Anti-Corruption Policy

1. Purpose
Global Investments Limited (“GIL” or the “Company”) is committed to conducting its business with integrity, transparency, and the highest ethical standards. This Anti-Corruption Policy (“Policy”) reiterates the Company’s commitment to full compliance with all applicable laws.

2. Scope and Applicability
This Policy applies to:
• Directors of the Company;
• Consultants, intermediaries, distributors, brokers and any third-party service provider engaged by the Company.
All parties are required to read, understand, and comply with this Policy.

3. Regulatory and Legal Framework
This Policy establishes clear and consistent standards to ensure compliance with:
• Penal Code 1871;
• Prevention of Corruption Act (“PCA”) 1960;
• Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (“CDSA”) 1992; and
• Relevant Singapore Exchange Securities Trading Limited (“SGX-ST”) Listing Rules

4. Corporate Governance
The Board of Directors (the “Board”) is ultimately responsible for the following:
• approving this Policy and any material amendments;
• providing oversight of this Policy and the Company’s Register of Gift and Entertainment; and
• ensuring appropriate systems of risk management and internal controls are put in place.

5. Definitions
5.1. Corruption
Corruption is receiving, asking for or giving any gratification as an inducement or reward to a person to do a favour with a corrupt intent. A gratification may include but not limited to the following:
(a) money or any gift, loan, fee, reward, commission, valuable security or other property or interest in property of any description, whether movable or immovable;
(b) any office, employment or contract;

(c) any payment, release, discharge or liquidation of any loan, obligation or other liability whatsoever, whether in whole or in part;
(d) any other service, favour or advantage of any description whatsoever, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary or penal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and
(e) any offer, undertaking or promise of any gratification within the meaning of paragraphs (a), (b), (c) and (d) above.

5.2. Bribery
Bribery is the act of corrupt offering, promising, giving, soliciting, or receiving of any “gratification” as an inducement or reward to influence a person in a position of power or trust for an action which is illegal, unethical or a breach of trust.

The PCA governs a range of bribery-related offenses and includes, inter alia, offenses relating to the bribing of public sector officials and private individuals. While bribery is not defined in the PCA, the term gratification, which covers both financial (such as money, gifts, rewards and valuable security) and non-financial (such as services and favours) benefits, is used instead when determining whether an offense of corruption from, inter alia, receiving bribes is found.

5.3. Third-Party
Any person or entity outside of the Company acting on behalf of or providing services to the Company.

6. Policy Statement
GIL adopts a zero-tolerance policy towards any forms of corruption and bribery.
1. No bribery or corruption in any form is permitted.
2. No facilitation payments are allowed, regardless of amount.
3. Gifts, entertainment, and hospitality must not influence or appear to influence business decisions.
4. Political donations on or behalf of the Company are prohibited.
5. Charitable donations must be approved through the established governance process and must not be linked to obtaining business advantage.
6. Books and records must be accurate, complete, and transparent.
7. Conflicts of interest must be declared immediately.

7. Gifts, Entertainment and Hospitality
7.1. General Rules
All directors and employees of the Company must:
• not give or accept gifts or entertainment that may influence decision-making;
• ensure any gifts/entertainment are reasonable, occasional, and transparent; and
• obtain approval in accordance with the internal policies of the Company.

7.2. Prohibited Items
• Cash or cash equivalent gifts;
• Lavish entertainment or excessive hospitality;
• Gifts given during a procurement or investment evaluation; or
• Any gift/entertainment with pending regulatory or licensing matters.

8. Engagement with Third-Party
Third parties may expose the Company to corruption risk. Before appointment, the Company must:
1. Conduct due diligence (i.e., fit-and-proper evaluation, sanctions screening, reputation checks etc.).
2. Enter into written contracts containing appropriate anti-corruption clauses/provisions where possible.
3. Monitor the conduct and performance of third parties.

The Company may terminate contractual engagements if the third-party violates this Policy.
When interacting with third parties, GIL personnel are expected to clearly communicate GIL’s zero-tolerance approach toward corruption. Third parties also have an obligation to ensure that their sub-contractors understand and comply with this Policy and applicable anti-corruption laws. Third parties with internal anti-corruption policies aligned with the PCA may follow their own guidelines.

GIL may be liable for the actions of third parties who offer or give something of value to benefit GIL’s business. This may include the payment of commissions or fees to intermediaries who are engaged in promoting GIL’s business. GIL personnel should remain alert for the following red flags when dealing with third parties and subcontractors:
a. A third party who has a reputation for offering or accepting bribes;
b. A third party who provides minimal detail on invoices or expense claims, or lump-sum requests (particularly for people who interact with the government);
c. A third party who requests for advanced or unreasonably large commissions or payments, or that payments be made through intermediaries, or via another country; and a third party who insists on using a specific consultant or one who provides little or no obvious added value.

If any individuals become aware of any of these red flags, the individual must seek the approval of the Board before proceeding with the transaction.

9. Record-Keeping and Internal Controls
The Company must maintain accurate and complete records of:
• Payments and expenses
• Gifts and entertainment
• Third-party engagements
• Approvals, due diligence, and declarations.

All financial transactions must be supported by valid documentation and subject to internal controls and audit review.

10. Reporting and Whistleblowing
Stakeholders who have any concerns of violations or potential violations of this Policy should report through GIL’s whistleblowing channel. Please refer to GIL’s Whistleblowing Policy for the reporting process.

11. Training and Communication
All directors of the Company are required to undergo regular anti-corruption training, with new directors receiving this training as part of their induction process.
Third-parties that maintain an internal anti-corruption policy aligned with the PCA may follow their organisation’s guidelines. Otherwise, they are required to adhere to our Company’s policy, which is available on our website.

12. Compliance Monitoring and Review
The Audit and Risk Management Committee will monitor compliance with this Policy. Internal audits may assess adherence to controls. The Policy will be reviewed regularly, and changes and improvements will be made where necessary.
Any breach of this Policy may result in disciplinary action, including termination, reporting to authorities, or legal action.