29.4.2016

To our stakeholders:

I am pleased to confirm that [ Company Name ] reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Kyaw Kyaw Hlaing

CEO

OUR COMMITMENT
SMART’s commitment to respecting human rights is all employees’ responsibility to wherever we operate. This policy is adopted in SMART’s working culture, our Quality Management System, our Environment Management System and our Code of Ethics.

We have a responsibility to respect human rights, and can also play a positive role in the communities where we work. We treat all our employees with respect, dignity and promote diversity in the workplace. Also, we protect personnel, assets and provide a secure environment in which business operations may be successfully conducted. Set clear accountability for line manager to communicate this policy to their respective subordinates, supplier and contractor and implement the policy, support and review. We support the principle of the Universal Declaration of Human Rights and Myanmar National Human Rights Commission.

EQUAL OPPORTUNITY: We are most valuable resources and are essential to its success. All of our employees are expected to treat each other professionally, based on mutual respect, trust and individual value. We shall provide equal employment opportunities and equal employment related decisions for hiring, evaluation, promotion, training , development , discipline, compensation and termination . We are to treat all job applications and employees without illegal bias. No one at SMART should ever be subject to illegal discrimination on the basis of age, race , gender , language , religion , national or social origin and disability or the receipt of public assistance. All employees should understand the value of diversity and never discriminate.

HARASSMENT : We are firmly committed to providing equal opportunity in all aspects of employment and business relations. We will not tolerate any illegal discrimination or harassment of any kind. All employees, officers and managers should respect the rights and cultural differences of other individuals. SMART is dedicated to treating all employees with honestly, fairness and respect. Never make inappropriate jokes or comments. If you are confronted with harassment, you should report your concern to your supervisor.

COMMUNITY : We protect and respect community where we work and appreciate diversity in the work place. We also respect local custom and culture in operation environment. We have responsible to help the community we live and taking social responsibilities will boost the moral of the employee.
SUPPLIER AND CONTRACTOR : We evaluate and select supplier and contractor based on SMART’s Human Rights, Conduct of Conduct ( Supplier) , Quality and Food Safety Management System. Compliance Team will conduct regular monitoring and analyzing supplier/vendor’s performance. We ensure that our supplier and contractor comply the laws and regulations in the workplace and conduct their business ethically and responsibly.

It is the responsibility of everyone to ensure that standards of conduct are implemented and maintained, and any employee or other person who wishes to report a violation of policy should report such violation to the SMART Ethical Committee.
The reporter should address by :
SMART Ethical Committee
City Bank Building , 5th Floor , Banyardala Road , Myingalar Taung Nyunt Township,
Yangon , Myanmar
+95-1-701593
ethicalofficer@smartmyanmargroup.com

We regular measure our Stakeholder concern with SMART’s Human Rights Policy Compliance by
- Practicing Greviance Mechanisms Procedure at our operation area.
- Conducting Workplace Human Rights Prevention Activites.
- Regular Supplier / Vendor Performance including Human Rights , Code of Conduct ,Quality & Food Safety Management System Analysis.
For our community , Our Ray of Hope Foundation is running the project by co-operate with ASEAN CSR Network, namely “ To reduce proverty by Increasing knowledge Capacity” . These project mainly scope is “Business and Human Rights” and focus on general knowledge on profitable business , harmless living , Human Rights. And also the project will help to protect the local work survival of locals for business , safety , health and prevention of natural disasters.

SMART is committed to upholding the protection of labor under the human rights in all workers where it is possible through our sphere of influence. We ensure that we are not complicit in any violations on labors or suppliers and partners to this same high standard. SMART supports and respects the principles proclaimed in the Universal Declaration of Human Rights, the International Labor Organization‘s Principles and Local Labor Laws believe businesses should ensure that they are not complicit in human rights abuses.
SMART Labor Policy Statement is intended to state the company’s position to all SMART employees and other stakeholders.
We focus the freedom of choice of employment and the fullest opportunity for each worker depending their qualification and skill. All SMART employees have the right to equal treatment and employment without discrimination.
We are committed to a work force that is free of harassment and unlawful discrimination by complying SMART Human Rights Policy.
We prohibit the employing of child labor and forcing labor where we operate. All employees must meet the minimum age requirement (locally regarding as 18 and above).
Compensation paid to workers shall comply with all applicable wage laws including those relating to minimum wages, overtime hours and legally mandated benefits under Myanamr Labour Law. Minimum working hours are regarded as total 8 hours to what is acceptable by Myanmar Labour Law.
Public holidays shall be complying as announced in annual notification by the Union Government, without deduction.
We support our employee to be in a safe environment, protected from hazards of the job. we are complying SMART Health, Environment, Safety and Social Responsibility Policy and SMART Stop Work Policy.
We allow the employee to create freedom of association and effective recognition of the right to collective bargaining.

SMART Labor Policy shall be controlled and watched under SMART Ethical Committee. It is the responsibility of everyone to ensure that standards of conduct are implemented and maintained, and any employee or other person who wishes to report a violation of policy should report such violation to the SMART Ethical Committee.

Violation result will be confirmed under the decision of SMART Ethical Committee. In certain circumstances, the final decision will be confirmed by regional Labor Office or the Court.
The reporter should address by: SMART Ethical Committee
City Bank Building, 5th Floor, Banyardala Road, Mingalar Taung Nyut Township, Yangon, Myanmar
+95 1 701593 or via ethicalofficer@smartmyanmargroup.com

We measure the outcome by analyzing and monitoring under related report.
1) Employee complaints, and requirements internally under Anomaly Report and Corrective and Preventive Action Report individually to know what the needs and want of employee
2) Employee performance annually review by Peer Review Form to reward fairly
3) Employee dignity and ethics were review by SMART Ethical Committee

We always create a safe and fun working environment by contributing equality and fairness in our daily routine working process.

Environment can be defined as the inter-relationship between aspects of living things, their process , products and their impacts of physical surrounding . An organizations’s environement extend from within the organization itself to the global system and includes air, water, land as well as human beings.
Our SMART Environmental Management System is to reduce eliminate the impacts resulting from the aspects of oil and gas related services and products.
Starting from 2012 ,we established following enviromental objectives :
1. Reduction of office electricity consumption
2. Reduction of office water usage consumption
3. Reduction of paper usage
4. Reuse the draft paper
5. Recycle of office paper waste
6. Use the solar power ( Renewable energy )
7. To reduce elevator usage
8. To reduce noise pollution by generator
9. Plastic free office environment
10. Live green policy
11. Waste disposal management

Our HESS Manager is assigned as Enviromental Management Representative (EMR) here to ensure that EMS requirements are established effectively implement and maintained in addition to his present duties. Management Team is responsible to review the EMS internal audit reports and access the extent of compliance or non-compliance to the organization’s adopted EMS standard and also review the effectiveness of corrective action. Top management will provide human resources and specialized skills and financial resources for implementation and control of SMART’ EMS.
Training will be conducted to get awareness of the importance of the EMS Policy, Objective and targets by the staff. HESS Team provide the establishment of training requirement and as well as investigating the possible sources for the training where in-house training is not adequate , out-source training will be conducted.

As part of the ISO 14001:2004 Certified Company , Our third parties organization(GIC) conduct annual environmental audit to review SMART’EMS objective and issued Audited Report for SMART .
HESS Team from SMART Technical annually conduct internal audit program and environmental activities includes growing plants, house hold water and drinking water donation , Education Program at Primary Level School , Complimentary video distribution program ,titled by Natural Environmental & Plastic Bags , Waste and Your responsibility.

OUR Commitment
“SMART takes zero-tolerance approach to bribery and corruption. We are committed to create an ethical culture and promote the highest integrity where we operate. We are responsible to ensure our employees and third party contractors fully understand our Anti- Bribery and Corruption Policy and share our commitment to comply as well. We believe we can work and achieve greater success together by doing our business right all the time.”

Kyaw Kyaw Hlaing
Chairman
SMART Group of Companies

“ We wish to practice business fairly and ethically. It is our commitment for all our employees and business partners to pledge all work activities with high integrity and transparency. It is our entire stakeholder’s responsibility to battle corruption and conduct business responsibly.”

Yadana Su Hlaing
Managing Director
SMART Technical Services

“Whatever change may be going on in the world around us, one thing remains unchanged: SMART’s commitment to maintain the highest standards of Anti-Bribery and Corruption Policy.”
Ye Kyaw Thu
Managing Director
SMART Electrical Trading

POLICY STATEMENT
This is our policy which creates an ethical culture and promotes compliance and integrity where we operate. We take a zero –tolerance approach to bribery and corruption and create more sustainable platform for future growth. We have responsible to communicate our company commitment to ensure our employee and third parties representative fully understand this scope and application of this Anti- Bribery and Corruption Policy. We make the business together and achieve the great success by doing the right things at all time.
We shall uphold all laws relevant to countering bribery and corruption. We practice and support the principles of Myanmar Anti-Corruption Law 2013, Foreign Corrupt Practices Acts (FCPA) 1977 and guideline of TRACE International. We are the member of TRACE (Anti-Bribery Compliance Solution) since 2013.
WHO IS COVERED BY THE POLICY
This policy shall be applying not only SMART Employees (all individuals working at all levels and grades including senior managers, officers, directors, and employees whether permanent, fixed-term or temporary, trainees, seconded staffs) but importantly also to its agents including vendors, suppliers, sub-contractors, advisers, consultants, joint ventures, partners and representatives which dealing with SMART.
PROMOTIONAL GIFTS, ENTERTAINMENT AND HOSPITALITY
This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties and the giving or receipts of gifts, provided that this is done in accordance with the Financial Regulation. As it is mentioned in our SMART Code of Ethics, all SMART’s Employee cannot offer, pay , make , seek or accept a personal payment , gift, entertainment, meal and travel more than nominal value (defined as USD 25 or any lower limit specified by the location) that might directly or indirectly influence the employees’ business judgments or advantage. Beyond above defined limit, which means more than 25 USD or local equivalent, we need to obtain approval from the line management. We only encourage corporate gift with SMART logo of no more than USD 25 value.
These requirements include any payment on behalf of the Company to government officials at any level, employees or others representatives of government owned business, and political candidates or parties. All employees should obtain SMART ethical committee before offering or exchanging any gift or entertainment with a government official and record it.
As a mentioned at our Code of Conduct for Supplier, SMART personnel are prohibited from accepting anything more than modest gifts, meals and entertainment from supplier or other third parties organization. Ordinary business meals and small tokens of appreciation such as gift baskets which amount are not more than USD 25 or local equivalent, but SMART employee should avoid receiving the travel tickets, frequent meals or expensive gifts, gifts of cash or cash equivalents, such as gifts card and others specials gifts are never allowed.
HOSTING TRAVEL
For time to time, We may received the invitation to host the employee from our client or potential client .SMART permits the payment of certain travel and accommodation expenses for business guests in accordance with their organization expense policies. However, we do not allow providing their personal trip or paying expense beyond related their expense policies. We must obtain their organizations approval for any additional expense.
FACILITATION PAYMENTS
Facilitation Payment are small and illegal payment made lower level of government official in most of the countries. It is make to expedite or speed up the performance of “Routine of government action”. This is sometimes described as “grease payments”. It is our policy that we strictly prohibit to make or accept Facilitation Payment or kickbacks on behalf of company.
If someone asked you to make the payment on behalf of SMART, you always make sure what the payment is for and you should know the detail reason for the payment. If you have any suspicion regarding the payment, you should raise with the Compliance Leader.

CHARITIES AND SOCIAL CONTRIBUTION PAYMENT
While donations to charitable organizations ordinarily are regarded as good as corporate citizenship, but we need to confirm that donation are not disguised illegal payments to government official or other violation of anti-corruption law. We only make charitable donations to a bona fide charity and that are in accordance with our Corporate Social Responsibilities (CSR) Policy.
POLITICAL CONTRIBUTION
We strictly prohibit any circumstance to fund any political parties and or candidates including anyone associated with it by using the company’s money or resources. We also consider the political parties and candidates as government officials. Therefore, no political contributions can be offered or made on behalf of SMART, unless pre-approved by SMART Ethical Committee.
Company Personnel may participate in political activities on an individual basis, with their own money and on their own time but make it clear that your individual political views and actions are personal and not SMART’s. SMART will not reimburse any personal political contributions.
HUMAN RESOURCES
HR Department must needs to obtain an undertaking letter signed by the new employee declaring of no pay in return for receiving the new job appointment at SMART. SMART’s employees have the right to equal treatment and employment without discrimination because of age, race, gender, language, religion, national or social origin and disability or the receipt of public assistance.
REPORTING OF VIOLATION
It is the responsibility of every SMART’s employee to implement, maintain and comply with this Anti-Corruption Policy at all time. Somebody found or suspects a violation of policy, he or she must report to the SMART Ethical Committee, ethicalofficer@smartmyanmargroup.com or Telephone: +95-1-701593. The Ethical committee granted confidentiality to the reporter to dodge the fear reprisals for speaking out. Also, the committee allows the anonymous reporting (Whistle Blowing). The Ethical committee does not take any action the reporter or whistle blower regarding their reporting violation. (Eg, Demotion, Penalty or other reprisal)

All employee and third parties are required to read carefully and clearly understand the SMART’s Anti- Bribery and Corruption Policy. Compliance Team has responsible for regular monitoring and periodically reviews the policy suitability, adequacy and effectiveness and implementation. And also conduct the Anti-Bribery and Corruption Training including case studies, group discussion regularly. Employee or third parties are invited to comment in this policy for improvement. Any comment, suggestion or questionnaires regarding this policy must be addressed to compliance leader. Compliance Team must obtain Ethical Committee approval for revision of this Anti- Bribery and Corruption Policy.

SMART was participate as a member of TRACE Anti-Bribery Compliance Solutions since 2013. The TRACE Organization annual review SMART’s Anti-Bribery Performance and issued Due Diligence Report for SMART . Our due diligence report are available TRACE corporate website www.TRACEinternational.org. Compliance Team from SMART Technical issued Compliance Risk Assessment which assesses the internal based research from all department by individual answering 13 questions related with SMART’s ABC Policy Information ( Anti-Bribery & Corruption Policy).