"Sign off on organizational sustainability targets" We as a holder of the certificates of ISO9001 Quality Management, ISO 14001 Environmental Management System, ISO 45001 Occupational Health & Safety Management System and Responsible Care Management System, had been annually setting and achieving the below organizational sustainability targets since we achieved the certificates in 2008 till 2020. • Energy Consumption Reduction Target • Water Consumption Reduction Target • Effluent Discharged Reduction Target • Waste Reduction Target • Incident Reduction Target • Zero-Fatality Target • Loss Time Injury (LTI) Free Target • Customer Complaint Reduction Target In 2021, due to COVID-19 Pandemic, we had to suspend our whole Objective & Target Initiative comprising both sustainability targets and the business targets. Instead of this broader Objective & Target Initiative, in this reporting period, we started practicing the company’s Golden Rules comprising labour, environmental and social related rules, as our annual targets. The Golden Rules are as follows. • Use specified PPE. • Use work area permit. • Work safely at height. • Report all injuries and incidents. • Not safe, stop! • No pollution to water drainage • Be customer friendly. • No blame each other • No drugs or alcohol in workplace • Say ‘We’, ‘Us’, ‘Our’ and ‘Together’. As the company achieved all the Golden Rules targets for 2021, the Board of Directors has signed-off these achievements in 2022. The company also achieved the OSH targets of maintaining ‘Zero-Fatality’ and ‘Loss Time Injury (LTI)’ for 2021 and the Board of Directors has signed-off in 2022. In 2022, we resume practicing the broader Objective & Target Initiative comprising annual sustainability targets and also keep practicing the Golden Rules. "Supervise Environmental, Social, and Governance reporting" The Managing Director of the company supervised and participated in all of the meetings held for this reporting.

We will develop code of conducts for Labour Rights/ Decent Work and Environment within two years. Up to now, we have been practicing as per the manuals, procedures and work instructions of our ISO14001 Environmental Management System and ISO45001 Occupational Health & Safety Management System for the sustainability topics.

"Labour Rights/ Decent Work" The company has been practicing an Integrated Management System (IMS). In the IMS, ISO 45001 OHSMS and ISO14001 EMS are two sub-systems. To effectively implement the company’s IMS, the IMS Steering Committee chaired by the Managing Director and led by the Executive Directors, was formed in 2009, and reformed in 2022. This committee is directly responsible for the labour rights issues regarding occupational health and safety. The committee oversees the following committees and teams. 1) OHS Main Committee (ie. For occupational health & safety) 2) RCMS Committee (ie. For Responsible Care Management System) 3) Legal Committee (ie. For legal compliance) 4) Internal Audit Team (ie. For IMS auditing) 5) Emergency Response Team (ie. For supervising First Aid Team, Firefighting & Evacuation Team, Schedule Waste & Chemical Team) For the other labour rights issues so far, Human Resources Department and the Administration Division are only two responsible units with limited influence over it. After developing the code of conduct for labour rights/ decent work, there will be a group particularly responsible for the company’s Labour Rights/ Decent Work. "Environment" The above IMS Steering Committee led by the highest level of the company is primarily responsible for all the environmental issues and to achieve the environmental objectives and targets of the company.

Please see our optional information in No.4.

“Labour Rights Risks & Corruption Risks” We will develop standard risk assessment procedures for these two sustainability topics within two years. “OHS & Environment” Conforming to our ISO45001 OHS and ISO14001 EMS, we have been implementing our standard operating procedure titled UP-P14 Risk Assessment & Establishing Objectives for risk assessments of the occupational health, safety and environment. This procedure in general covers identification and classification of risks, evaluation of risks, preventing, removing and reducing risks, communicating with the interested parties (if necessary) and establishing, implementing and evaluating of HSE objectives & targets. The IMS Steering Committee with the approval of the Board of Directors, is responsible for this process.

Please kindly see our optional information in No. 6.

“Process for Raising Concerns over OHS (Human Rights/ Labour) & Environment” The members of the group of committees and teams under the IMS Steering Committee are at almost every unit, work area or floor of the company. They have rights and responsibilities to raise the concerns related to the OHS and environment through the hierarchy of the IMS Steering Committee. “Informal Process for Raising Concerns over Human Rights, Labour (Other than OSH) & Anti-Corruption” We do not have a formal process for raising concerns over human rights, anti-corruption and labour rights (ie. other than OSH). However, any employee can report informally (eg., through supervisors) or directly to the Managing Director or the Executive Directors when they have a serious concern. However we will develop a code of conduct comprising formal process for raising concerns over labour rights/ decent work and environment within two years. We have also incorporated the following two commitments into our updated Company Policy. - To provide safe, healthy, decent and inclusive workplace for our workforce and have consultation and participation of non-managerial employees in implementing it - To protect employees from reprisal when reporting incidents, hazards, risks and opportunities We will put processes for raising concerns about the company's conduct on labour rights/ decent work and anti-corruption in their future codes of conduct.

“Detailed Process for Raising Concerns over OHS & Environment (ie. HSE)” The process for raising concerns over OHS & Environment (ie. HSE) is communicated to all employee/ workers in local language. In fact, as for this process, we have established two-way communication channels between the IMS Steering Committee and the all employees/ workers. The process is titled UP-P16 HSE Communication, Participation & Consultation. This is one of our IMS documents and the IMS Steering Committee is responsible for it. This process has two parts. The first part is for external communication and the second part is for internal communication which consist of the process for raising concerns about the company’s conduct regarding HSE. The detailed process of the second part of UP-P16 is as follows. ‘UP-P16 HSE Communication, Participation & Consultation (Internal Communications)’ Steering Committee shall ensure the internal communication being implemented effectively through the following methods: a) Two-Way Communication Two-way communication channel has been established through memo, email, suggestion box, toolbox meeting, discussion etc to; 1. collect information from employees for improvement 2. ensure the information is pass to concern personnel. b) HSE Issue The company shall communicate to all employees about HSE progress, change in IMS, difficulties during implementation and recognition of significant contribution of individuals, through noticeboard or email or toolbox meeting. Management Representative (MR) shall ensure that all the employees have been properly communicated and/ or trained the followings. 1. Company policies, objectives and management programme 2. Identified significant risks after risk assessment 3. Applicable legal and other requirements 4. Emergency preparedness programme 5. Role and responsibilities of employee 6. Customer and other interested parties’ requirements 7. Identified significant hazards and aspects Safety Committee Meeting If any Quality, HSE issue occurred, the concern HOD shall create Non-Conformance Report (UP-F10) (Notification) in SAP System and evaluate the need to carry out corrective action. Should there is corrective action required, the Steering Committee shall review the need of risk assessment before the proposed corrective action being implemented. The concern personnel shall be communicated to prevent the incident recur. Steering Committee shall ensure employees (including non-manager workers) have been participated and consulted the followings. 1) Involvement in Risk Assessment (UP-F66) and its countermeasures 2) Involvement in Monthly Incident Report ( UP- F73) 3) Provide consultation where any change affects the HSE performance 4) Representation on HSE matters/ issues 5) Determining the needs and expectations of interested parties (Refer to UP–CM ) 6) Involvement in incident investigation (Refer to UP–P13 ) 7) Involvement in developing and reviewing the company policy, objective and management programme (Refer to UP–P14 ) 8) Determining how to fulfil legal requirements and other requirements (Refer to UP–P15) 9) Determining applicable controls for outsourcing, procurement and contracting (Refer to UP–P03) 10) Drills (Refer to UP–P12 ) 11) Ensuring continual improvement 12) Determining competence requirements, training needs, trainings and training evaluations (Refer to UP–P10); Furthermore, one of our commitments regarding raising concerns over our policy and protecting reprisals stated in the Company Policy is as below. - To protect employees from reprisal when reporting incidents, hazards, risks and opportunities

In accordance with the Company Policy, the remedies are available to all company's employees/ workers.

Since our IMS is integrated with ISO9001 QMS, ISO14001 EMS, ISO45001 OHSMS and Responsible Care Management System, we have been practicing the below three procedures consisting of capturing lessons regarding quality and HSE. A. UP-P13 Incident Investigation Procedure This procedure in general covers: 1) obtaining incident information, forming investigation team; 2) executing investigation; 3) finding out root cause; 4)estimating impacts; 5) implementing corrective action; 6) communicating & remedying affected employees/ workers or interested parties; and 7) periodical reviewing of the records. B. UP-P08 Improvement Procedure This procedure in general covers: 1) monitoring company’s quality, HSE performance & activities; 2) finding non-conformance (or) receiving comment/ complaint from employees/ interested parties (or) acknowledging failed HSE objective; 3) root cause investigation; 4) sourcing information; 5) taking corrective action; and 6) improving IMS C. UP-P09 Internal Audit Procedure This procedure in general covers: 1) appointing Lead Auditor; 2) setting audit team and audit checklist; 3) auditing; 4) issuing non-conformance report 5) issuing audit summary; 6) taking corrective action 7) improving in management review meeting

There are 6 directors in the Board of Directors of the company. They all are also Executive Directors. 5 directors are males and 1 director who is the Director of Production, Research & Development, and Quality Assurance departments is female. There is 1 male director who is 30-50 years old in the Board of Directors. 3 directors are from minority ethnics and/ or religions. There is no independent director in the Board of Directors.

According to the socio-economic context of Myanmar and the locations of our operations, we identified the above five issues as the material human rights issues connected with our operations.

We hope that the labour rights commitments mentioning in our Company Policy and the ISO 45001 OHSMS practicing in our company are aligned with the international standards. In terms of OSH, the company received ‘ASEAN-OSHNET EXCELLENCE AWARD 2017’ in 2018, for the company’s OSH performance for it’s workforce. The Company Policy has been updated and approved by the Board of Directors, and signed by the Managing Director. It is publicly available on our website (i.e., https://www.upgpaint.com/). The Company Policy is only applied to the company’s operations.

‘Formation of Workplace Coordinating Committee for Collective Bargaining’ In accordance with the Settlement of Labour Dispute Law of Myanmar, the company has formed a Workplace Coordinating Committee on July 6, 2020, with a view to make collective bargaining. The committee members are 3 representatives of workers elected and signed by 471 workers and 3 representatives of the employer. The company also submitted the formation of Workplace Coordinating Committee and the list of the committee members to Department of Labour, Hlaing Tharyar Township, Yangon. The company updated and submitted the committee member list again on February 2, 2022. ‘Forced Labour, Child Labour, Non-Discrimination, OSH and Working Conditions’ Conforming to the Company Policy and the company’s Human Resources Department Manual, we do not allow forced labour, child labour and discrimination of any form in the company. The company has also been collaborating, as necessary, with the Department of Labour of Myanmar and the company’s workers for these issues in accordance with the respective laws of Myanmar.

In the reporting period, during the deadly second wave and third wave of COVID-19 outbreaks in Myanmar, the company executed the followings as OSH and the support the families of COVID-19 affected employees/ workers. A. PREVENTION & MITIGATION OF COVID-19 RISK AT WORKPLACE Engineering Controls Administrative Controls Support to COVID-19 Suspect or Infected Employees B. CSR RESPONSE TO COVID-19 PANDEMIC A Corporate Social Responsibility (CSR) Program called ‘UPG P&C’s Oxygen Concentrators Donation Project’ was implemented. A. PREVENTION & MITIGATION OF COVID-19 RISK AT WORKPLACE 1. ENGINEERING CONTROLS Enhancing Ventilation At all the company’s workplaces including the Head Office and the factories, doors and windows are opened if possible, all ventilating fans at the factories are switched-on, to reduce air-con enclosed areas and increase circulation of outdoor air as much as possible. Physical Distancing At all company units including the Head Office and the factories, the company repositioned workplaces and rearranged seating to create safer distance between the employees and demarcated the safe distances (at least 6 feet apart) using visual indicators (ie. Demarcation lines and marks) at all entrances, work areas and common places. Plastic partitions between the employees are installed where there could not be 6 feet apart. Floor markings are drawn in the elevators and near to the entrances of the elevators and washrooms to reinforce social distancing. Empty desks and meeting tables are marked with cross signs to maintain the safe distance. At the factory canteen where most employees enjoy dining, stanchion lines are drawn at the entrance area and in front of the food counter, for social distancing. At all the dining places in all company units, dining tables are rearranged as individual and/ or individually partitioned. Isolation In the factories, temporary isolation rooms are arranged for sick employees, to isolate before they are taken to the nearest government’ fever clinics. Visitors are discouraged but isolated parlors are also arranged for outside contractors, suppliers and buyers, with social distancing rules. Isolated restrooms are also available for the company’s delivery personnel who are in and out of the company premises frequently. 2. ADMINISTRTIVE CONTROLS Closure of Company Operation All the company units including the Head Office and factories were closed down during the periods of stay-at-home orders of the Ministry of Health & Sports (MOHS). The factories were reopened after passing the inspection of the health authorities and getting the permission to reopen. Work from Home (WFH) and Telework Employees whose job functions can be performed from home were to work from home (WFH) during 1st, 2nd and 3rd waves of the outbreak. The in-person meetings were replaced with Zoom video-conferencing. Staggering Work Shifts To spread out the employees across the time and place, and reduce possible congregation of the employees, at all company units including the Head Office and the factories, on-site employees had to attend on different days and times depending on their job functions. Some employees were to perform their work with hybrid work arrangement (ie. WFH and on-site alternatively). Vaccination Almost all employees in UPG P&C have been vaccinated and the company keeps the copy of the employees’ vaccination certificates. Antigen Rapid Test (ART) According to the company’s Workplace Health Program, at all company units including the Head Office and the factories, all onsite employees are required to take Antigen Rapid Test (ART) conducted by professional health workers, once every two weeks. The ART pass cards are to be attached to the employees’ ID card necklace. Safe Commuting Safe ferries to and from the workplaces are arranged for all employees. Employees have to ride the ferries from the start point to the destination. Ferries provide social distancing seating, temperature screening and hand sanitizers on board. The employees must wear face mask and face shield in the ferries. No employee is allowed to use public transport or taxi. Safe Entry At all the company units including the Head Office and the factories, employee temperature screening at the entrance of the workplaces are conducted daily, in accordance with the social distancing rules. The temperature screeners are equipped with non-touch thermometer, face mask, face shield, apron and gloves. Face Covering At all company units including the Head Office and the factories, all persons enter into the company’s premises must wear face mask at all times except during activities that require masks to be removed. Employees must also wear mask and face shield in the ferry. The company issues KN95 masks to all employees daily. Social Distancing At all company units including the Head Office and the factories, the company repositions workplaces and rearranges seating to create safer distance between the employees. The physical touch-points where employees could have close contact (ie. Within 6 feet) are minimized by staggering shifts. No facing seat, no workplace visit and no cross-deployment is allowed. In- person meetings are encouraged to replace with Zoom video-conferencing. Subject to the company’s staggering meal breaks, employees can have their lunch at the canteens where individual tables and/ or individually partitioned tables, disposable cups, paper towels, pedal sinks, soaps, sanitizers, water and pedal waste bins are available. (All employees must bring their lunch boxes. No Eat out is allowed.) Employee locker rooms in all company units must be used with staggering shifts. The lockers must be closed and cleaned by the respective employee after using. Cleaning & Disinfection At all the company units including the Head Office and the factories, every person enters into the company premises are encouraged to frequently wash or sanitize their hands for at least 20 seconds. The company also produces hand sanitizers and freely distributed to the employees. The hand sanitizers are available at all entrances, guestrooms, office rooms, meeting rooms, locker rooms, canteens and wash rooms. The practices of handshake, hug, fist-bump or high-five are discouraged. All high-touch surfaces like door handle, table surface, light switch, elevator bottom, handrail etc. are sanitized regularly. All the work areas, common areas, locker rooms, isolation rooms, canteens and washrooms are cleaned with disinfectant spray regularly. Daily housekeeping is done by the company’s housekeeping teams. No person is allowed to enter into the office areas with their outside footwear. Every person has to change their footwear with office footwear, clean their outside footwear and keep in the designated shoe cabinets. Visitor Entry At all company units including the Head Office and the factories, all visitors entering the company’s premises must have appointment, receive temperature screening, wear face mask, register at the security gates, draw visitor card and meet in the designated guestroom. The registration is to record the entry and help health authorities for contact tracing in case transmission is occurred. All frequent visitors like contractors and suppliers must fill Health Assessment Form. Information Dissemination At all company units including the Head Office and the factories, the orders and announcements of the Ministry of Health & Sports (MOHS) related to the company operation are strictly followed. And they are posted on the office notice boards, displayed as vinyl posters and stick on the walls at common areas. The instructions, warnings and reminders for COVID-19 are posted at the entrances and all other necessary areas. Through the PA systems, employees are being regularly reminded of MOHS and the company’s COVID-19 guidelines, especially for mask wearing, hand washing, and social distancing. UPG P&C Office Rules booklets comprising the company’s COVID-19 guidelines are in the drawer of the every office desk. Every floor and work area has Floor or Area In-Charge and Assistant In-Charge. Their contact numbers are provided to all respective employees for emergency. A list of local health emergency authorities and administrative authorities’ contact numbers is given to all employees concerned. Employees at Home Employee who is unwell or has symptoms of COVID-19, or tested positive for COVID-19, or identified by MOHS as close contact of an infected person, or has a sick family member at home with COVID-19, or his/ her neighborhood is heavily infected by COVID-19, is to immediately inform his/ her superior and stay home. Compliance Monitoring The following personnel are responsible to monitor and make sure the compliance of company’s COVID-19 Workplace Guidelines. All Departmental and Section Heads Health, Safety & Environment (HSE) Executive Security Teams 3. SUPPORT TO COVID-19 SUSPECT OR INFECTED EMPLOYEES Antigen Rapid Test (ART) All onsite employees are required to take Antigen Rapid Test (ART) conducted by professional health workers once every two weeks, through company’s Workplace Health Program. If an employee is tested suspect or infected, he/ she will be isolated, briefed about patient guidelines at home and neighborhood and drive to home by a designated company car. He/ she will be cured at home for 21 days. Information Dissemination To provide necessary support to the suspect or infected employee, the record of him/ her will be disseminated to the respective Departmental/ Section Head, Heads of Human Resources Department, Health, Safety & Environment (HSE) Committee, Administrative Department and the Company’s Doctor. Financial Support Every suspect or infected employee can apply for a company’s financial support of Kyat 100,000 through Personnel Affairs Committee (PAC) with ‘COVID-19 Suspect/ Infected Employee Support Application Form’. Medicines & Consultation Support With the consent of COVID-19 suspect or infected employee, the company will support drugs and medicines which will be deducted from the financial support he/ she is entitled. The employee shall daily report to the Company’s Doctor of his/ her health condition. To have consultation and motivation, the employee is informed to join the company’s ‘Talking about COVID-19’ Viber Group. Medical Oxygen Support Every COVID-19 suspect or infected employee can apply to hire the company’s oxygen concentrator or oxygen cylinder (with application & safety guidelines) through Personnel Affairs Committee (PAC) with ‘O2 Request Form’.