Pandemic Policy

1. Introduction
   • The Company has a tradition of conducting its business in accordance with the highest ethical standards and in compliance with all applicable laws. The Occupational Health and Safety regulations states that an employer must ensure that it provides a working environment which is safe and does not present a risk to the health of its employees.
   • The Company is committed to ensuring that the workspace as far as is reasonably practical protects the health, safety and welfare of employees, suppliers, service providers and customers (“business partners”) in accordance with ethical considerations and our legal duties.
   • This is particularly the case when an infectious disease develops into an epidemic or pandemic, and creates increased risks for our employees, business partners, and the general public.
   • The World Health Organisation (WHO) declared in March 2020 that the coronavirus (COVID-19) is a global pandemic.
2. Purpose

The purpose of this Policy is to set out the Company’s approach to health and safety within the workplace in relation to the outbreak and containment of epidemics / pandemics.

3. Scope
   • This Policy applies to all employees and business partners who enter the Company premises, whether permanently or temporarily employed or contracted to provide services to the Company.
   • In this Policy, “workplace” includes all locations and premises where the Company conducts business and where employees and/or business partners carry out their duties in the course of providing services to the Company.
4. Commitment

The Company:

• is committed to managing health risks in the workplace in the most reasonable manner practicable and employees and business partners with respect and good faith;
• supports the rights of all employees and business partners to work in an environment that is, so far as is reasonably practicable, safe and without risks to health or safety; and
• is committed to slowing the spread of epidemics / pandemics.

1. Roles and responsibilities
   • The HSE Team is responsible for ensuring the health, safety and welfare of its employees and is committed to developing preparedness programs and taking all reasonable steps in response to the pandemic in order to:
     • prevent the spread of infections in the workplace and assist its employees and business partners to reduce their exposure to and prevent contraction of the epidemic / pandemic;
     • provides up-to-date Government Department and WHO health information in relation to the epidemic / pandemic, including relevant symptoms and methods to limit exposure. Employees and business partners are encouraged to follow the recommendations of the WHO which are available: https://www.who.int/docs/default-source/coronaviruse/getting-workplace-ready-for-covid-19.pdf?sfvrsn=359a81e7_6;
     • encourage and assist those employees who have reason to believe that they have, or may have, contracted the epidemic / pandemic, to obtain a diagnosis from a medical practitioner;
     • where appropriate, provide standard precautions such as personal protective equipment (e.g. hand sanitizer, soap, gloves etc.);
     • continue to operate as efficiently as possible throughout the period of concern while encouraging employees to remain positive and productive while working remotely if required or instructed to do so;
     • as far as practicably possible, maintain the safety of any premises which is controlled by the Company so that the work place may not be claimed to pose a risk to the health and wellbeing of employees, business partners and the community in general.
   • HSE Manager Mr. Muhammad Hudaykuliyev will:
     • be committed to the provision and maintenance of a healthy and safe workplace and to assisting the executive management team in carrying out its obligations in terms of the OHSA and this Policy;
     • consult and participate in the preparedness program and diligently carry out the directions from the executive management team regarding workplace hygiene and safety measures;
     • require that their reporting team members as applicable abide by the recommended safety measures of the WHO as well as the precautionary statements of Ministry of Health and Medical Industry of Turkmenistan;
     • use risk identification, assessment and control principles to reach the Company’s health and safety objectives. This includes:
       • informing, and where appropriate training all team members in relation to this Policy and their health and safety obligations including e-mail distribution of campaign material and interactive training / question and answer sessions through video conferencing or cloud-based applications;
       • promoting regular and thorough hand washing by team members and visitors;
       • promoting good respiratory hygiene – making face masks and tissues / wipes available along with closed bins for disposing of them;

• advising colleagues and team members to consult national travel advice and to remain up to date with news and communication around the pandemic/epidemic;
• obtaining personal details – mobile and e-mail addresses of any visitors, caterers or meeting participants where applicable, stating clearly that their contact details will be shared with local public health authorities if any of them becomes ill with a suspected infectious disease, reserve rights of access where meeting participants or visitors refuse to share their details for these purposes and have a plan of action to isolate any person who shows signs of infection at the meeting;
• diligently implementing contingency plans to mitigate production losses, cater for leave of absence demands by team members who require quarantine and support team members who are authorised to work remotely through the use of mobile applications and teleworking functionalities. Support for team members working from home should include:
  • conducting an internet connectivity audit for work from home staff and consider UPS and connectivity back-up options;
  • ensuring that remote IT support is available to assist work from home employees with any connectivity or functionality issues;
  • ensuring that work from home employees have laptops and mobile devices and that teleworking / cloud – based applications such as Zoom, Gmail / Google Chat, WhatsApp Video and Slack as the case may be are installed and running;
  • maintaining ongoing communication and progress tracking through cloud-based applications with daily kick-off and wrap up telephone calls at the start and end of each day;
  • weekly catch -up meetings through Zoom or similar mobile conferencing system should continue as usual or increase in frequency to maintain morale and productivity levels during the period of concern.
• Employees must:
  • comply with the precautions of governments and the WHO;
  • comply with the lawful instructions of supervisors and senior management regarding hygiene, shift alternating and work from home contingency plans as applicable;
  • ensure that they are familiar with the health and safety campaign material posted at the workplace and disseminated through news and other public broadcasting channels;
  • take reasonable care for their own health and safety;
  • take reasonable care for the health and safety of family members, colleagues and business partners;
  • regularly and thoroughly wash their hands with an alcohol-based hand rub or wash them with soap and water for at least 20 seconds;
  • where possible, avoid touching their eyes, nose and mouth, or shaking hands with others;

• cover their mouth and nose with a tissue when they cough or sneeze, and dispose of used tissues immediately. If they do not have a tissue, use their bent elbow;
• cooperate with the Company, and follow any of its directions, in so far as is necessary to enable compliance with any requirement under the OHSA and/or this Policy which includes;
  • stay home if they feel unwell. If they are well enough to work but would like to minimize the risk of infecting others, ask their manager/ supervisor whether they can temporarily work from home;
  • notify their manager/ supervisor immediately if they believe that they may have contracted the epidemic / pandemic, or been in direct contact with someone that has contracted the epidemic / pandemic; and
  • seek medical advice promptly if they believe they have contracted the epidemic / pandemic, and follow these directions and the directions of their healthcare practitioner.

2. Remote and off-site work
   • The Company will genuinely consider all employee requests to work from home, or from another location (away from the workplace) (“off-site”). The Company will then confirm in writing whether the request is accepted or not.
   • At any stage, the Company may direct one or more of its employees to work from home, or off-site. The affected employees agree to follow any such direction and comply with all reasonable instructions from their line managers or supervisor regarding the work from home protocol.
   • This includes without limitation:
     • remain contactable and available to undertake work as reasonably directed during the applicable period while making use of the mobile and cloud -based applications installed on work devices. To the extent necessary, employees who are authorized to work from home may submit an expense claim to the Company for an agreed pro-rata portion of data or wireless internet connectivity as well as electricity use during the work day at the employee’s home;
     • provide daily/periodic updates to a specified person, the human resources department or their line manager as to their current health and wellbeing;
     • perform tasks not ordinarily performed by the employee in the ordinary course of their duties, but which are reasonable, fall within their general skills and experience and can be undertaken remotely.

3. Leave
   • Subject to the provision of Labor Code and regulations of Ministry of Health and Medical Industry of Turkmenistan, the Company’s sick leave policy and any relevant contractual arrangement, where an employee is:
     • unwell;
     • unable to get to work because of travel restrictions (international or domestic);
     • directed by the Company to obtain a medical certificate or not come into the workplace; and/or

• is required to self-isolate or be in quarantine,

the Company will discuss their ability to work from home and/or whether they would like to take annual leave, sick leave and/or unpaid leave for the period they are not able to carry out their regular duties.

• The Company will genuinely consider any feedback from the employee and then make a determination as to next steps. The employee agrees to follow any determination made by the Company.
• Any unauthorised leave of absence may be subject to disciplinary action by the Company.

• Sick Leave
  • Should an employee contract COVID-19, the Company’s sick leave Policy in line with the regulations will be applied. This means that:
    • The employee should obtain a medical certificate which can be sent electronically to his/ her supervisor. Should the employee be infected, he/she will be advised to remain in isolation for a period of at least 14 days and this time out of the office will be considered as paid sick leave (assuming that the sick leave allocation due to the employee has not been exhausted);
    • after the quarantine period and even if the employee does not display any symptoms, the Company may nevertheless require the employee to be tested by a medical practitioner and to provide the Company with a medical certificate confirming that the employee can return to work;
    • if an employee is directed to obtain a medical certificate, but is otherwise feeling well, the employee will be paid for their normal working hours up until the test results are obtained – the Company will exercise its discretion as to whether to require the employee to work from home or to attend at the workplace pending the results of the test.
  • Self-Isolation and Self – Quarantine:
    • To the extent that an employee requests self-isolation in the absence of a diagnosis, special paid leave or a work from home policy may apply at the Company’s discretion.
    • The employee must either take annual leave or unpaid leave. The Company will however consider all applications for self-isolation and quarantine and may upon its sole discretion accommodate an appropriate form of paid leave.
    • If the Company has reason to believe the business partner has been infected, the Company is entitled to require that the business partner remain home for 14 days and to undergo medical testing. This period of absence will be treated as special paid leave, rather than sick leave or annual leave. As the absence from work is on demand from the Company. If the business partner works from home with the consent of the Company, the absence will not be treated as leave.
  • Travelling:
    • Note that employees who have travelled to affected countries will, on their return, be required to self-isolate for a period of 14 days prior to returning to the workplace and may be requested to produce a medical certificate confirming that they are not infected.
  • This Policy takes precedent over any existing leave policy implemented by the Company.

1. Breach

Any breach of this Policy will be taken extremely seriously and may result in disciplinary action and or any other remedial action as required, which may include termination of employment.

2. Version and review

This Policy may be subject to review and amendment at the Company’s sole discretion. Employees will be notified of any amendments and will be responsible for ensuring that they are up to date and familiar with the contents of this Policy at all times.