Code of Business Conduct

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) Core principles and scope

Applies to employees, management, directors, temporary staff, consultants, and business partners acting for Tanqory. Uphold integrity, transparency, accountability, legal compliance, and relevant global standards (e.g., OECD, UNGC). Prohibit fraud, corruption, discrimination, harassment, and retaliation against whistleblowers. Read and follow related policies (Privacy/Security, AUP, Anti-Corruption, Insider Trading, HR). Violations may lead to discipline, termination, or legal action. Managers must model compliance, support “speak up,” and ensure fair resolution. Local law that is stricter prevails; when in doubt, consult Legal or speakup@tanqory.com before acting. No oral waivers. Updates are issued via durable medium (email/intranet). Mandatory training: e-learning with ≥80% score within 30 days of joining; annual recertification; key partners/suppliers with system/data access must accept this Code or an equivalent Supplier/Partner Code.

2) Integrity, transparency, and conflicts of interest

Avoid and disclose conflicts promptly (e.g., holdings/roles in competitors/customers/vendors; transactions with close relatives). Do not use your role for personal/related-party gain; recuse from conflicted decisions unless approved. Gifts/entertainment must be modest, reasonable, transparent (e.g., ≤USD 100 per instance with sensible spacing). Decline or seek approval and record if above threshold or during bids/negotiations. Prohibited gifts: cash/cash equivalents (vouchers/gift cards/crypto), luxury items, unjustified travel/lodging/banquets. No bribes, kickbacks, or anything intended to influence business decisions. Related-party transactions must follow approval/disclosure processes and be recorded. Company assets/resources are for business use; follow IT/security policies. Disclose outside work/consulting/board roles that affect time or impartiality. No trading on inside information or tipping. If unsure about a conflict, consult Legal/Compliance first. Breaches may trigger discipline and legal consequences.

3) Legal compliance, anti-corruption, and gifts/hospitality

Follow anti-bribery laws (FCPA, UK Bribery Act, relevant local laws) and sanctions/export rules. No bribing officials or anyone, including indirect/hidden benefits (lavish gifts, luxury travel/entertainment) to gain/retain business. Do not use intermediaries to channel bribes; conduct due diligence on agents/partners and use clear contracts. Gifts/hospitality must have legitimate business purpose, be modest, not during active tenders, and comply with counterpart policies; high-risk/over-threshold items need prior approval and logging. Record expenses transparently with supporting documents; no false books/records or off-books accounts. Comply with sanctions/export controls (UN/EU/OFAC/UK/SG/HK, etc.); avoid prohibited parties/regions. Charitable/sponsorship/donations must be transparent, non-bribery, and pre-approved. Follow fair procurement with competition and disclosure. Report suspected bribery/corruption immediately to speakup@tanqory.com or manager/Legal. Violations may lead to termination and criminal/civil penalties.

4) Data protection, privacy, and security

Comply with Privacy Policy, DPA, Data Classification/Retention, Security Policies, and data laws (GDPR/UK GDPR, PDPA SG, CCPA/CPRA, etc.). Collect/use/disclose personal data only as needed with a clear legal basis and consent where required; respect data subject rights. No accessing/using/sharing customer/employee/partner data without authorization or for personal purposes. Follow security measures: strong passwords/MFA, encryption, no account sharing, keep keys/tokens secure, no hardcoded secrets. Report incidents (breach, credential leak, malware, phishing) immediately to security@tanqory.com per IR SLAs. Avoid insecure channels; do not send sensitive data via personal email/social apps. Use company data/systems only for authorized business; no unauthorized data mining/model training. Follow cross-border transfer rules (SCC/IDTA/BCR/other) and conduct TIAs where needed. Follow Media/Comms Policy before sharing company info externally. Complete required privacy/security training and pass quizzes on schedule.

5) Equality, non-discrimination, and workplace conduct

Treat everyone with respect; no discrimination based on protected characteristics (race, color, religion, sex, sexual orientation, age, disability, etc.). No harassment, bullying, or creating unsafe/hostile environments. Promote diversity and inclusion in hiring, promotion, and development. Provide safe, non-retaliatory channels to report harassment/discrimination; investigate fairly. Maintain safe workplaces per EHS laws and support flexible work per policy. Provide regular training on D&I/anti-harassment/ethics. Manage performance/discipline fairly; no retaliation against good-faith reporters. Support employee well-being/mental health per company programs. Control site/system access to protect people and data. Assess and mitigate risks for fieldwork/travel; provide safety guidance.

6) Confidentiality, inside information, and trading

Non-public information about the company/customers/partners/employees is confidential and must be protected. No trading in company/partner securities using inside information or tipping others. Follow blackout/closed periods and pre-clearance rules. Communicate with investors/media/public only through authorized channels; do not disclose material non-public info without approval. Use company IT tools/channels for business communications; avoid personal email/chat for sensitive info. Retain/destroy documents per Retention Policy. Label confidential/internal info correctly and share only on need-to-know. Avoid discussing sensitive info in public/unsecure places. Violations may lead to discipline and securities law penalties. If unsure whether information is inside/confidential, consult Legal/Compliance before disclosure.

7) Accurate financial records and accounting

Record all financial transactions accurately, completely, timely, and per applicable accounting standards. No off-book accounts, false entries, or concealment; keep supporting documents. Follow ICFR/internal controls and cooperate with internal/external auditors. Report financial/control issues promptly via designated channels or to the Audit Committee. Expenses/claims must be supported and within policy; no duplicate/personal claims. Approvals must follow the authority matrix and budgets. Comply with tax laws and filings on time. Do not manipulate numbers to inflate bonuses/metrics. Provide accurate information in regulatory/financial/investor reports. Retain records per Retention Policy and law.

8) Fair competition and antitrust

Comply with competition/antitrust laws (EU, US, SG, etc.). No price-fixing, market/customer allocation, or bid-rigging with competitors. Avoid sharing competitive information (pricing, costs, product plans, customers) with competitors. Be cautious at industry forums; do not discuss topics that could breach competition laws. Marketing/promotions must be truthful and not misleading. Vendor/partner selection should be transparent, fair, and competitive where possible. Avoid false/comparative claims that defame competitors. Consult Legal before mergers/deals impacting competition and file notifications where required. Train sales/marketing/procurement teams on competition law and prohibited examples. Report antitrust concerns immediately.

9) Sustainability and social responsibility

Operate sustainably, reduce environmental impact, and comply with applicable laws. Promote efficient energy use, waste reduction, and responsible resource management. Respect human rights and labor; no forced/child labor; follow international labor standards. Oversee supply chains for ethical, environmental, and human rights compliance. Support community through CSR/volunteer projects aligned with the business. Disclose relevant ESG metrics transparently when required by law/investors, including Modern Slavery/Forced Labor statements where applicable (e.g., UK/AU/CA or public sector sales). Consider ESG risks/opportunities in strategic decisions/investments. Cooperate with regulators/investors on sustainability requests as allowed by law. Train staff on role-relevant ESG measures. Continuously improve sustainability practices per evolving standards/laws.

10) Reporting concerns and whistleblower protection

Report to: line manager, Legal/Compliance, or speakup@tanqory.com; for security matters use security@tanqory.com. Intake ref within 1 business day; acknowledge within 3 business days; initial assessment within 5 business days. Investigations start within 7 business days of assessment; updates every 14 business days; target closure within 60 business days. Summary reported to Board/Audit Committee at next meeting or within 30 days of closure. Non-retaliation: no punishment/bullying of good-faith reporters or participants. Anonymous/external channels (if available) will be listed on intranet/notices; protect whistleblower data per law. Maintain confidentiality of reporters and related data. Disclose investigator conflicts and assign neutral investigators. Anonymous reports allowed where permitted. Deliberately false reports may face discipline. Keep complaint/investigation records per Retention Policy and law.

Supplementing instruments

• This Code is supplemented by the Code of Ethics for Senior Financial Officers (governance/code-of-ethics-senior-officers.md), which applies to the Chief Executive Officer, Chief Financial Officer, Principal Accounting Officer, and Controller.
• This Code is supplemented by the FCPA and Anti-Corruption Compliance Policy (governance/anti-corruption-policy.md), the Anti-Money Laundering and Sanctions Compliance Policy (governance/aml-sanctions-policy.md), the Insider Trading Policy (governance/insider-trading-policy.md), and the Whistleblower Policy (governance/whistleblower-policy.md).

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