors, Contractors, Consultants and Service Provider and shall never take unfair advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of materials facts or any other unfair dealing practice.

COMPLIANCE WITH LAWS AND REGULATIONS

The Company is committed to comply with all laws, rules and regulations that govern the conduct of our business. All employees must ensure compliance with all laws, rules and regulations governing the business of the Company.

CORPORATE RESPONSIBILITY

Cymao believes that corporations are strong platforms to drive positive social change and armed with that belief, corporate responsibility has become an integral part of Cymao. Cymao has set out to implement both long-term and short-term programmes with the objective of advancing education and sports, protecting the environment, enriching and making a difference in the life of its employees and the communities within which it operates.

ENVIRONMENT, HEALTH AND SAFETY

The Company conducts its business operations in a manner that protects the health and safety of its employees, contractors, visitors and the public and is committed to comply with Cymao’s Occupational Safety & Health Policy. Cymao’s Occupational, Health and Safety department works with all lines of its businesses and employees to promote safe workplaces and prevent workplace accidents and injuries.

The Company communicates its expectations and safety protocols to its employees, suppliers and agents and explains the potential health and safety risks and implications of not complying with such requirements to them. The Company strives to comply with applicable environmental health regulations. With that in mind, Cymao has put in place a sustainability policy to minimise the environmental impact of its business and operations.

SHOULD I REPORT A VIOLATION OF THE CODE?

Yes, we encourage this and it will protect you against any retaliation. You can report a non-compliance allegation or concern to your Manager/Superior.

If you prefer to report confidentially, you can contact the Chairman of the Board or the Audit Committee Chairman.

The contact details of the Chairman of the Board and Audit Committee Chairman where concerns can be raised by the employee are as follows:

Chairman of the Board Audit Committee Chairman Email:

This Code of Conduct & Ethics may be amended as required, subject to the approval of the Board.

VIOLATION OF THE CODE

Cymao expects its business associates to comply with all applicable laws and regulations and this Code. Business associates and others who conduct business with Cymao risk termination of their relationship with Cymao in the event of material violations of this Code.

This Code of Conduct & Ethics is to be reviewed by the Board annually to provide assurance that it remains consistent with the Board’s objectives and responsibilities.

The Whistleblowing Policy (‘the Policy’) is intended to directly support the Company's Core Values, Code of Ethics and Governance requirement. Cymao Holdings Berhad (‘the Company’) places high value on the level of trust and integrity expected of its employees within its Group of Companies ('Group'). It is an avenue to encourage and enable employees and others to raise legitimate concerns to be objectively investigated and addressed within the Company prior to seeking resolution outside the Company.

In line with this, the Company and its Group has adopted the Policy that outlines the Group’s commitment to ensure that employees and other stakeholders are able to raise genuine concerns in relation to breach of a legal obligation, miscarriage of justice, danger to health, safety and environment at the earliest opportunity without being subject to victimization, harassment or discriminatory treatment, and to have such concerns properly investigated. The Policy sets out the mechanism and framework by which employees, contractors, consultants and any other individuals or organization who have dealings with the Company can confidently voice concerns / complaints in a responsible manner without fear of discriminatory treatment.

All employees are encouraged to raise genuine concerns about possible improprieties in matters of financial reporting, compliance and other malpractices at the earliest opportunity, and in an appropriate way.

The policy is designed to: -

• Support the company's values;
• Ensure employees can raise concerns without fear of reprisals; and
• Provide a transparent and confidential process for dealing with concerns.

The following shall constitute “Improper Conduct” under this Policy:

• Incidents of fraud, corruption or bribery;
• Conduct or activity which breaches any law or regulatory obligation;
• Breach of the Company’s policies, practices, procedures or other rules of conduct;
• Improprieties in matters of financial reporting; and
• Situation which pose a danger to health, safety or any individual or significant danger to the environment nly covers possible improprieties in matters of financial reporting, but also: -

PRINCIPLES

The principles underpinning the policy are as follows: -

• All concerns raised will be treated fairly and properly;
• The company will not tolerate harassment or victimization of anyone raising a genuine concern
• Any individual making a disclosure will retain anonymity unless the individual agrees otherwise;
• The company will ensure that any individual raising a concern is aware of who is handling the matter; and
• The company will ensure no one will be at risk of suffering some form of reprisal as a result of raising a concern even if the individual is mistaken. The company, however, does not extend this assurance to someone who maliciously raises a matter he/she knows is untrue.

GRIEVANCE PROCEDURE

If any employee believes reasonably and in good faith that malpractice exists in the work place, the employee should report this immediately to his/her manager. However, if for any reason the employee is reluctant to do so, then the employee should report the concerns to either the:

• Chairman of the Board; or
• Audit Committee Chairman.

The contact details of the Chairman of the Board and Audit Committee Chairman where concerns can be raised by the employee are as follow:

The contact details of the Chairman of the Board and Audit Committee Chairman where concerns can be raised by the employee are as follow:

The employee’s concerns will be reported to the company without revealing the identity of the employee unless prior consent from the employee was obtained.

The employees who have raised concerns will be informed of who is handling the matter, how they can make contact with them and if there is any further assistance required

Where concerns cannot be resolved without revealing the identity of the employee raising the concern (i.e. if the evidence is required in court), a dialogue will be carried out with the employee concerned as to whether and how the matter can proceed.

Upon completion of investigation, appropriate course of action will be recommended to the Audit Committee for their deliberation. Decision taken by the Audit Committee will be implemented immediately.

Where possible, steps will also be implemented to prevent similar situation arising.

List of Complaints under Whistleblowing Policy

The list of complaints / concerns includes, but are not limited to;

• Corruption or bribery
• Breaching of legal obligation
• Misuse of company information
• Any dishonest of fraudulent act
• Negligence in carrying out work obligations
• Forgery or alteration of a cheque, bank draft or any other financial document
• Misappropriation or theft of funds, supplies or other assets
• Providing or accepting gifts or material value to/from customers, contractors, vendors or other persons doing or attempting to do business with the Company or its Group of Companies that are intended to influence a business decision or selection process
• Destruction, removal or inappropriate use of the Company’s records, furniture, fixtures and equipment
• Falsifying travel and entertainment expenses and/or utilizing company funds to pay for personal expenses
• Fictitious reporting or receipts, delivery orders, etc from suppliers or shipment to customers s
• Misappropriation of Company-owned computer hardware, software, data, etc
• Acceptance of fictitious quotations from suppliers, vendors or contractors in favoring for a particular entity
• Inventory or asset theft
• IGross mismanagement within the Company (including serious potential breach to the interest of society and environment)
• IBreach of code of ethics of the Company, including sexual, physical or other abuse of human rights
• Act and omission which jeopardizes the health and safety of the company’s employees or the public
• Any other detrimental wrongdoing which nature of the wrongdoing is subject to absolute discretion of the Committee

CORPORATE DISCLOSURE POLICY

1. INTRODUCTION

The Board of Directors is committed to provide accurate, clear, timely and complete disclosure of material information pertaining to the Company's performance and operations to shareholders, investors and public generally

In formulating this Policy, the Company has taken into account the recommendations contained in the Malaysia Code on Corporate Governance 2012 and its disclosure obligations contained in the Listing Requirements of Bursa Malaysia Securities Berhad ("Bursa Malaysia").

2. OBJECTIVE

This Policy aims to achieve the following objectives:

1. To develop and maintain a positive relationship with all shareholders;
2. To promote and demonstrate a high standard of integrity and transparency through timely, accurate, quality and full disclosures; and
3. To provide guidelines and policies in disseminating corporate information to, and in dealing with shareholders.

3. DESIGNATED SPOKEPERSONS

The Managing Director will serve as the primary spokespersons for the disclosure requirement and to communicate with audience constituents and responds to questions in relation to the corporate vision, strategies, developments, future prospects, financial plans and operation matters. In the absence of any designated spokespersons, the authorized spokespersons may, from time to time, designate others within the Company to speak on behalf of the Company or to respond to specific inquiries. There could be blanket delegation on routine matters.

4. MODE OF DISCLOSURE

The Company makes use of brand of communication channels to disseminate information regarding the Company, which including:

1. Electronic facilities provided by Bursa Malaysia;
2. Press releases;
3. Corporate website;
4. General Meetings;

5. PRINCIPLES OF DISCLOSURE CONTROLS AND STRATEGIES

The Company has adopted the following principles and procedures to enhance the relationship with investors or potential investors:

5.1 Immediate disclosure of Material Information Any material information that is reasonably expected to have a material effect on the price value or market activity of the shares or the investors’ decision making, must be announced immediately to Bursa Malaysia and made available in the Company’s website.

5.2. Withholding of Material information and maintaining confidentially Material information may be kept confidential temporarily if the immediate disclosure would prejudice the ability of the Company to pursue its corporate objectives. In such cases, the Company must ensure that the material information will be kept confidential to prevent from leakage. The Company should limit the number of people with access to or in possession of the material information and ensure that all confidential documents are being protected and secured.

5.3. Company's Website The Company must have its corporate website where it publishes all corporate information on its developments, performance and others activities undertaken as well as all announcements made to Bursa Malaysia. The Company must ensure that its website is regularly updated with the Company’s latest disclosures.

5.4. Rumours When the Company aware of any rumour or report, true or false, that contains material information, the Company must make due enquiry and immediately publicly clarify, confirm or deny the rumour or report. In the event that rumour or report containing erroneous material information which has been circulated, the Company must immediately announce to Bursa Malaysia and provide facts sufficient to support the denial or to clarify any misleading aspects of the rumour or report. In the event that rumour or report containing material information that is correct, an announcement setting forth the facts must be prepared for public release, which must include but not be limited to, an indication of the state of negotiations or of corporate plans in the rumoured area.

determining his choice of action.

Bursa Malaysia also provides for the Company to electronically publish all its announcements by assessing online through Bursa Malaysia’s internet website at http://www.bursamalaysia.com.

All announcements have to be approved by the Board before releasing to Bursa Malaysia. From time to time, the Company Secretary will advise the Board and principal officers on the trading restrictions in the Company’s securities in accordance with the provisions of the Main Market Listing Requirement of Bursa Malaysia.

6. PERIODIC DISCLOSURES

The quarterly financial results are prepared in the format which is in compliance with the Listing Requirements and is announced to Bursa Malaysia after approved by the Board on the same day. The Annual Report will be printed and distributed to shareholders at stipulated timeframe required under Listing Requirements.

7. REVIEW OF POLICY LOSURES

This Policy shall be reviewed by the Board as and when necessary and may be amended as the Board may deem appropriate.

The Company shall disclose this Policy in its corporate website.

DIVERSITY POLICY

The Board is pleased to set out below its approach to boardroom diversity as recommended by the Malaysian Code on Corporate Governance 2017.

Policy

The Company is committed to actively managing diversity as a mean of enhancing the Company’s performance by recognizing and utilizing the contribution of diverse skills and talent from its directors, officers and employees.

Diversity involves recognizing and valuing the unique contribution people can make because of their individual background and different skills, experiences and perspectives, including persons with coexisting domestic responsibilities. Diversity may result from a range of factors including age, gender, ethnicity, cultural background or other personal factors. The Company values the differences between its people and the contribution these differences make to the Company.

1. Role of the Board

It is the responsibility of the Board to foster an environment where:

1. Individual differences are respected.
2. The ability to contribute and access employment opportunities is based on performance, skill and merit.
3. Inappropriate attitudes, behaviours and stereotypes are confronted and eliminated.

2. Objectives