1          INTRODUCTION 

Yangzijiang Maritime Development Ltd. (“YZJMD” or the “Group”), is organised under the laws of  Singapore and its operations are subject to the laws of Singapore. The Group is committed to achieving its  business objectives through ethical and excellent conduct. Integrity is one of the Group’s core values and the  Group is committed to high standards of corporate governance and accountability in its affairs. 

“Whistleblowing” refers to the making of certain disclosures (via a dedicated and clearly communicated  reporting mechanism) of actual, suspected, or potential (or “reasonably anticipated”) conduct that an  individual reasonably believes to be unlawful. Therefore, disclosures can be made by any third party engaged  in a business relationship with the Group about serious breaches observed in their dealings with the Group.  This includes the reporting of information alleging a serious breach of laws, regulations, or ethics by another  employee(s). You are encouraged to raise genuine concerns about possible improprieties in the conduct of the  Group’s business, whether in matters of financial reporting or other malpractices, at the earliest opportunity  in an appropriate way. 

2          CODE OF CONDUCT AND ETHICS 

The Code of Conduct and Ethics applies to all employees of the Group, including employees. It sets out the  principles to guide employees in carrying out their duties and responsibilities when dealing with the Group,  its business partners, customers, suppliers and other stakeholders. The Code of Conduct and Ethics covers  areas such as fraud, business and workplace behaviour, protection of assets, proprietary information and  intellectual property, confidentiality, conflict of interest, and non-solicitation of customers and employees. 

In addition, employees must comply with the applicable laws of the country, government regulations and  legal requirements of the country/ies where their operations are being carried out. 

Breaches of the Code of Conduct and Ethics will result in disciplinary action up to and including termination  of contract/employment or dismissal. 

3         ZERO TOLERANCE TOWARDS SERIOUS BREACHES 

The Group adopts a “zero-tolerance” policy towards corruption, dishonesty, fraud, negligence, any other  forms of illegal, inappropriate, unethical or unprofessional behaviour or conduct (collectively “Serious  Breaches”), and any deliberate concealment of information tending to show any of the aforementioned  Serious Breaches. Apart from the Code of Conduct and Ethics, it has put in place whistleblowing channels for  its business partners, customers, suppliers, other stakeholders and any third party to report actual or  suspected Serious Breaches. 

Investigations of actual or suspected Serious Breaches will be carried out in an objective manner by an  independent party who may or may not be within the Group. 

Where a Serious Breach is considered following an investigation, appropriate disciplinary actions will be  taken, up to and including termination of employment or contract. If the matter is substantiated, it will be  referred to the Singapore Police Force (“SPF”), the Corrupt Practices Investigation Bureau (“CPIB”), or other  law enforcement agencies, as deemed appropriate.

The Group recognises that there will be times when a person makes a report in good faith which later proves  to be unsubstantiated. However, the Company will take action against those who intentionally or maliciously  give false or misleading information against someone else. 

4         MAKING A WHISTLEBLOWING REPORT 

A Compliance Concern* is only protected under the Group Whistleblowing Policy where it is a “Qualifying  Disclosure” made in good faith and where you reasonably believe at the time that a Serious Breach has been,  is being, or is likely to be committed. A Qualifying Disclosure is defined as “any good faith communication  based on reasonable grounds that discloses or demonstrates an intention to disclose information that may  evidence a Serious Breach”. Compliance Concerns may be raised verbally or in writing. 

It is necessary that all vital information is provided in order to facilitate the investigation of any concerns  effectively. As such the Whistleblowing Report should be as specific and detailed as possible. It should  contain at least the following information: 

• Parties involved (Who); 
• Type of Serious Breach involved (What); 
• Dates or period of time (When); 
• Location where the Serious Breach was conducted (Where); 
• Apparent motives (Why); 
• Methods used to conduct the Serious Breach (How); and 
• Evidence substantiating the Compliance Concern(s). 

Incidents of actual or suspected Serious Breaches should be promptly reported to whistleblow@yzjmaritime.com, or the postal address 9 Raffles Place, #54-01, Republic Plaza, Singapore  048619 (with attention to the Audit and Risk Committee Chairman). 

*refer to legal, compliance and ethical questions and concerns, including (i) concerns regarding suspected or  actual violations of applicable laws or regulations or of the Code of Conduct and Ethics, and relevant policies  and procedures; (ii) concerns regarding suspected or actual ethical misconduct; and (iii) accounting concerns.

5         HANDLING OF WHISTLEBLOWING REPORTS 

All information provided will be investigated fairly and consistently, but consideration will be given to these  factors: 

• The severity of the concerns raised; 
• The credibility of the concern or information; and 
• The likelihood of confirming the concern or information from other sources. 

Concerns expressed anonymously are more difficult to act upon effectively. However, they will still be  considered and reviewed to the extent possible, taking into account the above factors. 

If at the conclusion of an investigation, it is determined that a violation has occurred or the allegations are  substantiated, remedial action will be taken, as appropriate. 

5.1 Whistleblowing Channel via Audit and Risk Committee Chairman 

Whistleblowing Reports made to the Audit and Risk Committee Chairman will be reviewed by a Review  Committee and the composition of which to be determined by the Audit and Risk Committee Chairman. This  is to ensure that your concern is being reviewed in a fair, consistent and timely manner. 

Regardless of the significance of allegations or the outcome, all Whistleblowing Reports will be tabled and  discussed at Review Committee meetings. 

6         CONFIDENTIALITY 

To the extent that is lawful and the investigative process allows, all reports received, including the identity of  the whistle-blower, will be handled in strict confidence. 

7         INVESTIGATION PROCESS 

The report should be factual and contain as much information as possible to facilitate proper assessment and  urgency of investigative procedures. 

During the course of the investigation: 

• The whistle-blower and any interested person(s) involved may be contacted for further information  and/or any documents that can shed light on the investigation. 
• Great care, sensitivity and timeliness must be exercised whilst carrying out the investigation to avoid  misleading or wrongful conclusions or actions which may affect the evidence of the investigation or  result in wrongful accusations of any party. 

Upon investigation: 

• Recommended actions will be initiated. 
• Investigation results are confidential and will not be disclosed or discussed with anyone other than  those with legitimate reasons. The whistle-blower may not be updated on the outcome of the  investigation other than confirmation that the concern has been dealt with by the Group. This is to  safeguard all parties, including the Company. 

The Review Committee reviews actions taken by the Group towards whistleblowing initiatives and ensure  that fraudulent practices are reviewed without prejudice or biases, and executed with professional integrity in  compliance with the Group Whistleblowing Policy. 

8         IMMUNITY OR PROTECTION FROM DISCIPLINARY ACTION 

All Qualifying Disclosures shall be protected against any retaliation and victimisation as per the Group  Whistleblowing Policy. Whistle-blowers acting in good faith and who have not themselves engaged in such  concerns shall be protected from any forms of discrimination, harassment, reprisals, etc. Any acts of  retaliation and victimisation shall be reported to the Audit and Risk Committee Chairman. The Group will  not tolerate against anyone who, in good faith, discloses any actual or suspected violations or participates in  an investigation. 

9         FALSE OR MALICIOUS ALLEGATIONS 

It is important to note that anyone making false or malicious allegations will not be awarded the immunity or  protection under the Group Whistleblowing Policy. You are expected to act in good faith, have reasonable  grounds, and not make the report for personal gain. Acting in good faith means reporting without malicious  intentions and doing so in the best interest for everyone involved. If an allegation is proven to be malicious,  appropriate actions, including blacklisting, legal action or reporting the matter to the SPF may be taken. 

10         MODIFICATION

The Group reserves the right to modify the contents to maintain compliance with the applicable laws and  regulations or accommodate organisational changes within the Company or the Group. 

Approved and adopted by: 

Yangzijiang Maritime Development Ltd. on 18 November 2025.