GROUP CODE OF CONDUCTPERSOLKELLY PTE LTD & SUBSIDIARIES
Version 2, Issued 14 Jul 2023 by RHQ LegalGROUP CODE OF CONDUCTMessage from the CEO of PERSOLKELLY
Our vision at PERSOLKELLY is to be the leading HR solutions company in Asia Pacific, providing thebest workforce solutions to create greater value and progressive growth for our society. We believethat our roles can help build a brighter future for you and your community.
As such, it is vital that we always display exemplary behavior during our service to our society andcommunities - in compliance with our company and parent company's legal and overall obligations.
This is why this Code of Conduct ("Code") document is important as it provides a framework thatgoverns the behavior of all employees under the PERSOLKELLY company and its wholly owned
subsidiary companies (herein referred to as “PERSOLKELLY”). This applies whether you are anindependent contractor, permanent staff or senior management of our company.
The Code safeguards the interests of all our stakeholders, including employees, our customers andour wider communities that we serve and operate in. The Code supplements our vision, mission &values, existing and future policies, compliance manual, employee handbook, as well as personal
data and privacy laws in your country.
No matter where you are based, offsite at a client's office or at one of our offices across Asia Pacific,
whether you are employed as a temporary, part-time, permanent or full-time staff, this Code must be
followed by all employees, at all times.
This Code comes into force with immediate effect. Please take some time to read through the Codecarefully. If you have any questions or concerns, please raise them with your manager, business orfunctional heads Chief Operating Officer, Chief Financial Officer, or myself.
We trust that each one of you will continue to carry out your role and work in a responsible, ethicaland inclusive manner.

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Page: 1OWNER: RHQ LEGALGROUP CODE OF CONDUCTMission
Our corporate philosophy is creating opportunity, individual growth and society progress.

VisionWork and Smile
Working life is a journey of growth and creation.
We all have big dreams, and there are many different paths to success. Thus, we need to makeour own choices from a range of diversified work opportunities.
Our vision is to enrich society so that all work leads to lives of happiness.

Our Values
PERSOLKELLY, has five core principles that it seeks all of its employees to observe, act and deliver
on, which are:Authentic
Employees are genuine and sincere, carrying ourselves with integrity

Customer-Focused
Employees put customers at the heart of everything and go beyond expectations

Professionalism
Employees deliver exceptional service with uncompromised standards

Teamwork
Employees work as one, learn as one, and progress as one

Innovative
Employees think and work smarter, making things better

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Ethical Code Of Conduct
Employees will act with fairness, honesty, respect, integrity and good faith in their dealings with thegroup's employees, shareholder(s), customers and the wider community.

Working Together
Employees
The PERSOL group of companies (including PERSOLKELLY) will respect the rights of ouremployees, encourage their input and suggestions, and ensure they are treated in a fair and honest
manner, free from harassment, hostility and offensive behaviour.
The PERSOL group of companies expects our employees to:a) perform their duties with skill, honesty, care and diligence, using authority in a fair andequitable manner;b) abide by policies and procedures, instructions and lawful directions that relate to theiremployment and duties;c) ensure they take all reasonable care to secure their own safety and health while atwork and to avoid jeopardising the safety and health of others;d) provide accurate information, give prompt attention and not discriminate on any
unlawful grounds when dealing with people in the course of their duties;e) treat all people they deal with in the course of their employment with sensitivity andcourtesy;f) behave in a manner that maintains or enhances the companies' reputation; andg) comply at all times with the laws and regulations that govern our business andactivities.

Employment Practices
The PERSOL group of companies will maintain employment procedures and policies thataccord with best practice, including those that relate to equal opportunity, selection on merit,antidiscrimination and conflict of interest.
Employees must respect "differences" (gender, sexual orientation, race, nationality, creed, religion,disabilities etc.) and believe it is important to actively leverage those differences. All employees
must be aware of equal opportunity and diversity policies and the responsibility these places onthem to respect the rights of individuals. By maintaining workplace environments where it is easy
for individuals to work, new concepts and value are generated which enables us to provide flexible
approaches towards changing business environments and diversification of customer needs.

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Page: 3OWNER: RHQ LEGALGROUP CODE OF CONDUCTNo Hostile Conduct
Any hostile conduct directed at an individual based on his or her race, age, religion, nationality ordisability 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 it will not be tolerated.
All employees are responsible for upholding this policy and eliminating any practices or behaviour
which are discriminatory or could lead to discrimination, workplace bullying or harassment.
Rejection of Child Labour & Modern Slavery
The PERSOL group of companies does not support child labour and modern slavery practices or
any forms of exploitation of children or young people. The PERSOL group of companies has zerotolerance towards such practices and will comply strictly with the International Labour Organisation(ILO) when dealing with those practices.
Anti-Harassment and Non-Discrimination
The PERSOL group of companies understands and acknowledges that no one should be subjected
to harassment in any form, and that every employee must be treated equally, with dignity andrespect. The PERSOL group of companies provides equal employment opportunities, without
discrimination or harassment based on skin colors, cultures, ages, races, genders, sexuality,
religions, physical conditions, marital status, citizenship or other qualities protected by law. It has
zero-tolerance policy against harassment and discrimination and such conducts will not be
condoned and/or tolerated by the company.

Healthy Balance Between Personal Life And Work
Achieving a balance between personal life and work life is indispensable to all of us enjoying fulland rewarding lives. For that reason, it is important that all employees maintain healthy workplaceenvironments, and foster a culture of mutually helping and supporting each other.

Health, Safety And Environment
The PERSOL group of companies is committed to the goal of a zero harm workplace. Accordingly,
all employees must be committed to continuously improving our workplace health, safety andenvironmental performance.
Safety is an integral part of our everyday activities. This requires both our organisation and allemployees to behave safely at all times.

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Environmental, Social & GovernanceAll employees must ensure that they discharge their duties for the PERSOL group of companies inaccordance with the company’s Environmental, Social & Governance Policy (ESG) policy which
comprises of daily acts and practices that reduces harm towards the environment. Such acts
include but are not limited to taking responsibility to comply with applicable environmental laws,
regulations and contractual obligations, prevent adverse environmental impacts, respond to andreport any environmental incident.

Conflicts
Conflict Of Interest
Potential for conflict of interest arises when an employee could be influenced, or could be perceived
to be influenced, by a personal interest when carrying out his or her duties. A conflict of interest that
leads to biased decision-making may constitute illegal or unethical conduct.
If employees are in a situation where they may be the only person aware of the potential for conflict
it is their responsibility to avoid any conflict that could compromise their ability to perform their duties
impartially, and to attempt to resolve any conflict that may exist.
If an employee becomes aware of any potential or actual conflict of interest, or if the employee is
uncertain whether a conflict exists, or if they become aware that a bribe or improper inducement
has been offered, the employee must report the matter in accordance with each company's policy.

Related Party Transactions
PERSOLKELLY has a Risk Management Policy which requires all related party transactions to bereported and monitored. This procedure assists to identify and assess situations which could giverise to a conflict of interest.

Giving Or Accepting Gifts, Gratuities Or Other Benefits
Employees are prohibited from giving or receiving any sort of improper gift, gratuity or payment,
loan or benefit, directly or indirectly, in order to give or obtain an advantage, or improperly
influencing a decision to secure an advantage, be it personal or business. Employees must not
submit or accept any bribe or other improper inducement.

Insider Trading
Sometimes employees may have access to material non-public confidential information relating to
the PERSOL group of companies or their clients/partners. In those circumstances, the employees

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are not permitted to use or share the information for securities trading purposes or for any otherpurpose except the conduct of the companies' business.
It is always illegal to trade in the securities of Kelly Services Inc and PERSOL Holdings Co. Ltd or
any related options or other rights while in possession of material non-public information, and it isalso illegal to communicate or "tip" such information to others.

Best Business Practices
Conducting Business Overseas
At all times, the PERSOL group of companies' business affairs and operations should be conducted
legally, ethically, and in accordance with community standards of integrity and propriety.
The PERSOL group of companies recognise that business practices differ in different countries.
As a responsible corporate citizen, PERSOLKELLY and its employees and representatives areaware of their obligation to comply with all laws, rules, regulations applicable to the Company
including all anti-bribery and anti-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.

Human Trafficking And Modern Slavery
The PERSOL group of companies has a zero-tolerance policy against all forms of human trafficking,modern slavery and related activities. The PERSOL group of companies is committed to protecting
against trafficking of any person, including employees and candidates.

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

Confidential Information
All information which is obtained by and/or is disclosed to employees of the PERSOL groupcompanies relating to the business of PERSOL group (including strategic business, trade,commercial information, personal data or personal information) is confidential and is the propertyof that PERSOL group company unless agreed otherwise.

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Page: 6OWNER: RHQ LEGALGROUP CODE OF CONDUCTAll employees must make sure that such information cannot be accessed by unauthorized persons,and it should be stored securely so that it is protected against risks of loss, destruction, modification,or improper disclosure.
All employees must ensure that information obtained at work or held in a company's records mustnot be used to obtain personal financial reward or to gain any other benefit. On termination of an
employee's employment, no documentation or information relating to the employee's work or to aPERSOL Group company's business or affairs are to be removed by that employee for any reason,
unless otherwise agreed by a manager in advance.
Releasing confidential documents or information to unauthorised persons is considered misconduct
and a breach of this Code.
Professionalism
All employees must discharge their duties and responsibilities with integrity and professional ethics.
All employees must always demonstrate courtesy and respect towards clients, stakeholders andthe community when dealing with business affairs and providing the services of the PERSOL groupof companies. The PERSOL group of companies requires all employees to exhibit their conducts,
attitude and behavior following the highest standards of competency, honesty, integrity,accountability and responsibility to comply with the applicable laws.

Financial Controls
The PERSOL group of companies has established various financial and accounting controls toensure that assets are protected and used properly. All employees share responsibility for
maintaining and complying with these controls and are required to maintain accurate and reliablefinancial records and reports.

Society And Us
Shareholder(s)The PERSOL group of companies is committed to reporting the companies' progress truthfully andaccurately. All employees will comply with the spirit as well as the letter of all laws and regulations thatgovern shareholders' rights, including the company's disclosure and financial reporting.
All employees engaged in financial reporting are required to exercise diligence and good faith tomaintain accurate and reliable financial records and reports.

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Page: 7OWNER: RHQ LEGALGROUP CODE OF CONDUCTCustomers
All employees have an obligation to use their best efforts to deal with the companies' customers ina fair and responsible manner and to deliver outstanding service. The PERSOL Group ofcompanies must be committed to providing value its customers and expect to be remunerated fairly
for the services they provide.

Electronic Communication And Social MediaAll employees must ensure that any reference to the company that they include on any
noncompany, electronic communications (including email or SMS) or social media (including, butnot limited to, Facebook, LinkedIn, Twitter, blogs or personal websites), must be restricted to factual
details of the employee's position and must not include comments about company or about current
or former customers, employees or associates of the company or any PERSOL Group's confidentialinformation.
All employees must not send or post material which may cause reputational or detrimental harm tothe company or any current or former customers, employees or associates of the company.
All employees must not send or post material which pose a risk to the health, safety or wellbeingof any current or former employee or breach any bullying policy.
All employees when using the companies' electronic communication services (e.g. email, Facebookor other services hosted by a PERSOL group company) must comply with each company's
electronic communications and social media policy.

Keep It Legal
Compliance With Laws And Regulations
All employees must comply with all laws, rules, regulations applicable to the Company including all
employment and labour laws, personal data protection laws, anti-bribery laws, insider trading laws,
health, safety and environmental laws, and all policies established by the Company.

Whistleblower Policy
All employees must raise matters of concern with their supervisors or managers. However, eachjurisdiction has a whistleblower policy in the event that an employee should require the legislative
protection of a whistleblower regime. In that instance employees must refer to the whistleblower
policy as there are measures to provide protection and support for employees who make complaints
or disclosures are included in the policy. A copy of the policy is available at on the intranet and/orcompany website.
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Page: 8OWNER: RHQ LEGALGROUP CODE OF CONDUCTCompliance And Breaches Of The Code Of Conduct
All employees are responsible for observing this Code and for ensuring it is not breached.
The PERSOL Group of companies promotes an open working environment in which all employees
are able to report instances of unethical, improper, unlawful or undesirable conduct without fear ofintimidation or reprisal. Any employee who, in good faith, makes a complaint or disclosure about
an alleged breach of the Code and follows the reporting procedure will not be disadvantaged orprejudiced making the disclosure. Any report made by an employee in good faith will be acted upon;a prompt investigation will take place and the employee will be informed of the outcome. The
particular circumstances of each case will determine the level of detail reported to the employee.
If an employee breaches the Code or any of the policies and procedures (or gives permission or
allows another employee to breach them) they may be subject to disciplinary action which mayinclude termination of employment.
If an employee is in doubt, or if an employee has any questions about their responsibilities or theCode, it is the employee's responsibility to seek clarification from their relevant manager or eachcompany's compliance team. Employees may discuss a matter, or seek advice on how to proceedwith a matter, at any time.
This Code operates in conjunction with all other applicable company policies, standards andprocedures.

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Page: 9OWNER: RHQ LEGALGROUP CODE OF CONDUCTGROUP CODEOF CONDUCTAUSTRALIA | CHINA | HONG KONG | INDIA | INDONESIA |MALAYSIA | NEW ZEALAND | PHILIPPINES | SINGAPORE |SOUTH KOREA | TAIWAN | THAILAND | VIETNAM

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