Corporate Social Responsibility (CSR/ESG) 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) Vision, objectives, and scope

Operate sustainably to create long-term value for shareholders, customers, employees, communities, and the environment. Covers ESG (environment, social, governance), including human rights, labor, diversity, ethics, data/privacy. Applies to the company, employees, management, directors, key suppliers, and partners influencing Tanqory’s ESG. Complies with local/global laws (labor, environment, data protection) and practices (UNGC, OECD, ILO, GHG Protocol). Set targets to reduce environmental impact, comply with law, be transparent, and report required data on time. Link this policy to business strategy, products, and supply chain. Assign CSR/ESG ownership to relevant executives and report to the Board/Audit or Risk Committee as designated. Operate with equity, human rights respect, and zero tolerance for corruption. Review at least annually or when laws/standards change. Communicate via durable medium (email/intranet) and retain acknowledgments.

2) Environment and carbon management

Reduce energy use and GHG emissions per GHG Protocol (Scope 1-3 where applicable). Use energy-efficient data centers/infrastructure; prefer providers with renewable targets/environmental certifications. Minimize IT/equipment waste (e-waste) via life extension, reuse, and lawful disposal. Encourage low-carbon travel (virtual-first, public transport, flights only when needed; carbon offsets where appropriate). Reduce paper; use digital documents; set efficient printing practices. Support green offices (energy/water/material efficiency) and environmentally certified suppliers. Track relevant environmental KPIs (e.g., energy per employee, travel emissions) and report to management/Board. Comply with local environmental/waste/hazardous material laws and licensing. Train staff on relevant environmental practices. Update goals/measures regularly and communicate progress.

3) Human rights, labor, and safety

Respect human rights per UDHR, ILO Core Conventions, and local labor laws. Prohibit forced/child labor and inhumane practices in the supply chain. Ensure safe workplaces free from harassment, discrimination, and bullying; promote diversity and inclusion. Provide fair working conditions and compensation per law/industry standards. Offer safe, non-retaliatory complaint/whistleblowing channels with fair investigation SLAs. Train on human rights/labor, anti-harassment, and health/safety (EHS) as relevant. Provide health/safety measures and flexible work as appropriate by role. Assess human rights/labor risks in the supply chain with questionnaires/audits as risk-based. Require suppliers to follow human rights/labor standards and accept audit rights. Track and close remediation for labor/human rights issues.

4) Governance, ethics, and anti-corruption

Comply with anti-bribery/corruption laws (FCPA, UK Bribery Act, local) and the company ABC policy. Prohibit bribes or gifts intended to influence business decisions; follow gift/entertainment caps and disclosure rules. Prevent money laundering/terrorist financing; comply with AML/CFT and sanctions (UN/EU/OFAC/UK/SG/HK). Enforce Code of Business Conduct, Conflict of Interest Policy, and Supplier/Partner Code. Promote transparency in financial information/internal controls (ICFR) and accurate books/records. Maintain safe whistleblowing channels with intake/investigation SLAs and anti-retaliation. Management must model ethics (“tone from the top”) and support candid communication. Report material ethics/anti-corruption matters to the Board/Audit Committee. Train high-risk staff/partners on ABC/AML/sanctions periodically with testing. Review/update ethics/ABC policies as laws/risks change.

5) Responsible procurement and supply chain

Use transparent, competitive, auditable procurement. Include ESG requirements in RFPs/contracts (environment, human rights, labor, anti-corruption, data/privacy). Perform supplier due diligence by risk (personal data/infrastructure/financial/corruption/human rights). Set audit/assessment rights and remediation plans for deficiencies. Prohibit suppliers with severe human rights abuses, environmental harm, or under sanctions. Support local/small/sustainable suppliers when appropriate. Vet high-risk materials/equipment (e.g., conflict minerals/forced labor) and apply mitigations. Share ESG standards with suppliers and provide guidance/training as needed. Track key supplier KPIs (delivery, quality, ESG compliance) and review periodically. Suspend/terminate for material non-compliance not remedied on time.

6) Products, services, and customer privacy

Design/deliver with safety, privacy, and ethical data/AI use per company AI/Privacy/InfoSec policies. Provide accurate, transparent information on features, pricing, limits, and potential impacts to customers. Protect personal data under DPA/Privacy Policy and law; obtain consent where required and honor data subject rights. Apply appropriate security (encryption, MFA, least privilege, logging/monitoring) and incident response SLAs. Test quality/security/privacy regularly, including fair accessibility/UX. Avoid dark patterns or undue pressure on customers. Use efficient infrastructure to serve customers sustainably. Provide support and systematic complaint handling with SLAs. Track service/satisfaction/complaints KPIs and use insights to improve. Comply with consumer/advertising/competition laws in all markets.

7) Community engagement and social investment

Support CSR/volunteer projects aligned with strategy/expertise (e.g., tech education, cybersecurity, sustainability). Donations/sponsorships must be transparent, auditable, non-bribery, and approved at appropriate levels. Encourage voluntary employee volunteering; may support time/resources per policy. Partner with nonprofits/academia/government that are transparent and aligned with ESG principles. Track and evaluate CSR project impact (quantitative/qualitative) and report to management/Board. Comply with local donation/charity laws and required disclosures. Avoid activities that break laws/ethics or harm reputation. Communicate CSR to employees/stakeholders and invite participation. Use clear project selection criteria (objectives, impact, resources). Refresh CSR portfolio periodically to match context and community needs.

8) Disclosure and reporting

Report ESG/CSR data per legal/investor/customer requirements with accuracy, transparency, and auditability. Use appropriate frameworks (e.g., GRI/SASB/TCFD if applicable) when required or requested. Validate data quality before publication; avoid greenwashing or misleading claims. Coordinate with Finance/Legal/Risk on ESG data collection/validation. Disclose policy changes or material events per law/contract. Provide ESG/CSR inquiry channels via csr@tanqory.com or published contacts. Retain reporting records per Retention Policy and law. Board/Audit Committee may review ESG/CSR reports before release if material. State scope/methods for assessing CSR impacts to give context. Seek stakeholder feedback to improve future disclosures.

9) Updates and notices

Material changes to this policy will be posted at https://legal.tanqory.com with the effective date/version and, where appropriate, announced via email/intranet or dashboard before taking effect. The latest dated version controls; statutory obligations still apply.

Version History