11 Aug 2020

Working from home – the new normal?

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Homeworking might once have been restricted to entrepreneurs, novelists or other roles that don’t require an office space, but since the COVID-19 pandemic started employees from all kinds of sectors have been forced to work from home. Thankfully, technology has developed to the point where the ‘portable office’ has become realistic for a wide range of jobs, but what are the long-term implications of this exodus from the employer’s office?

Click on the links below to read our international guide to the legal implications of working from home.

United Kingdom

Regardless of industry, sector or location, the COVID-19 pandemic has dramatically changed how individuals work. Both employers and employees have had to quickly adapt to the Government’s policy of “work from home, wherever possible”. There are likely to be ongoing repercussions from this unprecedented move to home working, including a spike in employees who now, having experienced the positives that working from home can provide, want to work from home more, or even permanently.

We set out below some of the most commonly asked questions about home working employers should consider.

Do employees have a right to work from home?

Employees do not have a statutory right to work from home but employees who have at least 26 weeks’ continuous service have a statutory right to make a flexible working request (but they cannot make more than one request in a 12 month period). Employees can request to change how many hours they work, where they work from and when their work is done. Employers must carefully consider each flexible working request and can only refuse if the reason falls within one or more of the eight business reasons provided by statute (such reasons include the burden of additional costs, an inability to reorganise work among existing staff or if there will be a detrimental impact on the employee’s performance or the quality of their work). Given that many workplaces have been forced to move to working from home during the pandemic, it may be harder for employers to refuse these requests going forward. Any improper refusal may lead to claims for up to eight weeks’ pay, currently capped at £538 per week, or claims of discrimination, which are uncapped.

What if my employees refuse to work in the office?

Employers should consider the employee’s specific reason for refusing to work in the office, as well as the employee’s personal circumstances. If an employee is ‘shielding’ or vulnerable, employers must take extra care when managing their return to the office.

Under section 44 of the Employment Rights Act 1996, employees have the right not to be subjected to a detriment because they have refused to return to work if there is a serious or imminent danger at the workplace. Given that the threat posed by the COVID-19 pandemic has been described by the UK Government as “serious and imminent” it is likely that section 44 will be cited by some employees refusing to return to work. To mitigate the risks of such claims and to comply with their health and safety obligations, employers should take steps to ensure the workplace is “COVID-19 secure” in line with current government guidance. Employers must also carry out regular risk assessments and keep an accurate paper trail of the decisions made regarding employee safety, in case of future claims.

What if the employee’s home environment isn’t suitable to work in?

Employers have a duty to provide a safe place of work for their employees and this duty extends to the home office. If employees do not have the necessary equipment to work from home safely, such as a screen or office chair, employers should consider contributing financially towards purchasing such equipment. It is also important that employers (provided they comply with the latest government guidance at all times) consider keeping some part of their office open, so that employees whose home environment is not suitable to work in can choose to come to the office. For any individuals whose circumstances are more complex, employers should take advice on a case-by-case basis.

How can I protect confidential information when my employees WFH?

When employees work from home, it is harder for employers to supervise the handling of confidential information and data. Whilst it may be acceptable for files to be left on employees’ desks in the controlled environment of the office, the same may not be true at an employee’s home. Employers must communicate their expectations to employees as to how they should treat confidential information when working from home.

To better protect the company’s confidential information, employers should review their confidentiality policies and implement new measures that specifically deal with working from home on a more frequent or even permanent basis. Employers should also consider reviewing contracts of employment to ensure they have robust confidential information clauses and post-termination restrictions.

Employers must also take care to ensure processing of any personal data is in line with the Data Protection Act 2018. Employers should review their data protection policies to ensure employees know what their obligations are and that the misuse of data will be a disciplinary manner. Some element of employee monitoring may also be necessary and this right should ideally be contained in contracts of employment.

How can I manage employee performance when they WFH?

Managing performance outside the office presents new challenges, particularly as monitoring employee behaviour when they are not physically present is difficult. Employers must make clear through their policies what is suitable and acceptable behaviour when working from home. Managers should also maintain an appropriate level of contact with employees to monitor progress. However, excessive attempts to supervise homeworkers, such as routinely intercepting emails or frequent “check-up” phone calls should be avoided as they could result in allegations of harassment or a breach of the implied duty of trust and confidence.

If an employee is not performing, employees can implement performance improvement plans remotely. However, employers should attempt to hold any grievance, disciplinary, or performance management meetings face-to-face or over video.   

Do I need to introduce a WFH policy?

The sudden and urgent requirement to work from home in response to the COVID-19 pandemic has meant that employers have had to tackle issues related to home working as and when they arise. We recommend introducing a working from home policy to ensure  that going forward employees are clear about working from home practices. We also expect to see an uptick in home-working requests so it is advisable to have in place a comprehensive working from home policy.

Hong Kong

Prior to 2019, it was very uncommon for employees to work from home. Geographically speaking, Hong Kong is relatively small and the commute to work for the majority of its employees is less than one hour. However, the Hong Kong protests and the Coronavirus have changed the way employees work. As Hong Kong experiences its third wave, many employers have directed their staff to work from home. Although many employees can carry out their contractual duties at home, employers need to ensure that they continue to fulfil their statutory requirements and provide adequate support to their employees who have switched from working in the office to working at home. We consider below a few of the issues that employers should consider when they allow/direct their staff to work from home.

Do employees have a right to work from home?

Employees do not have a right to work from home. However, if an employee makes a request to work from home and their duties can be carried out remotely, the employer should not unreasonably refuse this request, especially if the request is made by an employee for reasons related to childcare or looking after a family member. It would be prudent for employers to set out in writing the basis on which employees may work from home, whether it is a temporary or permanent arrangement, how employees apply for permission to work from home and what factors are taken into account when considering their application. Where, for health and safety reasons, employers direct employees to work from home they should also make clear their expectations of employees in terms of working hours and arrangements.

What if my employees refuse to work in the office?

The answer depends upon the reasons why the employees are refusing to work in the office. All employers are under a statutory duty to, as far as reasonably practicable, ensure the health and safety at work of its employees. This is a requirement set out in section 6(1) of the Occupational Safety and Health Ordinance Cap. 509. If an employee considers that the office is not a safe environment or that they may risk their health on their commute to work, the employer should try to reach an agreement with the employee which appeases their concerns.

What if the employee’s home environment isn’t suitable to work in?

Hong Kong is challenging for employees when it comes to working from home as the average apartment is very small. Employers owe a common law duty to their employees to take reasonable care of all employees’ safety and health and to provide a safe place to work, even if the employee is working from home. An employer should, before agreeing to an employee working from home, take steps to ensure that the employee is safe, failing which they can be liable for negligence as well as a breach of their statutory duties. Attention should be paid to whether there is sufficient space, ventilation and lighting for the employee to work from home as well as considering the home environment generally.

The average Hong Kong employee is unlikely to have a private room at home which can be used as a workspace and for most employees they will likely be working on the dining room table. This can be an issue if they need to speak with/have face-to-face discussions with customers and have no quiet area to move to for a phone call.

All employers in Hong Kong are required to have in place an insurance policy which covers the employer’s liabilities under the Employees Compensation Ordinance (Cap. 282). In the event that an employee is injured whilst working from home, it is likely to be considered an injury sustained in the course of their employment and the employer will be liable to pay compensation to the employee. Employers should check with their insurer as to whether their policy includes a provision for employees who are working from home.

How can I protect confidential information when my employees WFH?

In order to be able to fulfil their contractual duties, employees should be able to receive and make calls without their conversation being overheard. Confidentiality clauses contained in an employee’s contract continue to apply when the employee is working from home.  Employees who need specific equipment such as a laptop, mobile phone, printer, etc. in order to perform their duties should be provided with the same by their employer and be held responsible for the equipment. The employer should make it clear that any office equipment provided should be used for work purposes only and should not be shared with other household members. The employer should also remind all employees that the IT Policy continues to apply to employees who work from home as it does to those working from within the office.

How can I manage employee performance when they WFH?

Employees working from home are subject to the same rules and standards of conduct as if they were working in the office. Where there is a drop in standards/performance issues the employer should deal with these issues in the same way as it does with an employee who does not work from home. In the event that disciplinary action becomes necessary, the employer should ensure that any procedures which are set out in the handbook such as having face-to-face meetings and interviews with witnesses can be carried out through remote conferencing facilities. The Hong Kong courts require that where employers have detailed procedures set out in handbooks/policies regarding disciplinary procedures, the employer is required to comply with its procedures before taking any disciplinary action. In the event that they fail to do so, any subsequent dismissal of the employee can be challenged. Handbooks/policies should be updated to cover situations where employees are working from home so that any procedures documenting the carrying out of investigations can be complied with.

Do I need to introduce a WFH policy?

All employers should have a WFH policy where they have staff working from home. The policy should detail what is expected of staff working from home and also how often they should communicate with their line manager. The line manager should check in with the employees to ascertain whether they need any equipment in order to work from home and whether the working environment is suitable to working from home. Where working from home is mandated due to a government lockdown, the employee’s line manager should try and ensure that they have regular check-ins with the employee to detect any mental health issues. The WFH Policy should remind employees to notify their employer if they have any accidents at home given that the employer’s obligations regarding accidents or incidents suffered in the course of employment will still apply to employees working from home.

United Arab Emirates

Working from home (WFH) in the private sector has tended to be the exception rather than the rule in the UAE. Many employers were resistant to the idea of WFH, often simply on the basis that short commutes between home and the workplace negated the need for most employees to WFH. However, in March 2020 the landscape literally changed overnight when strict UAE government-mandated restrictions suddenly came into force in response to the COVID-19 pandemic. Employers and employees adapted to the new norm of remote working with impressive speed and success and it seems that WFH in some form or another is here to stay in the UAE.

For the purpose of this alert, we have focussed on the legal requirements that currently apply to:

  1. Private sector employers and employees subject to Federal Law No. 8/1980 (the “UAE Labour Law”) and the Ministry of Human Resources and Emiratisation Resolution (“MOHRE”) No. 281 of 2020 on remote working in the private sector during the application of precautionary measures to limit the spread of COVID-19 (the “Remote Working Resolution”). Employers based in free zones should take advice on whether the Remote Working Resolution applies to them; and
  2. Private sector employers and employees subject to the Dubai International Financial Centre (“DIFC”) Law No.2/2019 (the “DIFC Employment Law”).

Up until 31 July 2020, the DIFC Presidential Directive No. 4/2020 (the "DIFC Directive"), which implemented emergency employment COVID-19 measures, was in force. As at the time of writing, the DIFC Directive had not been extended; accordingly, any aspects of the DIFC Employment Law that were relaxed whilst the DIFC Directive was in force (including in relation to health and safety obligations – see below) must be complied with in full from 1 August 2020 onwards.

A separate remote-working regime is currently in force for national employees of certain UAE ministries and federal bodies (see Cabinet Resolution No. 27/2020). A detailed examination of that regime is outside the scope of this note but, in summary: certain criteria apply to determine whether a role is suitable for remote-working; and two types of remote-working are available – partial remote working (where the employee's work time is divided between the main workplace and the remote workplace) and full-time remote working (where the job is performed completely outside the main place of work). The UAE Federal Authority for Government Human Resources (FAGHR) has already announced that remote working will continue for some of these federal and ministry employees, even after the COVID-19 restrictions ease.

Do employees have a right to work from home?

Private sector employees do not have a legal right to work from home under either the UAE Labour Law or the DIFC Employment Law. However, in response to the COVID-19 pandemic, UAE-government imposed restrictions on movement, caps on workplace capacity and health and safety obligations, which effectively forced employers to implement and encourage remote working where possible.

For onshore UAE employers, the Remote Working Resolution set out guidelines to regulate remote working. In particular, it mandated employers to implement a remote working system for all workers whose jobs did not require their physical presence at the main workplace, and to give priority for remote working to employees from defined vulnerable groups. This included employees who were: pregnant; mothers to children in grade 9 and below at school; over 55 years old; a person of determination (that is, those with a disability); or suffering from respiratory or chronic illness. The Temporary Guide attached to the Remote Working Directive also imposed certain obligations on employers, including providing the necessary tools for remote working. In addition, the MOHRE Ministerial Resolution No. 279/2020, considered in our previous alert, empowered employers to implement WFH systems.

The Remote Working Directive/Temporary Guide did not give employees a freestanding right to work from home – they are required to obtain approval from their employer to WFH and must still report to the main workplace when requested.

Similarly, whilst the DIFC Directive did not grant DIFC employees the right to insist on WFH, it did grant DIFC employers a similar power to impose WFH for the duration of the Emergency Period (21 April 2020 to 31 July 2020), including means of measuring engagement and productivity. It also imposed obligations on employers to ensure that adequate cybersecurity measures were in place for WFH, and to notify employees that IT systems and equipment may be monitored whilst WFH (or otherwise document and demonstrate that such monitoring outweighed the employee's privacy considerations). As the DIFC Directive is no longer in force, DIFC employers should review any WFH measures that have been imposed during the Emergency Period and consider whether additional steps (for example, obtaining employee consent) are now required to ensure the effective and lawful continuance of those measures. In relation to monitoring, regard should also be had to the new DIFC Data Protection Law (Law No. 5/2020), which came into force on 1 July 2020 (the “Data Protection Law”).

What if my employees refuse to work in the office?

At the height of the pandemic, restrictions were imposed on the percentage of the workforce that could physically attend the workplace. Those restrictions have been lifted in the UAE and the majority of businesses can now operate at full capacity. But what happens if an employee refuses to return to the workplace?

Broadly, in both jurisdictions (DIFC and onshore UAE), employees are required to attend work if requested to do so by their employer, unless they have a lawful reason for not attending. An unreasonable refusal to return to work could be grounds for disciplinary action and, potentially, dismissal. For example: DIFC employees have a statutory duty to comply with their employer's reasonable and lawful instructions (DIFC Employment Law, Article 58(c)), which could include an instruction to return to the workplace; onshore employees risk summary dismissal if they are absent from work without valid reason for more than 20 non-consecutive days or 7 consecutive days (Article 120(j)).

Accordingly, the issue is essentially two-fold: (1) has the employer given a reasonable and lawful instruction to return to work; and (2) has the employee unreasonably/unlawfully refused to do so? This analysis is inevitably subjective and there is no one-size-fits-all approach.

In assessing whether the employer's instruction to return is reasonable, a key consideration will be the extent to which the employer has complied with its general obligations to ensure employees’ health and safety at work and all government-issued guidance/requirements in order to operate a suitable and safe workplace (such as providing masks, implementing temperature checks, physical distancing, and regular sanitisation). In addition, a prudent employer will have ensured that it has communicated to its employees the health and safety measures that have been implemented and given them reasonable notice of the date by which they are expected to have returned to work (note that neither the UAE government nor the DIFC set a formal deadline by which employees must return to work).

If all the required steps have been taken, but an employee still refuses to return to working in the office, we recommend that the employer should carefully consider the specific reason for the refusal, the employee's personal circumstances, and whether it is possible to make any adjustments to accommodate/alleviate the employee's concerns. For example, if an employee is in a vulnerable category (e.g. older employees, pregnant employees, and employees who have underlying medical conditions), it may be appropriate to extend their WFH arrangements if they cannot be kept sufficiently distant from their colleagues in the office. Similarly, employees with childcare responsibilities may, until schools resume normal service, require some additional flexibility to WFH or work altered hours.

Having carefully complied with any health and safety obligations and precautions, and taken any reasonable and proportionate steps to accommodate/alleviate employee concerns, an instruction to return to the workplace is likely to be a reasonable one and any action taken by the employer in response to a continued refusal (such as disciplinary sanctions, including dismissal) should (absent any other reason making the action unlawful, for example, discrimination) be justified.

What if the employee’s home environment isn’t suitable to work in?

Under DIFC Directive, employers’ obligations to provide a safe system of work (in accordance with Articles 43 to 54 of the DIFC Employment Law) were suspended during the Emergency Period. However, now that the Directive has expired, it is arguable that these obligations could extend to providing a safe WFH environment – particularly where an employer insists on an employee WFH, or where it is necessary due to personal circumstances (e.g. if they are vulnerable). The extent of this duty is not clear, nor does it seem to have been tested, in the context of WFH. However, prudent employers wanting to ensure business continuity (and the security of their data) are likely to want to carry out some form of WFH risk assessment and provide some basic equipment to enable the employee to perform their duties remotely. In contrast, the Remote Working Directive clearly requires employers to provide the necessary tools for remote working.

If an employee insists on WFH and their working environment isn’t suitable, it may be reasonable for an employer to refuse their request; however this is likely to depend on the extent to which employers can assist/have assisted with providing a suitable environment (e.g. by the provision of equipment/tools) and the reasons for the employee’s refusal to come into the office. If the refusal continues, employers may want to consider alternatives i.e. paid/unpaid leave and potentially redundancies (also see the section above regarding refusal to return to work).

How can I protect confidential information when my employees WFH?

The protection of confidential information and data is inherently more difficult when employees are WFH, given that the employer has little to no control over how the information is used or stored in an employee’s home, and has no right of access (a physical search an employees’ home for this purpose is unlikely to be justified).

Employers should also implement (and enforce) clear policies and monitoring mechanisms to ensure employees are using and storing confidential information appropriately and in accordance with relevant legal obligations. For example, DIFC employers are required under the Data Protection Law to implement appropriate measures to ensure the security of personal data and protect it against loss and destruction. The Remote Working Directive/Temporary Guide similarly requires onshore employers to ensure the provision of a safe technological environment and monitor workers remotely; and requires employees to maintain the confidentiality of information and documents which can be flagged to employees (the DIFC Directive similarly imposed certain cybersecurity obligations on employers when it was in force).

Data protection, data monitoring, IT and working from home policies should be reviewed, updated and communicated to employees; and state clearly that any breaches could result in disciplinary action.  Employers should also consider reviewing confidentiality and post-termination obligations contained in employment contracts to ensure they provide sufficient protection should a breach occur.

In practical terms, consideration should be given to some of the following protective measures:

  • restricting access to confidential information (for example, by the use of password or ethical walls) to only those employees who genuinely require access in order to perform their duties;
  • using only employer-approved devices and prohibiting the use for work of, or downloading or saving of employer confidential information to, personal devices (particular any personal devices which might automatically backup to cloud-based storage sites that are outside the employer's control);
  • requiring employees to use secure wi-fi networks and only employer-approved video-conferencing facilities; and
  • installing remote-deletion software on employer-provided devices in case of loss or compromise.

How can I manage employee performance when they WFH?

Employees working from home are subject to the same expectations as if they were working in the office and performance concerns should be dealt with in the same way. Policies should be updated to clarify suitable and acceptable behaviour when working from home to reflect new working practices, and to provide for flexibility in carrying out meetings and interviews through remote conferencing facilities.

When it was in force, the DIFC Directive enabled employers to impose means of measuring the productivity of employees WFH. In addition, for onshore UAE employers, the Remote Working Directive/Temporary Guide sets out obligations on employees which could assist employers with managing and monitoring their performance when they are WFH, including obligations to perform duties within specified timeframes, to make themselves available over the phone/by email, and to provide evidence on achievements and productivity. It would be good practice for both DIFC and onshore employers to communicate expectations of this nature to employees and update any relevant policies accordingly.

Employers should consider the extent to which any performance concerns could be due to poor WFH conditions or pressures otherwise caused by the pandemic e.g. inadequate IT systems and equipment, family distractions, sickness and stress – and whether support can be offered before any action is taken.

Do I need to introduce a WFH policy?

Given that WFH looks like it’s here to stay, employers should certainly consider implementing a work from home policy to bring together the above law, guidance and best practice around WFH to ensure that expectations are clear. The policy should include rules for dealing with using/storing confidential information and data, regulating the use of personal devices for work purposes, and data/communication monitoring; as well as expectations around the degree of flexibility and notice required to WFH, and rules related to performance management, working hours and reporting requirements.

It is likely that implementation of a fair and flexible policy to facilitate WFH will be even more critical in the future to ensure that talent is retained, but also to ensure that businesses can adapt with ease if WFH is to be mandated by any further government restrictions.

Singapore

This article reflects the state of Singapore law and guidelines as of the date of this article. Due to the rapidly evolving COVID-19 situation, there may be changes from this present position. On 1 June 2020, the Ministry of Manpower ("MOM") issued an updated advisory on "Requirements for safe management measures at the workplace" ("Advisory").1 This was first issued on 9 May 2020 by the Tripartite Partners, which are MOM, the National Trades Union Congress ("NTUC") and the Singapore National Employers Federation ("SNEF").2 The requirements for safe management measures issued in the Advisory are meant for general workplace settings as at the time of writing.3 Specific workplaces (e.g. construction, worksites, retail and maritime) would have to fulfil additional sector-specific requirements set up by the relevant agencies.4

Do employees have a right to work from home?

Yes. Based on the Advisory, employers should actively enable employees to work from home. Working from home must be the default mode of working.5 Employees who have been working from home thus far must continue to do so and should go to the office only where there is no alternative.6

Physical meetings must be minimised (e.g. by using tele-conferencing facilities) and all events or activities that involve close and prolonged contact amongst participants (e.g. conferences, seminars and exhibitions) must be cancelled or deferred.7

What if my employees refuse to work in the office?

Companies should pay particular attention to vulnerable employees (e.g. older employees, pregnant employees, and employees who have underlying medical conditions) to enable them to work from home, including temporary redeployment to other roles within the company.8

Notably, agencies including MOM and Enterprise Singapore are empowered by the COVID-19 (Temporary Measures) Act 2020 to step up enforcement and take action against errant employers, including issuing stop-work orders and financial penalties.9  

What if the employee’s home environment isn’t suitable to work in?

According to the Advisory, employers should review work processes for employees who are unable to work from home and provide the necessary information technology ("IT") equipment to employees.10 Employers should also adopt solutions that enable remote working and online collaboration by leveraging on technology to ensure business continuity and safe management. Annex A11 of the Advisory provides a list of resources such as technology solutions and grants available to assist companies.

If employees are genuinely unable to work from home, they can be allowed to continue working in the workplace, subject to the implementation of all other safe management measures such as staggered work hours, avoiding peak hour travel, implementing split team arrangements, minimising socialising, ensuring everyone wears face masks at the workplace, appointing safety management officers to oversee safety measures and ensuring that everyone observes good personal hygiene.12 If an employee is unable to work from home, employers should be prepared to substantiate why.13

How can I protect confidential information when my employees WFH?

Remote working inherently carries a higher risk of compromised data protection and security. Some risks to confidential information include the use of third-party technologies and use of personal devices, rendering confidential information more susceptible to cybersecurity threats such as malware and viruses. Another amplified business-as-usual risk is the enhanced exposure of confidential information to unauthorised personnel such as the employee's family members or those living in the same household.

Some suggested measures for businesses to consider include:

  • updating data protection policies;
  • conducting relevant training and informing of employees of such enhanced risks; and
  • providing IT support and enhancing IT protections.

Businesses may also want to consider enhanced email-specific controls in the short-term to minimise the risk of email cybersecurity, strengthening of password policies, developing a response system, and implementing automated email warning reminders in respect of emails received from external sources.

How can I manage employee performance when they WFH?

The MOM guide entitled "Work @ Home" that was released even before the pandemic is instructive.14 Among others, the guide suggested for employers to:

  • Set key performance indicators ("KPIs"): Appropriate and realistic KPIs should be set. Importantly, these KPIs should be specific, measurable, actionable, realistic and time-specific.
  • Give positive reinforcement: Owing to less face-to-face interaction, supervisors should prioritise feedback on tasks and projects. They could also motivate through reward rather than penalty or fear.
  • Establish clear expectations: Reduce miscommunication and misunderstandings by demarcating job scopes and responsibilities. This can include drawing up a written agreement on working conditions (e.g. working hours, KPIs), which should be read and signed by both employer and employee.
  • Manage the time difference: This is applicable to those who have offices and operations in other countries or in different time zones.

Businesses are also advised to promote a culture of open communication and accountability between leaders and employees. Leaders should have regular one-on-one sessions with employees to check on their progress, discuss issues and receive feedback. Information communication technology should also be used to maintain contact (e.g. web-chats and instant messaging).

Do I need to introduce a WFH policy?

Currently, there is no legal obligation to introduce a WFH policy.

The Singapore section of the article was written by Virtus Law LLP (a member of the Stephenson Harwood (Singapore) Alliance).





1 See further "MOM FAQs on Safe Management measures at the workplace during Circuit Breaker" at [1]: <https://www.mom.gov.sg/covid-19/requirements-for-safe-management-measures> ("Advisory").

2 Advisory at [2].

3 Advisory at [2].

4 See further: < https://covid.gobusiness.gov.sg/safemanagement/sector/>.

5 Advisory at [5].

6 Advisory at [5(a)].

7 Advisory at [5(c)].

8 Advisory at [5(e)].

9 Advisory at [3].

10 Advisory at [5(b)].

11 See further: < https://www.mom.gov.sg/-/media/mom/documents/covid-19/annex-a-resources-to-assist-companies.pdf>.

12 Advisory at [6].

13 See further: < https://covid.gobusiness.gov.sg/faq/resumption/wfh/>.

14 See further: <https://www.mom.gov.sg/~/media/mom/documents/employment-practices/employers-guide-on-implementing-homebased-work.pdf>.

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