Third Party Ethics Code

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INTRODUCTION

Trust is the cornerstone of all business relationships at Singapore LNG Corporation Pte. Ltd. (“SLNG” or the “Company”). Our business is conducted with a clear commitment to integrity and transparency.

To achieve SLNG’s aim to act ethically and professionally at all times, we have put in place a Code of Ethics for our employees to follow. These expectations of integrity and business conduct extend also to third parties with whom we do business. This document known as the SLNG Third Party Ethics Code (“this Code”) explains these expectations and we would expect our third parties to require the same levels of integrity and business conduct from their personnel and anyone outside their organisation who they engage to provide goods or services to SLNG.

When used in this Code, “Third Parties” include our business partners, suppliers (including consultants, contractors and vendors) and other parties who provide goods and/or services to or do business with SLNG.

COMPLIANCE WITH THIS CODE AND APPLICABLE LAWS

Third Parties are expected to comply with this Code. To the extent any applicable law or regulation is more restrictive than this Code, such law or regulation shall govern. SLNG expects Third Parties to implement policies, procedures and training as deemed necessary by the Third Party to comply with this Code. If SLNG determines that a Third Party has breached this Code or identifies a potential situation which may give rise to a breach, we may require the Third Party to take appropriate measures and/or implement a remediation plan, or, in certain circumstances, we may suspend or terminate the relationship with the Third Party.

ETHICAL STANDARDS

1.  Conflict of Interest

Our Standards
SLNG is committed to identifying and addressing actual and potential conflicts of interest that may arise in the conduct of our business. We expect our personnel to act in SLNG’s best interests at all times, and to avoid any business activity and/or decision which conflicts (or appears to conflict) with the interests of SLNG.

How this applies to Third Parties
Third Parties are to avoid any conflicts of interest. The existence of a conflict depends upon the facts and circumstances, including the nature and relative importance of the interest involved.

If a Third Party becomes aware of an actual or potential conflict of interest or a sensitive situation that is related to and/or may impact its work for or with SLNG, it shall notify SLNG immediately. Depending on the circumstances, a Third Party may be required to put in place appropriate measures to manage the conflict of interest or sensitive situation.

2.  Combating Bribery and Corruption

Our Standards
SLNG adopts a zero-tolerance approach towards bribery and corruption of any form. Soliciting, accepting or agreeing to accept any form of bribes (or other improper payments) for a corrupt or improper purpose is strictly prohibited, whether directly or through any other entity / party or for any other entity / party.

Giving, promising, paying or offering any person any form of bribe (or other improper payment) for a corrupt or improper purpose is also strictly prohibited, whether directly or through any other entity / party or for any other entity / party.

For the avoidance of doubt, a “bribe” is not confined to any monetary rewards or payments and can be “anything of value” in order to secure, induce or reward an improper or unfair benefit or improper performance (or refraining from performance) of a function or activity. “Anything of value” includes cash or other kickbacks or gratification, such as a gift, commission, voucher, gift card, property, offer of employment, travel and entertainment, business opportunity, loan, release of obligation or other liability, or any other service, favour or advantage of any description whatsoever.

How this applies to Third Parties
Third Parties shall not engage in bribery and corruption (as elucidated in the “Our Standards” section) or any other activity (including improper payments) that creates the appearance of and/or may imply involvement in corruption or bribery when working for or with SLNG. For the avoidance of doubt, this includes dealings in relation to both private sector and public sector parties, bodies and individuals. However, additional specific care should be taken in working with public sector parties, bodies and individuals (e.g. public officials) which may be subject to increasingly stringent rules and scrutiny (including the operation of legal presumptions) governing relationships with customers, suppliers and vendors.

Facilitation payments (which refer to payments or gifts of small value to a public official in order to expedite or secure the performance of a particular routine governmental action by the public official) are prohibited.

SLNG personnel are unable to accept (directly or indirectly) any payment, gift, entertainment or hospitality which might (or might appear) to unduly influence a business decision in contravention of our internal policies.

If a Third Party becomes aware of any instances of bribery or corruption that is related to and/or may impact its work for or with SLNG, it shall notify SLNG immediately.

3.  Fraud and Other Misconduct

Our Standards
SLNG adopts a zero-tolerance approach towards fraud, dishonesty and any other forms of fraudulent behaviour.

How this applies to Third Parties
Third Parties shall not engage in any fraudulent or dishonest behaviour. Fraud is generally defined as acts involving deception, cheating, forgery, embezzlement, misappropriation, conspiracy, false representation, concealment of material facts and collusion. Examples of fraud and dishonesty include:

• Theft or misappropriation of SLNG’s funds, property or other assets;

• Impropriety in handling or reporting of financial transactions;

• Forgery or unauthorised alteration of documents or records (e.g. time sheets, invoices, agreements, etc.);

• Profiteering as a result of insider knowledge of activities or information whether in the area of procurement or otherwise;

• Misrepresentation of information on documents;

• Authorising, claiming or receiving payments for goods not received or services not performed;

• Authorising, claiming or receiving payment for hours not worked; and

• Any other dishonest or fraudulent act.

Third Parties shall also refrain from any unfair competition under applicable anti-trust and competition laws and regulations, whether alone or in combination with other entities or individuals.

If a Third Party becomes aware of any instances of fraudulent or dishonest behaviour that is related to and/or may impact its work for or with SLNG, it shall notify SLNG immediately.

SLNG will not hesitate to take necessary and appropriate action where any allegations of fraudulent, illegal and/or improper behaviour arise vis-à-vis a Third Party.

4.  Money Laundering and Terrorist Financing

Our Standards
SLNG does not tolerate economic crime, including money laundering and terrorist financing activities.

How this applies to Third Parties
Third Parties shall comply with all applicable anti-money laundering and countering the financing of terrorism laws and avoid doing anything that would place themselves in violation of such laws. This includes complying with mandatory reporting obligations.

Third Parties shall not provide any service or enter into any arrangement that facilitates, gives rise to or may constitute SLNG being involved (directly or indirectly) in economic crime, including money laundering or terrorist financing activities.

Third Parties shall not channel any funds directly or indirectly through SLNG as a consequence of, for the purposes of or to support, illegal activities (for example, terrorism, tax evasion or fraud).

If a Third Party becomes aware of any instances of money laundering or terrorist financing activities that is related to and/or may impact its work for or with SLNG, it shall notify SLNG immediately.

5.  Sanctions

Our Standards
SLNG is committed to adhering to applicable economic sanctions and export control laws and regulations to maintain trust and reputation in our business.

How this applies to Third Parties
Third Parties shall comply with all applicable economic sanctions and export control laws and regulations promulgated, administered and/or enforced by the United Nations, European Union, United Kingdom, United States of America, Singapore and any other applicable competent authority or government, and avoid doing anything that would place themselves in violation of such sanctions and controls.

If a Third Party becomes aware of any violations of economic sanctions and/or export control laws and regulations that is related to and/or may impact its work for or with SLNG, it shall notify SLNG immediately.

6.  Other Ethical Standards

Our Standards
SLNG is committed to the preservation of ethics and human rights.

SLNG reviews our relationships with business partners, suppliers and customers and will not hesitate to take necessary and appropriate action where any allegations of contravention of ethics and/or human rights arise.

How this applies to Third Parties
SLNG expects Third Parties to act with integrity and constantly strive to uphold the highest standards of ethical practice.

In particular, Third Parties shall not engage in, derive benefit from or otherwise support human trafficking or modern slavery in any way or form.

If a Third Party becomes aware of any violations of human trafficking or modern slavery laws that is related to and/or may impact its work for or with SLNG, it shall notify SLNG immediately.

7.  Confidentiality

Our Standards
SLNG respects the privacy and confidentiality of information relating or belonging to our customers, our business partners and others with whom we do business.

SLNG protects personal and other confidential information in accordance with laws and contractual requirements.

How this applies to Third Parties
Third Parties shall handle, use and disclose personal data and confidential information that they obtain in the course of their relationships with SLNG, only as authorised and directed by SLNG and in accordance with and as required by applicable laws and regulations and contractual requirements.

If a Third Party becomes aware of any violations of privacy or data protection laws or breaches of confidentiality that is related to and/or may impact its work for or with SLNG, it shall notify SLNG immediately.

8.  Health, Safety and the Environment

Our Standards
SLNG is committed to caring for the environment and to protect the safety and health of our personnel by providing a healthy and safe working environment.

How this applies to Third Parties
Third Parties shall provide a healthy and safe working environment in line with applicable laws and regulations, free of abusive, violent, threatening and other improper behaviour.

Third Parties shall minimise and respond to health and safety incidents and accidents occurring in the workplace and provide adequate personal protective equipment (as may be required).

Third Parties shall not tolerate harassment and other disrespectful conduct, including sexual harassment, discrimination and bullying.

9.  Reporting of Concerns

Our Standards
SLNG is committed to encouraging the reporting of any actual, potential and/or suspected violations of this Code or applicable laws and regulations, in line with its reporting matrix.

How this applies to Third Parties
Third Parties shall report in good faith any concerns it may have in connection with SLNG’s business and any actual, potential and/or suspected violations of this Code or applicable laws and regulations. Concerns may be raised to Compliance@slngcorp.com.

Concerns may be reported anonymously. SLNG will review and investigate reported concerns as appropriate.

SLNG’s whistleblowing channels are also available as follows:

• by email to “whistleblow@SLNGCorp.com”; or

• by hard copy addressed to Chairman of the Audit & Risk Committee, Singapore LNG Corporation Pte. Ltd., 991G Alexandra Road, #03-29C, Singapore 119975.

The Company also has a Whistleblowing Policy available at our website at https://www.slng.com.sg/whistleblowing-policy and will protect individuals who, in good faith, volunteer information of improper conduct against reprisal or discrimination.

If you have any questions regarding this Code, please contact us at Compliance@slngcorp.com.