1 INTRODUCTION 

1.1 It is the general policy of Yangzijiang Maritime Development Ltd. (“YZJMD”) to fully comply  with anti-money laundering (“AML”) and counter-financing of terrorism (“CFT”) laws and  regulations (together, the “AML/CFT Laws”). This policy (“Policy”) sets out the guidelines and  requirements of YZJMD relating to compliance with AML/CFT Laws. 

1.2 Singapore is a member of the Financial Action Task Force (“FATF”) and is obligated to implement  FATF’s recommendations regarding measures to combat money laundering, terrorist financing and other related threats to the integrity and security of the international financial systems  (“FATF Recommendations”). To the extent applicable to YZJMD, this Policy takes into account  the FATF Recommendations relating to the financial sector and designated non-financial  businesses and professions. 

1.3 YZJMD depends upon the conduct and diligence of its directors, officers and employees to ensure  full compliance with this Policy. All directors, officers and employees are therefore required to  act in a manner consistent with this Policy.

2 DEFINITION 

Money Laundering 

2.1 Money laundering is the process by which the illegal origin of wealth is disguised to avoid suspicion of law enforcement authorities and to wipe the trail of incriminating evidence.  Criminals are interested in concealing the destination and the purpose for which the money is  collected. It is an offense to use funds (even for otherwise legitimate purposes) which are derived  from criminal or illegitimate means. 

2.2 The objective of AML laws is traditionally to eliminate the movement of illegally obtained funds.

Terrorism Financing 

2.3 Acts of terrorism seek to coerce governments into a particular course of action and/or to  intimidate the public. Terrorists require funds to carry out acts of terrorism and terrorism  financing is the provision of such funds. These funds may be derived from criminal activities such  as robbery, drug-trafficking, kidnapping, extortion, fraud or hacking of online accounts. In such  cases, there may be an element of money laundering to disguise the source of funds. 

2.4 Terrorist acts and organisations may also be financed from legitimate sources such as donations  from charities, legitimate business operations, individual self-funding. In these cases, which often  does not require the involvement of large sums of money, terrorism financing can be hard to  detect. 

3 Laws and Regulations

CDSA and TSOFA 

3.1 Singapore has put in place strong laws and regulations to punish crimes and protect its financial  system. Generally, the laws are focused on detection, prevention and reporting of suspicious  transactions to deter money laundering. 

3.2 Singapore’s primary legislation to combat money laundering is the Corruption, Drug Trafficking  and Other Serious Crimes (Confiscation of Benefits) Act 1992 (“CDSA”). The primary Singapore  legislation to combat terrorism financing is Terrorism (Suppression of Financing) Act 2002  (“TSOFA”). In addition, there are regulations that are relevant to the conduct of YZJMD. 

4 APPROACH 

4.1 Aligning with the FATF recommendations, YZJMD adopts a risk-based approach in complying  with AML/CFT Laws and determines the appropriate type and extent of mitigation to be applied  after considering relevant risk factors, such as the following: 

a) nature of business or operations conducted by YZJMD (the “Business”), including products,  services, transactions and delivery channels; 
b) country or jurisdiction where the Business is conducted; and 
c) country or jurisdiction of the Counterparty with which the Business is conducted. 

4.2 YZJMD screens customers and associated parties against lists issued by MAS and international  bodies [i.e., U.S. Department of Treasury Office of Foreign Asset Control (“OFAC”), EU Sanction,  UN Sanction, and UK Asset Freezing Unit of the Treasury]. Therefore, YZJMD ensures that  customer profiles are monitored regularly.

5 OBLIGATIONS 

5.1 The main obligations under this Policy are: 

a) Counterparty Due Diligence; 
b) Suspicious Transaction Reporting; 
c) Record Keeping; and 
d) Training 

5.2 Apart from the above main obligations, an entity within YZJMD that has obtained a Capital  Markets Services Licence to conduct a regulated activity has additional obligations under notices  and guidelines issued by the MAS or equivalent regulatory requirements in the relevant local  jurisdiction(s), as the case may be. 

Counterparty Due Diligence (“CDD”) 

5.3 The term “Counterparty” refers to any counterparty with which YZJMD comes into contact  within the course of its Business, including the following: 

a) a “Customer” of an entity within YZJMD that holds a Capital Markets Services Licence;
b) providers of services or goods to YZJMD (on a risk-proportional basis); and
c) counterparties to transactions with YZJMD that involve the payment or receipt of substantial sums of money, such as the entry into a joint venture for the acquisition or  development of a project.

5.4 Prior to establishing a business relationship or entering a transaction with a Counterparty, CDD  measures must be undertaken to obtain knowledge regarding the Counterparty to guard against  establishing any business relationship or entering any transaction which is or may relate to or  may facilitate money laundering or terrorism financing. 

5.5 Employees undertaking the CDD measures must be vigilant to any suspicious circumstances in  the proposed transaction with a Counterparty (“Red Flag”). 

5.6 If there is any Red Flag, the relevant Head of Department or his or her authorised delegate or  representative (collectively, “HOD”) shall adopt a risk-based approach in determining whether  to undertake enhanced due diligence measures (“Enhanced CDD”) and/or the extent of  Enhanced CDD to be undertaken. Where Enhanced CDD is assessed to be required, screening of  the Counterparty shall be undertaken. 

5.7 Following the completion of Enhanced CDD, the relevant HOD shall assess if there are further or  other Red Flags and determine whether to proceed with the transaction with the Counterparty. 

5.8 Ongoing monitoring. On an ongoing basis, employees must be alert to changes in a  Counterparty’s circumstances that may require updates to or review of CDD conducted prior to  the commencement of the business relationship with or prior to the transaction with the Counterparty. When there is a change of circumstances, the relevant HOD shall perform a  targeted review of the relationship and manage the future relationship with the Counterparty. 

Suspicious Transaction Reporting 

5.9 Under the CDSA, there is an obligation to report any knowledge or suspicion of Relevant  Circumstances (as defined below) to the Singapore Police Force Commercial Affairs Department  (“CAD”). A report to the CAD is made by filing a “Suspicious Transaction Report” (or “STR”) to  the Suspicious Transactions Reporting Office (“STRO”) via the STRO Online Notices & Reporting  (“SONAR”) platform. 

5.10 If, as a result of the CDD measures undertaken on a Counterparty for a business transaction to be  entered into in Singapore or other business activity in Singapore, any employee:
          (a) becomes aware that; or 
          (b) has reasonable grounds to believe that, 

a property* represents the proceeds of or was used or is intended to be used in connection with  criminal conduct or is terrorist property or is to be used for terrorist purposes (“Relevant  Circumstances”), the requisite work shall be carried out to determine whether there is actual  knowledge of or there are reasonable grounds to believe that there are Relevant Circumstances to  be reported as a suspicious transaction (“Suspicious Transaction”) by filing a STR to the STRO. 

*means money and all other property, movable or immovable, including things in action and other  intangible or incorporeal property.

5.11 During this period of time, the employee should not abruptly cease all communications with the  Counterparty so as not to run the risk of tipping off the Counterparty. The employee should  continue communications as usual. However, the employee should not complete the transaction  with the Counterparty. 

5.12 If and after filing a STR, YZJMD will comply with any instructions from CAD about how to  proceed with the transaction with the Counterparty. In proceeding with the transaction, the  relevant employee shall act according to the instructions of his or her HOD. 

5.13 Ongoing monitoring. On an ongoing basis, employees must be alert to changes in a  Counterparty’s business activity that may give rise to Relevant Circumstances. 

Record Keeping 

5.14 Employees conducting CDD shall prepare, maintain and retain records of any data, documents  and information obtained (including any analysis performed) to comply with this Policy. Such  records may be retained as originals or copies, in paper or electronic form, and shall be retained  for a period of at least five (5) years after entry into the business relationship with the  Counterparty or the completion of the transaction with the Counterparty, or any longer period  required under the AML/CFT Laws, or any other applicable local laws, as the case may be. 

5.15 The CDD documents and records shall be maintained in a manner that would facilitate the timely  retrieval of and access to such documents and records in response to requests by government  authorities or otherwise. 

5.16 Records of data, documents and information pertaining to a transaction or matter which is under  investigation or which has been the subject of an STR shall be retained for as long as requested or  ordered by CAD or other relevant authorities.

6 REPORTING 

6.1 Any person may report any instance of non-compliance with this Policy to the Compliance department. 

6.2 Any non-compliance with this Policy may potentially result in criminal and civil liabilities on the  part of the relevant employees under applicable laws and may additionally expose the YZJMD to  the same. If YZJMD finds that its employee has not complied with this Policy may institute  disciplinary action and have reasonable basis to terminate his or her employment. The employer  is not obligated to wait for the outcome of any civil or criminal action against the employee before  taking any disciplinary action or terminating his or her employment. 

Approved and adopted by: 

Yangzijiang Maritime Development Ltd. on 18 November 2025.