Ethics Code & Compliance Policy

Prime Marinus Trading Pte. Ltd. (the “Company”) has adopted this Code of Ethics and Business Conduct and Compliance Policy (the “Code”) to set out the Company's standards and practices relating to the business conduct and ethics of its employees, including all directors and officers.

The Company values all stakeholders, including employees, customers, suppliers, partners, shareholders, regulators and the general public, and is committed to engaging with them in a transparent, fair and constructive manner. Joint venture partners, suppliers, agents, advisers, consultants and other related entities are encouraged to conduct themselves consistently with the spirit of the Code when working with the Company.

The Code supplements, and does not replace, other Company policies. It cannot address every situation employees may encounter. Employees must exercise personal responsibility, sound judgment and high standards of personal ethics, and should seek guidance from their supervisor or manager when in doubt.

Employees must act honestly and with integrity, comply with relevant legal requirements, protect confidential information, avoid questionable business relationships and disclose situations that may create a conflict of interest or cause detriment to the Company.

The Company's Chief Compliance Officer is responsible for monitoring compliance with the Code and providing guidance to employees faced with a business conduct or ethical dilemma.

The Chief Compliance Officer is also the appropriate person to whom a violation of the Code should be reported.

The Code is underpinned by compliance with the laws and regulations applicable to the Company's business. Employees should have a general understanding of relevant local and international requirements where the Company conducts business and, where standards differ, apply the higher standard.

Employees must take active steps to avoid activities that may involve them or the Company in an unlawful practice. Where legal uncertainty remains, employees should seek guidance from their supervisor, manager or the Chief Compliance Officer, who will determine whether independent legal advice should be obtained.

Employees must conduct Company business on an arm's-length basis. A conflict of interest may arise when personal, social, financial or political activities affect, influence, or appear to affect or influence, an employee's ability to make an objective business decision for the Company. Any such conflict must be disclosed to the Chief Compliance Officer as soon as the employee becomes aware of it.

Examples of potential conflicts include:

• holding an ownership interest in an entity that does business with, or competes with, the Company;
• acting for another entity in a transaction involving the Company;
• offering or accepting payments, services, gifts or gratuities to influence a business decision;
• using information obtained through Company business for personal benefit or to the Company's detriment; or
• redirecting a business opportunity in which the Company may be interested for an employee's benefit.

The Company requires honest and accurate recording and reporting of information to support responsible business decisions and meet its financial reporting obligations to governmental authorities.

• Financial books, records and accounts must accurately reflect transactions and events.
• No false or artificial entries may be made.
• Company funds or assets must not be undisclosed or unrecorded, except where permitted by applicable law or regulation.
• Payments must not be made or approved without sufficient supporting documentation identifying the relevant goods or services.
• Invoiced sums must not be amended at a customer's request unless the adjustment is approved by the Company.
• Payments should not be made in cash or by cash cheque, except for petty cash.
• Company funds, assets and liabilities must be recorded in accordance with appropriate procedures and applicable law.

Confidential information may include:

• trade secrets, drawings, specifications and calculations;
• business plans, strategies, designs and programmes;
• financial, cost, pricing, sales and marketing information;
• technology, operations, research and technical documentation;
• employee files and compensation or personal information;
• customer requirements and contractual terms; and
• supplier information, including approved vendor lists.

Employees must preserve the confidentiality of information entrusted to them by the Company, its customers or collaborators, including after their employment ends. Employees must protect Company intellectual property and respect intellectual property and confidential information belonging to others.

A waiver of the Code may be granted only by the Chief Compliance Officer in pursuit of a legal purpose or requirement, or at the request of a governmental or regulatory authority.

Compliance with the Code is a condition of employment. Failure to comply may be grounds for dismissal, and unlawful activities will be reported to the relevant authorities.

A suspected violation should be reported to the Chief Compliance Officer, who will conduct an investigation. No employee should assist or enable a violation, or attempt to influence or discourage its reporting.