EMPLOYEE

CODE OF
CONDUCT
Transmarine Logistics
Asia PTE Ltd. (TML)

Current Revision: ver 4

Page 1 of 4 SOP No: MHL/OP/SOP/15/010 Authorized By:

Employee Code of Conduct

1 Objective

At Transmarine Logistics Asia PTE Ltd (TML), we believe in good business results as well as how they
were conducted.

Here lies a full list of conducts that our employees need to follow for the best possible outcomes and
long term sustenance of our company.

2 Scope

This particular policy covers all sorts employee codes of conduct and activities related to employee
behavior of this company.

This Policy applies to all employees in Transmarine Logistics Asia PTE Ltd (TML), directly or indirectly
connected.

This Policies are globally standardized. In some countries, more stringent applicable laws and regulations
supersede the principles set out in this Policy.

3 Principles

This code of conduct applies to all employees of Transmarine Logistics Asia PTE Ltd (TML).

 It provides a framework of principles for conducting business and dealing with

customers, colleagues and other stakeholders which are to:

 Act with integrity and professionalism and be scrupulous in proper use of Company
information, funds, equipment and facilities;

 Exercise fairness, equity, proper courtesy, consideration and sensitivity in dealing with
customers, employees and other stakeholders; and

 Avoid real or apparent conflict of interests.

4 Responsibilities

Employees are required to

 Promote the interests of the Company.

 Perform their duties with skill, honesty, care and diligence, using authority in a fair and
equitable manner;
 Abide by policies and procedures, instructions and lawful directions that relate to their
employment and duties; and comply with the spirit as well as the letter of the codes of
conduct applying to the professions of individual employees.

5 Conflict of Interest

 Employees must avoid any personal, financial or other interest which may be in conflict with
their duties and responsibilities to the Company.

Page 2 of 4 SOP No: MHL/OP/SOP/15/010 Authorized By:

  Any interest which may constitute a conflict of interest must be promptly disclosed to
the appropriate Head of the Department.

 Accepting any external appointment, working for another organization, or conducting a

business, is not permitted

6 3rd Party Arrangements (Contractors/Consultants/Suppliers/Vendors)

When going into any 3rd party agreement employees must ensure:

 Assigned work to be done in full compliance with all applicable laws, regulations, and in
accordance with the highest standards of ethical business conduct, and is done by trained
individuals with the skills, expertise, and certifications necessary to complete the job in a safe
and compliant manner.

 Confidentiality of information entrusted to be maintained, except when disclosure is

properly authorized or legally mandated.

 Customers of the Company to have a positive experience when working with the suppliers,
including professional attire and conducting oneself in a professional manner.

 Suppliers’ employees, subcontractors, sub-suppliers and sub-vendors must also adhere to the
abovementioned policies.

7 Confidentiality

 Employees must not use or disclose information obtained through their employment other than in
the proper course of their duties.

 Information obtained in the course of employment must not be used to obtain financial reward
or other benefit, or to take advantage of another person.

8 Company Property

 Company property, funds, facilities and services must be used only for authorized purposes.

 Unless governed by law or otherwise agreed in writing, any intellectual property developed by
an employee during or as a result of his or her employment by the Company is the sole property
of the Company.

9 Public Statements

The Company’s relationships with the media and the investment community are conducted
exclusively by the Managing Director or as delegated by the Managing Director.

10 Gifts and Entertainment

 Under no circumstances must employees offer or accept gifts or money.

 Gifts or money should never be offered or accepted in circumstances where the outcome of a
transaction may be influenced by the gift, or give rise to the perception that the transaction may
be influenced by the gift.

 Employees involved in a tendering process must refrain from actions which may give rise to an
expectation of some favored treatment from or by any tendering party.

Page 3 of 4 SOP No: MHL/OP/SOP/15/010 Authorized By:

  Invitations where travel and accommodation is involved must be authorized by Head of the
Department, or in the case of Head of the Department, by the Managing Director.

11 Compliance

 Employees must be aware of, and adhere to, company policies, especially those relating to
health and safety, equal opportunity, privacy, trade practices and continuous disclosure.

 In the course of their duties, employees must comply with relevant legislation.

12 Anti-Trust

 It is the obligation of every employee to comply with the letter and the spirit of the Anti-Trust
laws.

 No employee of Company or person outside of the Company is authorized to direct any

Employee violate the antitrust laws.

 All employees should be familiar with the Anti-Trust and Trade Regulation Guidelines.

Page 4 of 4 SOP No: MHL/OP/SOP/15/010 Authorized By: