Expo 2030 Riyadh KAFD Building 1.10, Floor 17 KAFD City Riyadh 12512 Saudi Arabia MAIL TYPE Workflow Transmittal MAIL NUMBER BECHTEL-WTRAN-010498 REFERENCE NUMBER BECHTEL-WTRAN-010498 Final (WF-009302) ABD-0062-WRW-PLN-00001 Workers Welfare Management Plan From Mr Suneeth Gopalakrishnan Nair - Bechtel Global To (4) Cc (3) Sent Thursday, 11 June 2026 1:13:33 PM AST (GMT +03:00) Status N/A Suneeth Gopalakrishnan Nair Final (WF-009302) ABD-0062-WRW-PLN-00001 W... 11/06/2026 BECHTEL GLOBAL WORKFLOW TRANSMIT... BECHTEL-WTRAN-010498 Mr Mohamed Favas - Abyatona Development Company (+3 more...) Ms Noura AlSaweed - Expo Riyadh Company (+2 more...) DOCUMENT ATTACHMENTS (2) ( 2 selected) File Document No Revision Revision Date Title Status ABD-0062-WRW- CRS-00001 02 04/06/2026 Workers Welfare Management Plan B - Approved with Comments ABD-0062-WRW-PLN- 00001 02 04/06/2026 Workers Welfare Management Plan B - Approved with Comments MESSAGE Workflow Review History The attached documents have completed the "ABD-0062-WRW-PLN-00001 Workers Welfare Management Plan" workflow with the following results : This transmittal was automatically generated. Doc No Step Participant Review Outcome Comments ABD-0062-WRW-CRS- 00001 PMC DCC Review S Gopalakrishnan Nair B - Incorporate Comments - Proceed ABD-0062-WRW-PLN- 00001 PMC DCC Review S Gopalakrishnan Nair B - Incorporate Comments - Proceed Workers Welfare Management Plan Design & Build of ERC Headquarter Complex Document No :ABD-0062-WRW-PLN-00001 Document Revision: 0 2 Document Revision Date: 04 /0 6 /2026 Revision No. 0 2 Revision History Revision Code Description of Changes Purpose of issue Submission Date 01 Prepared By Approved By Reviewed by Name Signatures Page 1 | 2 For Approval Ahmad Obeidat Project Manager Job Title PMO Elzein Aamir 22/04/2026 Document No .: ABD-0062-WRW-PLN-00001 Document Name : Workers Welfare Management Plan EXPO 2030 RIYAD H COMPANY 02 For Approval 04/06/2026 Eleumar Carmona HSE Manager ABD-0062-WRW-PLN-00001 Rev 0 2 Page 1 of 42 WORKER WELFARE MANAGEMENT PLAN (WWMP) Item Detail Project I.CP.20 — ERC Site Office (Design & Build), Expo 2030 Riyadh Site Contractor (Employer of Workers) ABYATONA Development Contracting Company Client / Developer Expo 2030 Riyadh Company (ERC) Project Management Consultant Bechtel Document Number ABY - CP20 - WW - PLN - 0001 Revision Rev 00 — Resubmission following ERC rejection (07 - May - 2026) ABD-0062-WRW-PLN-00001 Rev 0 2 Page 2 of 42 Document Control Purpose of this revision. This Rev 00 is a complete rebuild of the Worker Welfare Management Plan for CP - 20. It replaces the earlier submission that ERC formally rejected during the onboarding session held on 07 - May - 2026, where it was acknowledged that the previous document had been copied from an unrelated project and was not developed for the CP - 20 package. This plan has been authored specifically for the I.CP.20 ERC Site Office contract, is implementation - focused rather than a restatement of standards, and addresses each of the deficiencies and agreed actions recorded in the onboardin g meeting notes. Approval and Endorsement By signing below, ABYATONA’s senior management endorses this Worker Welfare Management Plan, confirms the allocation of resources necessary to deliver it, and accepts accountability for Worker Welfare compliance ac ross the CP - 20 workforce and its entire labour supply chain. The CEO/General Manager - signed Worker Welfare Commitment Letter (ERC template) is bound into Appendix G Role Name Signature Date Project Director / Authorized Signatory Project Manager Worker Welfare Officer (WWO) Distribution Recipient Purpose ERC — Worker Welfare (Delivery Assurance) Review, comment, and formal approval prior to mobilization Bechtel (PMC) Oversight and interface management ABYATONA Project Leadership Team Implementation and governance ABYATONA WWO, HR, Procurement, HSE Day - to - day execution and assurance Subcontractors and labour suppliers Back - to - back flow - down of obligations ABD-0062-WRW-PLN-00001 Rev 0 2 Page 3 of 42 Abbreviations Term Definition CAN Corrective Action Notice CSW Construction Site Welfare (WWMS Section 5.2) EPS Employment Practices (WWMS Section 5.1) ERC Expo 2030 Riyadh Company (the Client / Developer) GLA Group Labour Accommodation (WWMS Section 5.3) HSE Health, Safety and Environment IFC PS2 International Finance Corporation Performance Standard 2 (Labour and Working Conditions) Iqama Saudi Residence Permit KSA Kingdom of Saudi Arabia KYR “Know Your Rights” induction training MHRSD Ministry of Human Resources and Social Development PMC Project Management Consultant (Bechtel) SNC Serious Non - Compliance (as defined in the WWMS) TRN Transportation (WWMS Section 5.4) WPS Wage Protection System of the Kingdom of Saudi Arabia WWMP Worker Welfare Management Plan (this document) WWMS Worker Welfare Minimum Standards (ERC - 0000 - SW99 - STD - WW - 00001) WWO Worker Welfare Officer Blue, bold text is used throughout this plan to identify requirements that are ERC - additional (“blue font”) requirements in the WWMS — i.e., the Expo 2030 obligations layered on top of KSA Labour Law. This mirrors the convention in the WWMS itself and confirms that ABYATONA has read, understood, and built implementation around the Expo - specific requirements, not only the statutory baseline. ABD-0062-WRW-PLN-00001 Rev 0 2 Page 4 of 42 Table of Contents Document Control ................................ ................................ ................................ ................................ ......... 2 Revision History ................................ ................................ .......................... Error! Bookmark not defined. Approval and Endorsement ................................ ................................ ................................ ...................... 2 Distribution ................................ ................................ ................................ ................................ ............... 2 Abbreviations ................................ ................................ ................................ ................................ ............ 3 1. Purpose ................................ ................................ ................................ ................................ .................... 6 1.1 Relationship to the WWMS and to this resubmission ................................ ................................ ........ 6 2. General Requirements ................................ ................................ ................................ ............................. 7 3. Scope of Application ................................ ................................ ................................ ................................ 8 3.1 Workers and journey covered ................................ ................................ ................................ ............. 8 3.2 Application of WWMS requirement areas ................................ ................................ .......................... 8 3.3 Exclusion ................................ ................................ ................................ ................................ .............. 9 4. Governance, Leadership and Resources ................................ ................................ ................................ .. 9 4.1 Three Lines of Defense governance model ................................ ................................ ......................... 9 4.2 Worker Welfare organization chart ................................ ................................ ................................ .. 12 4.3 Key personnel and Worker Welfare duties ................................ ................................ ....................... 13 4.4 Management commitment, oversight and resources ................................ ................................ ...... 14 5. Recruitment and Pre - Mobilization (WWMS EPS) ................................ ................................ .................. 16 5.1 Zero recruitment fees and the reimbursement process ................................ ............................... 16 5.2 Recruitment - agency due diligence and supply - chain fee prohibition ................................ .......... 16 5.3 Pre - departure documentation ................................ ................................ ................................ ...... 17 6. Onboarding and Induction (WWMS EPS / CSW) ................................ ................................ .................... 17 6.1 Verification of employment terms ................................ ................................ ................................ 17 6.2 “Know Your Rights” training ................................ ................................ ................................ .......... 17 6.3 Communication of the grievance mechanism ................................ ................................ ............... 17 6.4 Health, safety and welfare awareness ................................ ................................ .......................... 17 7. Employment Practices (WWMS EPS) ................................ ................................ ................................ ..... 18 7.1 Wages, WPS, and payslip transparency ................................ ................................ ........................ 18 7.2 Working hours, rest and leave — corrected planning basis ................................ ......................... 18 7.3 Passports, personal documents and anti - intimidation ................................ ................................ 19 8. Accommodation and Transport (WWMS GLA and TRN) ................................ ................................ ........ 19 8.1 Company - provided accommodation — management arrangements ................................ .......... 19 8.2 Company - provided transport — management arrangements ................................ ..................... 19 8.3 Inspection and monitoring regime ................................ ................................ ................................ 19 8.4 Subcontractor - provided facilities ................................ ................................ ................................ .. 20 ABD-0062-WRW-PLN-00001 Rev 0 2 Page 5 of 42 8.5 Allowance - based arrangements ................................ ................................ ............... 20 9. Worker Engagement and Grievance (WWMS EPS) ................................ ................................ ................ 20 9.1 Worker consultation and outreach ................................ ................................ ................................ ... 20 9.2 Grievance mechanism — the seven required components ................................ .............................. 20 10. Supply Chain Due Diligence ................................ ................................ ................................ .................. 23 10.1 Pre - contract due diligence ................................ ................................ ................................ .......... 23 10.2 Back - to - back flow - down ................................ ................................ ................................ .............. 27 10.3 post - contract monitoring ................................ ................................ ................................ ............ 27 11. Audit and Compliance Program ................................ ................................ ................................ ........... 28 11.1 Self - audit cadence and subcontractor coverage ................................ ................................ ......... 28 11.2 Audit methodology, corrective action and ERC tools ................................ ................................ 28 12. Reporting and Review ................................ ................................ ................................ .......................... 31 12.1 Internal reporting to senior management ................................ ................................ .................. 31 12.2 Monthly reporting to ERC ................................ ................................ ................................ ............ 32 12.3 Contractor declarations ................................ ................................ ................................ ............... 32 12.4 Evidence of implementation and review with subcontractors ................................ ................... 32 13. Escalation and Enforcement (SNC / CAN Protocols) ................................ ................................ ............ 33 13.1 Escalation of Serious Non - Compliance ................................ ................................ ........................ 33 13.2 Corrective action close - out and accountability ................................ ................................ ........... 33 13.3 Contractual consequences and return - to - site ................................ ................................ ............ 33 14. Mobilization Requirement ................................ ................................ ................................ ................... 33 Appendix A — Worker Welfare Organization Chart ................................ ................................ ................... 35 Appendix B — 12 - Month Worker Welfare Audit and Compliance Schedule ................................ ............. 36 Appendix C — Corrective Action Tracker (CAR) Format ................................ ................................ ............. 37 Appendix D — Worker Grievance Log Format (Expo 2030 workers) ................................ .......................... 37 Appendix E — Monthly Worker Welfare Compliance Report — Contents ................................ ................ 37 Appendix F — Subcontractor Worker Welfare Due - Diligence Checklist ................................ .................... 38 Appendix G — Worker Welfare Commitment Letter ................................ ................................ ................. 38 Appendix H — Recruitment - Fee Reimbursement: Process and Worker Acknowledgement ..................... 39 Appendix I — Worker Welfare Responsibility (RACI) Matrix ................................ ................................ ...... 39 Compliance Map — WWMS to this WWMP ................................ ................................ ............................... 41 ABD-0062-WRW-PLN-00001 Rev 0 2 Page 6 of 42 1. Purpose This Worker Welfare Management Plan (WWMP) sets out how ABYATONA Development Contracting Company will implement and maintain compliance with the Expo 2030 Riyadh Worker Welfare Minimum Standards (WWMS) and the ERC Worker Welfare Policy on the I.CP.20 ERC S ite Office (Design & Build) contract. It is a mandatory contractual deliverable under Schedule 2 of the Employer’s Requirements and a pre - condition to workforce mobilization The plan describes the practical arrangements — the people, processes, controls, records, and verification activities — through which ABYATONA will protect the dignity, safety, and wellbeing of every worker engaged on CP - 20, across the full worker lifecycle from recruitment in the home country, through mobilization , employment, accommo dation, and transport, to repatriation. It demonstrates how ABYATONA discharges its responsibility not only for its own direct workforce but for every tier of its labour supply chain, for which it remains fully liable. 1.1 Relationship to the WWMS and to t his resubmission The WWMS contains 66 auditable requirements in Section 5 (of which approximately 90% derive directly from KSA Labour Law and 10% are ERC - additional, marked in blue font), together with the management and reporting obligations in Sections 6 and 7. This WWMP does not reproduce those requirements; it explains, in ABYATONA’s own words and against the specific circumstances of CP - 20, how each will be delivered in practice. A clause - by - clause traceability map linking every WWMS requirement to the section of this plan that delivers it is provided as the Worker Welfare Compliance Map (Project Map) at the end of this document. This revision directly responds to ERC’s feedback. During the onboarding session on 07 - May - 2026, ERC rejected the previous WWMP because it had been copied from an unrelated project and was not aligned with the Employer’s Requirements, WWMS, or ERC Worker Welfare Policy. ABYATONA accepted that finding. This plan has been rebuilt from first principles for the CP - 20 package, remo ves all references to external or unrelated projects, replaces generic statements with defined implementation, and reflects the corrections agreed in the meeting — most notably on working - hour planning assumptions for blue - collar workers (see Section 7), o n recruitment - fee reimbursement eligibility, and on the requirement that HR, Procurement, Delivery, and HSE all carry Worker Welfare responsibilities rather than treating Worker Welfare as an HSE - only function. ABD-0062-WRW-PLN-00001 Rev 0 2 Page 7 of 42 2. General Requirements ABYATONA confirm s that this WWMP satisfies the general requirements of ERC - 0000 - WRW - GDL - 00005. The table below records compliance against each general requirement, and against each “shall not” constraint that caused the previous submission to be rejected. Requirement of t he WWMP Status How addressed Project - specific to the relevant Expo 2030 contract Met Authored solely for CP - 20; named CP - 20 personnel, supply chain, and arrangements throughout Focused on implementation, not policy statements Met Each section defines process, owner, frequency, and evidence Supported by defined processes, responsibilities and evidence Met RACI in Section 4; evidence registers cited per process; appendices provide templates Fully aligned with ERC WW Policy and WWMS, including all blue - font requirements Met Blue - font requirements flagged inline; Compliance Map traces all 66 + Sections 6 & 7 Does NOT reference external or unrelated projects Confirmed All such content removed in this rebuild Does NOT contain generic or copied content Confirmed Written from first principles for CP - 20 Does NOT replicate standards without defining implementation Confirmed Requirements paraphrased then operationalized , never merely restated Does NOT substitute technical specifications for management arra ngements Confirmed Plan describes management controls; design/spec detail is excluded This plan is a controlled document. It will be reviewed and reissued whenever the WWMS is updated by ERC, whenever the CP - 20 supply chain or accommodation/transport arrangements change materially, and at minimum every six months in step with the self - audit cycle. The most recent ERC - issued version of the WWMS shall always take precedence; nothing in this plan limits, ABD-0062-WRW-PLN-00001 Rev 0 2 Page 8 of 42 reduces, or substitutes ABYATONA’s full legal responsibilities under all applicable KSA laws and regulations, including those not expressly referenced. 3. Scope of Application 3.1 Workers and journey covered This WWMP applies to: • Blue - collar and vulnerable workers physically working on the I.CP.20 Site Office, with particular emphasis on low - skilled migrant workers; • the full worker journey — recruitment in the home country, mobilization , employment in the Kingdom, accommodation, transport, and repatriation; • all workers under ABYATONA’s direct employment , and all workers engaged through subcontractors (all tiers), manpower suppliers, and recruitment agents supplying labour or services to CP - 20; • all accommodation, transportation, and welfare arrangements associated with these workers. 3.2 Application of WWMS requirement areas ABYATONA applies the WWMS requirement areas to CP - 20 as follows, consistent with ERC - 0000 - WRW - GDL - 00005: Requirement area Application on CP - 20 Employment Practices (EPS) and Construction Site Welfare (CSW) Apply to ALL workers within scope, regardless of how their accommodation or transport is arranged. Group Labour Accommodation (GLA) and Transportation (TRN) Apply to company - provided accommodation and company - provided transport. Where a worker receives a housing and/or transportation allowance and independently arranges their own, the GLA/TRN specifications do not a pply to those private arrangements; however, ABYATONA remains responsible for ensuring such workers are not exposed to unacceptable risk conditions that would contradict the intent of the WWMS, and verifies this through the welfare check described in Secti on 8.5. ABD-0062-WRW-PLN-00001 Rev 0 2 Page 9 of 42 3.3 Exclusion In line with the guidance, this WWMP does not extend to professional, managerial, or office - based staff who are not considered vulnerable workers, unless otherwise directed by ERC . This exclusion is a scope boundary only; it does not dilute ABYATONA’s general legal duties to those staff. Where a member of office staff falls into a vulnerable category, or where ERC directs inclusion, they are brought within scope of this plan. 4. Governance, Leadership and Resources Worker Welfare on CP - 20 is governed through a single, clearly - resourced framework that places accountability with senior management and embeds delivery across four functions — Worker Welfare, Human Resources, Procurement, and HSE. ABYATONA has taken on boa rd ERC’s point in the onboarding session that Worker Welfare cannot be managed solely as an HSE function ; the governance model below reflects shared ownership. 4.1 Worker Welfare Governance Structure Abyatona is committed to implementing the Expo 2030 Riya dh Worker Welfare Minimum Standards (WWMS) throughout its direct workforce and supply chain. A dedicated Worker Welfare Governance Structure has been established to ensure compliance with KSA Labour Law, Expo 2030 Worker Welfare Core Principles, and the Wo rker Welfare Management Plan (WWMP). The governance structure provides clear accountability for recruitment, onboarding, accommodation, transportation, grievance management, welfare monitoring, audits, reporting, and subcontractor compliance. KEY RESPONSI BILITIES PROJECT DIRECTOR • Provides executive leadership and oversight of Worker Welfare performance. • Reviews monthly Worker Welfare reports and major welfare risks. • Ensures adequate resources are allocated for Worker Welfare implementation. • Approves corrective action plans for Serious Non - Compliance (SNC) cases. PROJECT MANAGER • Overall accountable person for Worker Welfare implementation on the project. • Ensures WWMS requirements are integrated into project operations. • Chairs monthly Worker Welfare Rev iew Meetings. • Escalates significant Worker Welfare issues to ERC and senior management. HR MANAGER • Oversees recruitment, onboarding, employment contracts, and payroll compliance. • Verifies compliance with Qiwa requirements and WPS regulations. • Ensures fee - free recruitment practices. ABD-0062-WRW-PLN-00001 Rev 0 2 Page 10 of 42 • Maintains worker personnel records and grievance records. WORKER WELFARE OFFICER (WWO) • Full - time focal point for Worker Welfare compliance. • Conducts Worker Welfare inspections and audits. • Maintains grievance register and corrective action tracker. • Coordinates worker engagement sessions. • Submits Monthly Worker Welfare Compliance Reports to ERC. • Monitors subcontractor compliance with WWMS requirements. HSE MANAGER • Oversees construction site welfare requirements. • Monitors hea t stress management, welfare facilities, potable water, rest shelters, first aid facilities, and emergency preparedness. • Supports welfare inspections and investigations. CAMP MANAGER • Responsible for labour accommodation management. • Ensures compliance with accommodation standards. • Conducts accommodation inspections. • Maintains accommodation occupancy records and welfare facilities. TRANSPORT COORDINATOR • Manages worker transportation arrangements. • Verifies vehicle inspections, driver competency, maintenance re cords, and transportation schedules. • Ensures compliance with transportation welfare requirements. SUBCONTRACTOR WORKER WELFARE FOCAL POINTS • Implement Worker Welfare requirements within their organizations. • Conduct internal inspections and worker engagement sessions. • Report Worker Welfare performance to Abyatona WWO. • Participate in audits and corrective action programs. WORKER WELFARE REVIEW COMMITTEE A monthly Worker Welfare Review Committee shall be established comprising: • Project Director • Project Manager • HR Manager • Worker Welfare Officer • HSE Manager • Camp Manager • Transport Coordinator • Subcontractor Worker Welfare Representatives The committee shall review: • Worker Welfare KPIs • Audit findings • Grievance statistics • Accommodation inspections ABD-0062-WRW-PLN-00001 Rev 0 2 Page 11 of 42 • Transportation inspections • Recruitment compliance • Corrective Action Status • Serious Non - Compliance cases • Improvement initiatives ORGANIZATION CHART ABD-0062-WRW-PLN-00001 Rev 0 2 Page 12 of 42 4. 2 Three Lines of Defense governance model ABYATONA manages Worker Welfare assurance on CP - 20 through a Three Lines of Defense model, which also dovetails with the layered assurance arrangement ERC operates (contractor implementation, PMC oversight, and ERC assurance): Line Who Role in Worker Welfare First line — Own and manage HR, Procurement, Delivery (Site), and Accommodation/Transport management Operate the day - to - day controls: ethical recruitment, WPS payroll, working - hour planning, induction, site welfare, accommodation and transport man agement, grievance intake. Second line — Monitor and challenge Worker Welfare Officer (WWO), supported by HSE Conduct self - audits, monitor controls, maintain the grievance and corrective - action trackers, compile monthly reporting, and escalate Serious Non - Compliance. Third line — Independent assurance Project Director / senior management review; ABYATONA internal audit where available Independent executive review of performance, resource adequacy, and corrective - action close - out; endorsement of this pl an and of monthly results. External assurance Bechtel (PMC) and ERC Worker Welfare Monitors PMC oversight and ERC document - based and physical audits, including worker interviews and the ERC hotline/app. ABYATONA facilitates access at all reasonable times. 4. 3 Worker Welfare organization chart A CP - 20 Worker Welfare organization chart covering both site and off - site functions is provided as Appendix A . It shows the reporting line from the Worker Welfare Officer to the Project Manager and, through the Project Director, to ABYATONA senior management, together with the functional interfaces to HR, Procurement, HSE, and the Accommodation and Transport leads. Full contact details for each named individual are held by the project and provided to ERC and the PMC. ABD-0062-WRW-PLN-00001 Rev 0 2 Page 13 of 42 4. 4 Key personnel and Worker Welfare duties The following key personnel are appointed on CP - 20. The Worker Welfare Officer is a full - time appointment made within 14 days of contract award, as required by the WWMS. Named individuals are drawn from the CP - 20 project team recorded at the ERC onboarding session; where a role shows a name to be confirmed, the appointment will be finalized before mobilization Role Name Worker Welfare duties on CP - 20 Project Manager Overall project accountability for Worker Welfare delivery; chairs the monthly Worker Welfare review; ensures resources and authority for the WWO; owns the relationship with ERC and the PMC on welfare matters. Worker Welfare Officer (WWO) Full - time WWO. Monitors compliance across EPS, CSW, GLA, and TRN; runs the self - audit programmed ; maintains the grievance log and corrective - action tracker; compiles the Monthly Worker Welfare Compliance Report; immediately escalates Serious Non - Compliance; declares monthly workforce and accommodation data. HR Lead Recruitment, contracts, Qiwa authe ntication, WPS payroll, payslip transparency, working - hour and leave records, recruitment - fee reimbursement, grievance handling support, and “Know Your Rights” delivery. Procurement Lead Appointment and management of subcontractors, suppliers, manpower providers, and the labour supply chain; ensures the WWMS and all ERC requirements are attached to every subcontract; runs pre - contract due diligence with HR participation. ABD-0062-WRW-PLN-00001 Rev 0 2 Page 14 of 42 HSE Lead Health - and - safety integration with welfare: PPE, heat - stress controls, first - aid and site - emergency awareness evidence, and support to the WWO’s audit program. WWMP Author / Environmental Manager [Insert name] Authors and maintains this WWMP; coordinates revisions; supports the WWO on documentation, evidence, and reporting s tructure. Accommodation (Camp) Manager / FM POC Day - to - day operation of company - provided Group Labour Accommodation; hygiene, fire safety, records, and access control (see Section 8). Transportation / Logistics Manager [Insert name — where company - prov ided] Worker transport arrangements, vehicle compliance, driver licensing, and maintenance regime (see Section 8). ERC interface — Worker Welfare Lead AbuJahed Ahad (ERC) Client - side Worker Welfare Lead and approving authority for this plan; ABYATONA’s primary escalation route to ERC. A detailed responsibility - assignment (RACI) matrix mapping every welfare process to these roles is provided as Appendix I , confirming that no welfare obligation rests on a single function and that HR and Procurement carry first - line responsibility alongside HSE and Delivery. 4. 5 Management commitment, oversight and resources Senior management endorses this plan (see Approval and Endorsement) and demonstrates oversight through a standing monthly Worker Welfare review, chair ed by the Project Manager and attended by the WWO, HR, Procurement, and HSE. The review examines audit findings, the grievance log, recruitment - fee cases, working - hour compliance, accommodation and transport monitoring, and the status of corrective actions . Material issues and all Serious Non - Compliances are escalated to the Project Director and to ERC. Decisions, attendance, and actions are minuted and retained as evidence of executive - level review. ABYATONA commits the resources necessary to deliver this plan, including: a full - time WWO; HR, Procurement, and HSE capacity allocated to welfare duties; budget for recruitment - fee reimbursement, compliant accommodation and transport, “Know Your Rights” and audit training, and grievance - mechanism infrastructure (multilingual posters, anonymous channels, ABD-0062-WRW-PLN-00001 Rev 0 2 Page 15 of 42 and a documented log); and the WWO plus two nominated staff to attend the ERC Worker Welfare training modules so that ERC tools and templates are adopted correctly. ABD-0062-WRW-PLN-00001 Rev 0 2 Page 16 of 42 MANAGEMENT OF THE WORKER LIFECYCLE 5. Recruitment and Pre - Mobilization (WWMS EPS) Recruitment is the highest - risk stage in the worker journey, because debt and deception incurred before a worker reaches the Kingdom travel with them and become a project risk once they arrive. ABYATONA applies t he Employer Pays Principle : the worker pays nothing to obtain or keep their job on CP - 20. The controls below are operated by Procurement and HR jointly, with the WWO monitoring effectiveness through audit and worker interview rather than relying on declarations alone. 5.1 Zero recruitment fees and the reimbursement process Zero - fee commitment. No worker on CP - 20 — directly employed or supplied through any tier — pays recruitment fees, and ABYATONA bears all costs of recruitment and relocation, includ ing Iqama and work - permit issuance and renewal, change of profession, exit/re - entry visas, and the return ticket home at the end of the relationship. These obligations are written into ABYATONA’s recruitment - agency agreements and flowed back - to - back into e very subcontract and manpower agreement. Reimbursement. Consistent with WWMS 5.1(a) and the clarification given at the onboarding session, any worker who entered the Kingdom on or after the CP - 20 Contract Award date and who paid recruitment - related costs i s reimbursed in full within two (2) weeks of their new employment contract commencing, or before they start on the Expo 2030 Site, whichever is sooner. The process is: 1. Identify — at onboarding, every worker completes a structured recruitment - cost interview in their own language; HR also reviews the recruitment - agency trail. 2. Assess — HR quantifies any fees, loans, or deductions reported, including those reported despite a signed “no - fee” acknowledgement (a known concealment risk). 3. Reimburse — payment is made to the worker within the two - week window via WPS - traceable transfer, never in cash. 4. Evidence — recruitment agreements, proof of ABYATONA’s payments to agencies, signed worker acknowledgements, and records of any reimbursement (and of investigations where fees were reported despite acknowledgements) are retained in the worker’s HR file and made available for audit. 5.2 Recruitment - agency due diligence and supply - chain fee prohibition ABYATONA and its supply chain use only recruitment agencies that are valid ly registered with MHRSD . Procurement maintains a register of approved agencies with evidence of registration. Every recruitment - agency agreement prohibits any part of the recruitment supply chain — sub - agents, brokers, or third - party intermediaries in the worker’s home country — from charging