Anti-Harassment, Discrimination, and Equal Employment Opportunity Policy

0) Corporate structure and scope

Tanqory PTE. LTD. (Singapore, UEN 202448997H) is the ultimate parent and holding company of the Tanqory group, including its wholly-owned subsidiaries Tanqory Inc. (Delaware, USA) and Tanqory OÜ (Estonia). Tanqory Inc. is the contracting entity and merchant of record for every product and service Tanqory sells to merchants and customers worldwide — Tanqory PTE. LTD. itself does not contract with, bill, or hold a direct customer relationship with any merchant or customer. This document is adopted by Tanqory PTE. LTD. as the group's holding company and applies group-wide, including to Tanqory Inc.'s and Tanqory OÜ's operations, unless a section below states a narrower scope.

1) Purpose

TANQORY PTE. LTD. and its affiliated entities Tanqory OÜ and Tanqory Inc. (together, "Tanqory") are committed to providing a workplace that is free from unlawful discrimination, harassment, and retaliation, and to making employment decisions on the basis of merit, qualifications, and lawful business considerations.

This policy:

• Sets a single Tanqory-wide standard of conduct that applies across all three entities.
• Identifies the categories of conduct that are prohibited.
• Describes the channels for raising concerns, the procedures for investigating concerns, and the protections afforded to good-faith reporters.
• Identifies the principal legal authorities under which Tanqory operates and against which this policy is designed to be measured.

This policy is intended to meet, at minimum, the requirements of the legal authorities referenced in Section 4. Where local law in the personnel's place of work is stricter than this policy, local law prevails.

2) Scope

This policy applies to:

• Employees of TANQORY PTE. LTD., Tanqory OÜ, and Tanqory Inc., including full-time, part-time, fixed-term, and probationary employees.
• Officers and directors of each entity, in the course of acting for the entity.
• Contractors, consultants, agency workers, and interns engaged by any Tanqory entity.
• Job applicants, in respect of recruitment and hiring decisions.
• Conduct occurring in Tanqory offices, at Tanqory-sponsored events (including remote and virtual events), on Tanqory communications systems, on customer or vendor premises while performing Tanqory work, and on business travel.

References in this policy to "personnel" cover all of the above.

3) Equal employment opportunity commitment

Tanqory makes employment decisions — including recruitment, hiring, assignment, training, compensation, benefits, promotion, demotion, transfer, discipline, and termination — on the basis of qualifications, performance, and lawful business considerations.

Tanqory does not discriminate against any personnel or applicant on the basis of any characteristic protected by the laws of the jurisdiction in which the personnel work, and does not tolerate harassment or retaliation on such bases.

4) Legal authorities

This policy is designed against the following legal authorities, as applied to the jurisdiction in which the relevant personnel are based:

United States (Tanqory Inc.; personnel based in the United States):

• Title VII of the Civil Rights Act of 1964 (race, color, religion, sex including pregnancy, sexual orientation, gender identity, and national origin).
• Age Discrimination in Employment Act of 1967 (ADEA) (age 40+).
• Americans with Disabilities Act of 1990 (ADA), as amended by the ADAAA.
• Equal Pay Act of 1963.
• Genetic Information Nondiscrimination Act of 2008 (GINA).
• Pregnancy Discrimination Act; Pregnant Workers Fairness Act.
• Section 1981 of the Civil Rights Act of 1866.
• State and local equivalents, including (without limitation) the California Fair Employment and Housing Act (FEHA), the New York State Human Rights Law, the New York City Human Rights Law, and analogous statutes in any other state or city in which Tanqory has personnel.

Singapore (TANQORY PTE. LTD.; personnel based in Singapore):

• Tripartite Guidelines on Fair Employment Practices, issued by the Tripartite Alliance for Fair and Progressive Employment Practices (TAFEP).
• Workplace Fairness Act / Workplace Fairness Bill, as and when in force, including its protected characteristics and enforcement framework.
• Employment Act (Cap. 91) and the Protection from Harassment Act 2014.

Estonia and European Union (Tanqory OÜ; personnel based in the EU):

• Estonian Equal Treatment Act and Gender Equality Act.
• Council Directive 2000/43/EC (racial and ethnic origin), Council Directive 2000/78/EC (employment framework — religion or belief, disability, age, sexual orientation), Directive 2006/54/EC (equal opportunities and equal treatment of men and women), and Directive (EU) 2019/1158 (work-life balance).

United Kingdom (where Tanqory personnel are based in the UK):

• Equality Act 2010, covering age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

Other jurisdictions. Where Tanqory has personnel in jurisdictions not listed above, this policy is applied in conjunction with the local equal-employment, anti-discrimination, and anti-harassment laws of that jurisdiction.

5) Protected characteristics (jurisdiction summary)

The protected characteristics under this policy include, at minimum, the union of those recognized in the personnel's place of work. By jurisdiction:

• United States (federal floor): race; color; religion; sex (including pregnancy, sexual orientation, and gender identity); national origin; age (40+); disability; genetic information; citizenship status (under IRCA); uniformed service (under USERRA). Many state and local laws add categories such as marital status, familial status, source of income, off-duty conduct, reproductive-health decisions, height/weight, and others; these apply additively where personnel work.
• Singapore: under the Tripartite Guidelines and the Workplace Fairness Act / Workplace Fairness Bill framework, protected characteristics include age, nationality, sex, marital status, pregnancy, caregiving responsibilities, race, religion, language, disability, and mental health condition. This list is applied as the baseline and is adjusted to reflect whichever Workplace Fairness instrument is in force as of the effective date.
• Estonia / EU: sex (including pregnancy and parental status), gender identity, racial or ethnic origin, nationality, religion or belief, age, disability, sexual orientation, language, and social status.
• United Kingdom: the nine characteristics under the Equality Act 2010 listed in Section 4.

Where any characteristic is protected in any jurisdiction in which Tanqory has personnel, Tanqory treats that characteristic as protected as a matter of internal standard, regardless of whether legally required in another jurisdiction.

6) Prohibited conduct

The following conduct is prohibited:

6.1 Discrimination

Adverse treatment of personnel or applicants in any term or condition of employment — including recruitment, hiring, assignment, training, compensation, benefits, promotion, demotion, transfer, discipline, or termination — because of a protected characteristic, or because of a characteristic perceived (even if incorrectly) to be a protected characteristic, or because of association with a person having a protected characteristic.

6.2 Harassment

Unwelcome conduct based on a protected characteristic, where (a) submission to the conduct is made a term of employment, (b) submission to or rejection of the conduct is used as a basis for employment decisions ("quid pro quo"), or (c) the conduct is sufficiently severe or pervasive to alter the conditions of employment and create an intimidating, hostile, or abusive working environment ("hostile work environment").

This includes (without limitation):

• Sexual harassment, including unwelcome sexual advances, requests for sexual favors, and other verbal, visual, or physical conduct of a sexual nature.
• Slurs, epithets, derogatory comments, jokes, or imagery directed at a protected characteristic.
• Threats, intimidation, or physical aggression.
• Display or distribution of offensive material on Tanqory communications systems, including in chat, email, video, or social channels used for work.

Conduct may amount to harassment regardless of the medium (in-person, video conference, chat, email, social media used for work, or otherwise), and regardless of whether it occurs inside or outside of normal working hours, if it has a sufficient nexus to the workplace.

6.3 Retaliation

Adverse action against any personnel because they (a) raised a good-faith concern under this policy or any other Tanqory policy, (b) participated in an investigation, (c) requested a reasonable accommodation, (d) requested equal-pay information protected by law, or (e) exercised any legally protected right. Retaliation is prohibited regardless of whether the underlying concern is ultimately substantiated, provided it was raised in good faith.

7) Reasonable accommodation

Tanqory provides reasonable accommodations for:

• Disability, including mental-health conditions, where required by the ADA, the Estonian Equal Treatment Act, the UK Equality Act 2010, and analogous laws.
• Religious observance and practice, where required by Title VII, Council Directive 2000/78/EC, and analogous laws.
• Pregnancy, childbirth, lactation, and related medical conditions, where required by the Pregnant Workers Fairness Act, the Pregnancy Discrimination Act, the Estonian Gender Equality Act, the UK Equality Act 2010, and analogous laws.
• Caregiving and parental responsibilities, where required by Directive (EU) 2019/1158 and analogous laws.

Personnel requesting an accommodation should contact their manager or People Operations. Tanqory will engage in a timely, good-faith interactive process to identify an effective and reasonable accommodation, and will provide an accommodation unless doing so would impose an undue hardship.

8) Equal pay commitment

Tanqory is committed to equal pay for substantially similar work, irrespective of protected characteristics. The Company will conduct pay-equity reviews on a periodic basis, using an appropriate analytical methodology and engaging independent review where warranted.

Tanqory does not prohibit personnel from discussing their own wages or working conditions with each other to the extent such discussions are protected by applicable law (including the US National Labor Relations Act §7 for non-supervisory employees in the United States).

9) Reporting channels

Personnel who experience or witness conduct that may violate this policy are encouraged to report it promptly. Tanqory provides multiple channels so that personnel may choose the channel they are most comfortable with:

• Line manager.
• Skip-level manager, if the line manager is the subject of the concern or is otherwise conflicted.
• People Operations / HR.
• Legal and Compliance at legal@tanqory.com.
• Speak Up at speakup@tanqory.com (as set out in the Whistleblower Policy and the Code of Business Conduct), including for confidential and, where lawful, anonymous reports.
• Ethics hotline. The Company is establishing a confidential reporting channel, which may include an external third-party ethics hotline, and will publish the applicable contact details once that channel is operational.

Reports may also be made directly to applicable government agencies (for example, the US EEOC and state human-rights agencies, the Singapore TAFEP, the Estonian Gender Equality and Equal Treatment Commissioner, or the UK Equality and Human Rights Commission). Tanqory does not require personnel to report internally first as a condition of reporting externally.

10) Investigation procedure

When a concern is received, Tanqory will:

1. Acknowledge receipt in line with the SLAs set out in the Code of Business Conduct (intake reference within 1 business day; acknowledgement within 3 business days; initial assessment within 5 business days).
2. Assign a neutral investigator, with conflicts disclosed and managed.
3. Conduct interviews with the reporter, the subject of the concern, and any relevant witnesses, taking reasonable steps to preserve evidence.
4. Provide the subject of the concern with sufficient information about the allegations to enable a meaningful response, consistent with confidentiality obligations and applicable law.
5. Document findings on the balance of probabilities and recommend corrective action where the concern is substantiated.
6. Communicate the outcome to the reporter and to the subject of the concern to the extent permitted by law.

Investigations will target closure within 60 business days of intake, consistent with the Code of Business Conduct, recognizing that complex matters may take longer.

11) Confidentiality

Tanqory will treat reports, the identities of reporters and witnesses, and investigation records as confidential to the maximum extent consistent with conducting a thorough investigation, taking required corrective action, and complying with applicable law (including disclosure obligations to regulators, courts, or law enforcement).

Personnel involved in an investigation are expected to treat the matter as confidential; however, Tanqory does not prohibit personnel from disclosing information about their own experience of discrimination, harassment, or retaliation to the extent such disclosure is protected by applicable law.

12) No retaliation

Retaliation against any person for raising a concern in good faith, participating in an investigation, requesting an accommodation, or exercising any legally protected right is itself a violation of this policy and is subject to discipline up to and including termination of employment.

13) Corrective and disciplinary action

Where a concern is substantiated, Tanqory will take corrective action proportionate to the nature and severity of the conduct. Corrective action may include:

• Verbal or written warning.
• Mandatory training or coaching.
• Reassignment, removal of management responsibilities, or change in reporting line.
• Suspension with or without pay, where consistent with applicable law and any employment agreement.
• Termination of employment or engagement.
• Referral to law enforcement, where the conduct may constitute a criminal offense.

Corrective action will be applied without regard to the seniority of the person responsible for the conduct.

14) Mandatory training

All personnel must complete anti-harassment and EEO training. Tanqory's training is calibrated to the requirements of the personnel's place of work, including:

• California — supervisor and non-supervisor training under Government Code §12950.1 (originally enacted as AB 1825 and expanded by SB 1343).
• New York State — Sexual Harassment Prevention Training under N.Y. Labor Law §201-g.
• New York City — annual interactive training under the Stop Sexual Harassment in NYC Act.
• Connecticut — supervisor and employee training under the Connecticut Time's Up Act.
• Illinois, Maine, Delaware, Washington — training in accordance with state-specific requirements, where applicable.
• Singapore — TAFEP-aligned fair-employment training for managers.
• EU / Estonia — training reflecting EU equal-treatment directives.

The Company provides equal-employment and anti-harassment training on a periodic, risk-based basis, including initial and refresher training and jurisdiction-specific training where legally required (for example, California, New York, Connecticut, Illinois). The Company will set and track a completion-rate target, and the senior officer designated by management to oversee human resources is responsible for maintaining training records.

15) Recordkeeping

Tanqory maintains records of:

• Reports, investigations, findings, and corrective actions, under the Code of Business Conduct retention rules.
• Training completion, for the period required by applicable law (including the EEOC's general recordkeeping requirements and any longer state-law period).
• Pay-equity reviews and supporting data, under the same retention rules.

Records are retained, classified, and disposed of in line with Tanqory's Records Retention and Data Classification policies.

16) Posting and notice requirements

Tanqory will post or otherwise make available to personnel the notices required by applicable law, including:

• United States — the EEOC "Know Your Rights" poster, the FLSA / Equal Pay Act notices, and state and city posters required where Tanqory has personnel.
• California — California-specific harassment, pregnancy disability, family rights, and pay-transparency notices.
• Singapore — TAFEP and Ministry of Manpower notices.
• Estonia / EU — workplace-equality and works-council notices where applicable.
• United Kingdom — workplace notices where applicable.

For fully remote personnel, electronic posting (intranet or HR system) is used where permitted by applicable law. The senior officer designated by management to oversee human resources maintains and updates the set of required notices and the posting medium (physical or electronic) applicable in each jurisdiction.

17) Annual review

This policy is reviewed at least annually, and more frequently if applicable law changes materially. Material changes are communicated to personnel through a durable medium (email and intranet), and personnel may be required to re-acknowledge the policy.

18) Related policies

This policy should be read together with:

• Code of Business Conduct.
• Whistleblower Policy.
• Corporate Social Responsibility (CSR/ESG) Policy.
• Modern Slavery and Human Trafficking Statement.
• Employee Data Protection Policy / Privacy Policy (for the handling of personal data generated by reports and investigations).
• Acceptable Use Policy (for conduct on Tanqory communications systems).

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