MEGA SQUARE SDN. BHD.

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

MSSB-004 REV.02.202306

MEGA SQUARE SDN BHD

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

Document No. : MSSB-004

REV.02

1. INTRODUCTION

Mega  Square  Sdn  Bhd  (“the  Company”)  believes  that  hiring  qualiﬁed  individuals  to  ﬁll  various  posi ons
contributes  to  the  overall  success  of  the  Company.  The  Company  will  comply  with  all  relevant  labour
regula ons  and  principles  rela ng  to  recruitment  of  foreign  workers.  Where  applicable,  this  Policy
complements and is supplementary the Company’s Hiring Policy and Business Code of Conduct.

2. OBJECTIVE

This policy will provide clarity and transparency on the processes of hiring or legalizing foreign workers. The
third-party recruitment agent appointed or to be appointed by the Company is expected to be bound by this
Policy.

3. PROHIBITION OF FORCED LABOUR

The Company strictly prohibits the use of forced labor in any form, including but not limited to prison labor,
bonded labor, and indentured labor. No employees who are imprisoned, bonded, or indentured shall be
u lized by the Company or any of the appointed recruitment agent.

4. ZERO RECRUITMENT FEES AND COST

The Company implements Zero Recruitment Fees for new hiring. Workers (foreign or local) shall not be
required to pay employers’ or agents’ recruitment fees or other related fees for their employment. Fees shall
also not be collected indirectly for example, through deduc ons from wages and beneﬁts.

No monetary deposit is collected by the Company or the appointed recruitment agent from any foreign
worker or local worker as part of the hiring process.

MEGA SQUARE SDN BHD

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

Document No. : MSSB-004

REV.02

4.1 RECRUITMENT FEES

The costs and fees associated with recruitment, travel and processing of workers’ employment shall be borne
by the Company. The details of the costs and fees are set out in Table 1 below:

Table 1: Fees and Costs to be Borne by Employer

Agency service fees, recruitment or placement fees in both sending and receiving countries.

Airfare or fare for other modes of interna onal transporta on from sending to receiving
countries

The cost associated with passport

Visa processing fees

Work permits fees including renewal

Government Levy unless legally allowable for deduc on

Pre-departure training or orienta on, skills tests, medical examina on, or other
requirements for employment by sending or receiving countries

Transporta on in receiving country to and from airport to supplier facility or provided
accommoda on.

Government-approved insurance, taxes, or other related fees that law requires the
employer to bear

10
.

Any other fees imposed by sending or receiving country government for recruitment.

11 Where applicable and required, pre-departure accommoda on cost a er employment at

the source country and upon arrival at receiving country

12 Costs to insure the foreign worker
13 Costs for tools, uniforms, safety gear and other equipment needed to perform the worker’s

job

MEGA SQUARE SDN BHD

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

Document No. : MSSB-004

REV.02

4.2. REIMBURSEMENT OF RECRUITMENT FEE

In the case of any type of employment fees paid by the employee in any stages of hiring process as set out in
Table 1, such employee may raise their request for reimbursement by se ng out clearly the details of such
payment or through the Company’s recruitment fee due diligence set out below. The reimbursement process
shall be ﬁnalised within 3 month from the commencement of employment or from the conclusion of the
recruitment due diligence and in accordance with the following process:



Recruitment fee due diligence shall include understanding from the employee the stages, the sum
and the receiving party of such payment through the following interviews with workers in a
conﬁden al se ng:

a)  During interview process in the sending country
b)  During departure at the departure airport
c)  Upon arrival in Malaysia
d)  3 months a er arrival
e)  Annually for a minimum of 3 years



Conclusion of due diligence and analysis of the due diligence result to iden fy the appropriate
payment amount



Announcement of the reimbursement scheme to employee including the sum, the payout meline
and other details



Pay out based on the announced reimbursement scheme with worker’s acknowledgment of the
reimbursement fee received individually



Document the reimbursement scheme and workers’ acknowledgment of reimbursement fee
received (by P&A department)

4.3. REMEDIATION OF LOCALLY RECRUITED FOREIGN WORKERS

In case of the Company recruits foreign workers locally, the Company shall pay the full cost of recalibra on,
legalisa on of workers and any other related local costs incurred.

4.4 RECRUITMENT AGENT DUE DILIGENCE

The selec on of recruitment agencies is based on many factors including, but not limited to, reputa on, cost,
and reliability. The recruitment agency shall be legally registered in its home country and has a long-standing
reputa on. The P&A department shall conduct a proper due diligence on the poten al recruitment agencies
accordingly to the Company’s due diligence checklist for foreign worker agent. The recruitment agency shall
sign an agreement to adhere to this Policy, the Company’s other relevant policies and Dyson’s Forced Labour
Preven on and Ethical Recruitment Policy and Ethical and Environmental Code of Conduct before the
Company engages their services and conﬁrms their appointment.

Subject to their terms of engagement, the recruitment agencies may be required to provide services
including but not limited to, providing accommoda on, picking up the foreign workers, and assist to obtain
work permits for the foreign workers.

The  Company  shall  assess  and  audit  the  recruitment  agencies  annually  in  accordance  with  the  relevant
sec on  in  the  Company’s  ISO  9001  manual  to  ensure  con nuous  compliance  of  the  recruitment  agencies
with the above stated policies.

MEGA SQUARE SDN BHD

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

Document No. : MSSB-004

REV.02

5. RECRUITING PROCESS AND PROCEDURES (APPLICABLE TO FOREIGN WORKERS)

In hiring foreign workers, the following process will be followed by the Company:

5.1 CONFIRMATION TO HIRE FOREIGN WORKERS

The Personnel & Administra on Department together with the HOD’s will verify and forecast the manpower
planning based on the Company’s business requirements.

The Personnel & Administra on Department is then required to seek approval from the Management. Once
the approval is given, Personnel & Administra on Department will proceed with the recruitment of foreign
workers through recruitment agencies.

5.2 HIRING PROCESS

P&A Manager shall communicate with the recruitment agent on the job requirements for foreign workers.
Job descrip ons and any other hiring materials will be free from language that may discriminate or deter
candidates based on protected characteris c.

The Company will ensure all recruited workers in the Company Premises:

 Aged 18 years old and above,
 Provide documentary evidence such as Passport Identification

The recruitment agent shall carry out the age veriﬁca on during hiring process via the following methods:

 If photo is available, make sure the photo and iden ty on the submi ed documents match the

appearance of the applicant.

 Check that the original seal between the photo and card is intact.
 The date of issue should broadly tally with the condi on of the card. It is suspicious if a card issued

many years ago looks brand new.

 If the proof of age document is suspicious, applicants can be asked further informa on to enable the

recruitment agent to cross check with the informa on stated in the document received.

The recruitment agent will screen applica ons and resumes prior to scheduling interviews. Interviews are
generally conducted by the recruitment agent in the na ve language and adopt the best prac ces as set out
in the “Interview process & Evaluation” of the Company’s Hiring Policy.

During the interview, the recruitment agent is required ask the foreign workers the questions set out in the
Company’s Forced Labour Prevention Questionnaire. The questionnaire shall include the following questions:

a)  Voluntarily choose to work in MSSB?
b)  Any form of payment made for the hiring process or recruitment agent?
c)  Do you know which country you will be working if this job application is successful?
d)  Do you know what is the job which you have applied for?

MEGA SQUARE SDN BHD

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

Document No. : MSSB-004

REV.02

5.3 SCREENING

The foreign workers’ biodata and results of the forced labour preven on ques onnaire will be submi ed by
the recruitment agency to the personnel of the Personnel & Administra on Department for screening
purposes and to communicate on the list of approved foreign workers to the recruitment agency.

5.4 MEDICAL CHECK-UP

The recruitment agency must ensure that the approved foreign workers undergo medical checkup in
accordance with the authori es’ requirements.

5.5 EMPLOYMENT CONTRACT

The workers will be briefed thoroughly on corporate proﬁle, job func ons and contract details as part of the
employment process before the workers are asked to sign the employment contract by the agent at least one
week (7 days) before the workers departure. The agent has also made available all the employment contracts
in the worker’s na ve language.

6. EMPLOYMENT – FOREIGN WORKERS

6.1 ARRIVAL OF FOREIGN WORKERS

Where applicable, the assigned person from Personnel & Administra on Department has to pick up the
foreign workers from the airport within 24 hours of their arrival.

Within a reasonable period upon arrival, the foreign worker will be asked if they have paid any recruitment
fee in accordance with Sec on 4.2 above. The response received shall be ﬁled accordingly by the P&A
department.

6.2 ACCOMMODATION

Where applicable, the Company will provide accommoda on and bus transporta on for the foreign workers
to travel to work. Foreign workers shall not be required to pay for accommoda ons and transporta on
provided to the workers who stay in the company provides accommoda on. Workers are free to move
around the provided accommoda ons, without any undue restric ons.

If any foreign worker would like to arrange their own accommoda on, he/she shall reach out to P&A
Manager for discussion.

7. INDUCTION TRAINING

For all the newly recruited foreign workers, induc on training will be conducted by the Personnel &
Administra on Department’s personnel as well as personnel in charge of with the assistance of an
interpreter.

MEGA SQUARE SDN BHD

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

Document No. : MSSB-004

REV.02

8. HEALTH SCREENING

The assigned personnel from Personnel & Administra on Department will proceed to register foreign
workers at FOMEMA and have the workers to do their health screening within one month of arrival or
legaliza on in Malaysia at panel clinics with all costs borne by the Company.

8.1 MEDICALLY FIT WORKERS

For workers who are cer ﬁed as they are ﬁt to work, the assigned personnel from Personnel &
Administra on Department will submit the passport to Malaysia Immigra on to obtain permits.

8.2 UNFIT WORKERS

Workers who are cer ﬁed to be medically unﬁt to work will be repatriated back to their home country. The
transporta on cost will be borne by the Company.

9. PASSPORT HANDLING

The  Company  recognizes  that  possession  of  personal  iden ﬁca on  documents,  such  as  passports,  is  a
fundamental  right  of  all  individuals.  The  Company  respects  the  autonomy  and  freedom  of  the  foreign
workers and aﬃrm their right to retain their passports in their possession at all  mes.

The Company provides secure and accessible passport lockers for employees to store their passports during
working hours, if they choose to do so. These lockers are conveniently located within the workplace and
accessible to employees throughout the day (24 hours access) and are under CCTV monitoring for security
reason.

The Company also provide compartment lockers for workers at the hostel for the storage of their passports
and other personal iden ty documents with full and direct access without any restric on at all me.

It is important to note that the usage of the passport lockers or the lockers at the hostel is en rely op onal.
Foreign workers are under no obliga on to store their passports in the provided lockers. They have the
freedom to keep their passports in their possession or make use of the lockers as they see ﬁt.

Any request for the temporary submission of passports for visa processing or other legal requirements shall
be handled with transparency and in accordance with the Company’s Passport Policy.

10. OPENING OF SAVINGS ACCOUNT

The assigned personnel from Personnel & Administra on Department will open saving accounts for salary
purpose.

11. DOCUMENT FILING

The assigned personnel from Personnel & Administra on Department will keep the biodata of the foreign
workers in their personnel ﬁle.

MEGA SQUARE SDN BHD

FOREIGN WORKERS RECRUITMENT AND EMPLOYMENT POLICY

Document No. : MSSB-004

REV.02

12. CONTRACT RENEWAL

Upon comple on of their contract period, the workers are free to choose whether to renew their contract or
be repatriated back to their home country. In the event of workers choose to go back to their home country,
the transporta on cost will be borne by the Company.

13. EARLY RESIGNATION BEFORE CONTRACT EXPIRY

In the event of a worker’s early resigna on due to:

13.1 PERSONAL REASON

If the worker opts for early termina on of the contract, there will be no threat or punishment and such
resigna on shall be handled according to the employment contract. The worker will be repatriated and
transporta on costs will not be borne by the Company.

13.2 MEDICAL GROUND

In the event the medical doctor cer ﬁes the worker to be medically unﬁt during the employment period, the
worker will be repatriated and transporta on costs will be borne by the Company.

14. FAIR DISCIPLINARY AND TERMINATION PROCEDURE

In  the  event  the  worker  commits  any  oﬀence  or  fails  to  comply  with  any  of  the  Company’s  rules  and
regula ons,  disciplinary  ac on  will  be  taken  in  accordance  with  the  type  and  severity  of  the  oﬀence.  The
Company  may,  on  the  ground  of  misconduct  consistent  with  the  fulﬁlment  of  the  express  or  implied
condi on of service, a er due inquiry;

a) Issue warning le er; or

b) Dismiss the employee without any no ce.

c) Any such ac ons in accordance with the Company’s disciplinary procedure.

If a worker is terminated for cause through proper and fair disciplinary and termina on procedure, the
Company shall not be required to pay for the cost of return transporta on.

15. CONCERNS/GRIEVANCE

For any ques ons or concerns regarding this Policy (including the reimbursement fee procedure), the workers
may raise their ques ons or concerns:

a)  to the General Manager, the P&A Manager directly;
b)  email through concern@megasquare.com.my; or
c)  raise  a  concern  anonymously  through  “Let’s  talk”  portal    (available  at

https://megasquare.com.my/publications/

16. RESPONSIBILITY

The Personnel & Administra on Department is overall responsible for the implementa on of this policy.