倫理守則 Code of Ethics

1. Introduction

Kelly Services (Singapore) Pte Ltd (“KSG”) and its subsidiaries (individually and collectively the “Company”) are committed to doing the right thing, conducting ourselves in a legal, ethical, and trustworthy manner, upholding our regulatory obligations, and complying with both the letter and spirit of our business policies and applicable local laws in the countries where we operate.

This Code of Ethics (“Code”) is intended to help us recognize and deal with ethical issues, deter wrongdoing, provide mechanisms to report and prevent dishonest or unethical conduct and foster a culture of honesty and accountability.

Each of us has a personal responsibility to conduct ourselves, and ensure that our suppliers, agents and representatives are aware of their obligation to conduct themselves, in a legal, ethical way and to comply with both the letter and the spirit of this Code.

No code or policy can anticipate every situation that may arise. This Code is intended to serve as a guide. Employees are encouraged to ask their manager questions about particular circumstances that may involve the provisions of this Code. Employees also may present their questions to their respective head of human resources (“HR”) in their country teams, or the Regional Head of HR, Regional General Counsel or Chief Operating Officer at KSG.

For the avoidance of doubt, any reference to “us” or “we” shall refer to the Company, its subsidiaries, and their respective employees and officers.

2. Anti-Bribery and Anti-Corruption

We take pride in conducting our business with integrity and are committed to abiding by all applicable anti-bribery laws. Please refer to our Anti-Bribery and Anti-Corruption Policy for further details.

3. Insider Trading

Individuals who have access to material non-public confidential information are not permitted to use or share the information for securities trading purposes (“insider trading”) or for any other purpose except the conduct of the Company’s business. It is always illegal to trade in the securities of Kelly Services, Inc and Temp Holdings Co., Ltd. or any related options or other rights while in possession of material non-public information, and it is also illegal to communicate or “tip” such information to others.

4. Corporate Opportunities

Each of us has a responsibility to the Company to advance its legitimate interests. We must not: (a)personally take for ourselves or divert to others opportunities that are discovered through the use of Company property, information or our respective positions;
(b)use Company employees, property, information or our respective positions for personal gain; or
(c)compete with the Company director or indirectly for business opportunities.

5. Confidentiality and Privacy

The Company is committed to safeguarding the integrity, availability, and confidentiality of the Company’s information and information systems, as well as those entrusted to the Company by its customers, employees, candidates, applicants, vendors, and suppliers. Accordingly, each of us are expected, as a condition of employment, to safeguard the data and systems from unauthorized use, disclosure, modification, destruction or loss by complying the Company’s Privacy Policy, which can be found on the respective Company’s websites.

Confirmation and private information includes personal data, as well as Company information that has not been made public, such as business plans, research or strategies, and inside financial information that could be used for personal gain.

As a Company employee, you are personally responsible for any comments about, and on behalf of the Company, that you post to a social media network (e.g. Facebook, LinkedIn, Twitter, YouTube, blogs or forums). Please refer to the Corporate Communications and Social Media Policy for further details.

6. Protection and Proper Use of Company Assets

We must each protect the Company’s assets and ensure their efficient use. No one is to use Company assets for personal benefit.

7. Fair Dealing

We have a responsibility to deal fairly with each other and our customers, employees, applicants, candidates and suppliers. No one must take unfair advantage of anyone else through manipulation, concealment, abuse or confidential information, misrepresentation of material facts or any other unfair dealing practices.

8. Behavior in the Workplace

The Company is committed to maintaining a work environment which promotes individual dignity and mutual respect and following all applicable laws and legislation related to labour and human rights. Inappropriate behavior in the workplace, which extends to business travel and after-hour Company sponsored events, will result in disciplinary action, up to and including termination.

It is the policy of the Company to protect the employment rights of qualified applicants and employees regardless of an individual’s race, age, religion, nationality and/or any other protected categories under applicable laws.

If is the policy of the Company to comply with all applicable laws concerning the employment of persons with disabilities. Consistent with that commitment, it is the Company’s policy not to discriminate against qualified individuals with disabilities in regard to application procedures, hiring, advancement, discharge, compensation or other terms and conditions.

Any hostile conduct directed at an individual based on his or her race, age, religion, nationality, or disability is expressly prohibited. Sexual advances, requests for sexual favours, other unwanted verbal or physical conduct, or communication of a sexual nature is considered inappropriate behavior in the workplace and will not be tolerated.

To avoid perceptions of favouritism, conflicts of interest, lack of confidentiality, unfair treatment or potential liability, (i) a relative of an employee, (ii) a person living in the household of an employee, or (iii) a person in a dating, romantic or other intimate relationship with an employee should not be hired or transferred into a position that results in him or her being in the same chain of command as that employee without the prior written approval of the Regional Head of HR. In the event circumstances develop between the employees that would have required the written approval noted above, both employees are require to report the circumstances to the Regional Head of HR.

We believe that violence in the workplace is unacceptable. In order to help protect our co-workers and ourselves, we have an obligation to immediately report any situation involving violence, threats, bullying, or intimidation. If you have concerns about the immediate safety of yourself or others, please contact local authorities before reporting the situation internally.

We strive to ensure a safe workplace for all our employees. We are each responsible for paying close attention to our surroundings, following all safety rules, and reporting any unsafe conditions. The use of alcohol or illegal drugs while at work is not permitted as it can prevent us from thinking clearly and can endanger the safety of others.

9. Compliance with Laws, Rules and Regulations

Each of us shall, and shall ensure that our suppliers, agents and representatives are aware of their obligation to, comply with all laws, rules, regulations applicable to the Company including all anti-bribery and corruption laws, employment and labour laws, insider trading laws, health, safety and environmental laws, personal data protection laws, and all policies established by the Company.

10. Risk Tolerance

Risk is inherent in the pursuit of any worthy business objective. Although risk cannot be eliminated, not all risks are justified or appropriate. We are willing to accept appropriate business risks that are within our tolerance and assumed in pursuit of a suitable reward. We have no appetite for activity that endangers our employees or others, or puts our integrity or financial well-being at risk.

11. Anti-Human Trafficking

Risk is inherent in the pursuit of any worthy business objective. Although risk cannot be eliminated, not all risks are justified or appropriate. We are willing to accept appropriate business risks that are within our tolerance and assumed in pursuit of a suitable reward. We have no appetite for activity that endangers our employees or others, or puts our integrity or financial well-being at risk.

12. Whistle Blowing, Reporting Dishonest or Unethical Behavior

When in doubt about the best of action in a particular situation, employees should talk to their managers. Known or suspected violations of laws, rules and regulations applicable to the

Company, of this Code or any Company policy must be promptly reported to your respective head of HR in their country teams or the Regional Head of HR.

In making a report, employees should provide as much details as possible, such as names, dates, times of the incident and supporting information or other evidence.

If the employee does not feel that a reported violation has been addressed, he or she should follow up directly with the Regional General Counsel or Chief Operating Officer at KSG. All reports will be treated with strict confidentiality and the identity of the “whistle-blower” will be protected unless required to be disclosed by applicable laws. The Company reserves the right to take disciplinary action against any employee who makes a report in bad faith.

The Company will not tolerate any harassment or retaliation of any employee who makes a report in good faith and any such conduct may be subject to disciplinary action.

13. Failure to Comply

The failure by any director, officer or employee to comply with the laws, rules or regulations governing the Company’s business, this Code or any Company policy will constitute grounds for corrective action, up to and including termination of employment or engagement.

Tempstaff Taiwan