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In 2021, we continued to make improvements to ensure the Group continues to meet high standards of governance. Business Ethics

Good governance and ethical behaviour are the cornerstones of our operations and the foundation of our licence to operate. As a business, we are committed to complying with all relevant laws and regulations while upholding the highest standards of ethics. We expect everyone who works with us, from our employees to contractors and suppliers, to share our values and behave in an ethical and responsible way as a matter of course.

Our Code of Ethics establishes the governance framework for how we conduct business. The principles laid out in the Code are further detailed in individual policy documents that address specific aspects of our business ethics including anti-corruption, whistleblowing, human rights, and supplier relations.

The purpose of The Code is to clearly articulate our ethical standards and provide employees with a guide to what is expected of them in their behaviour and business activities. It provides information on how they can get help, and also guidance on their responsibility to report issues if they identify a problem. The Code provides guidance to ensure employees are aware of, and understand, their ethical and legal responsibilities, and covers issues relating to employees, customers, shareholders and the community. On joining, new employees are required to read the Code and then sign to demonstrate that they have read and understood it. All employees are kept up to date with the Group’s governance policies and we provide ongoing training to cover any policy changes.

Anti-Bribery & Corruption

We are committed to upholding the highest ethical standards and operate a zero tolerance approach to bribery and corruption in any form; our approach is reflected in the Group’s Code of Ethics, which sets out the standards of conduct expected.

Our Anti-Bribery and Corruption Policy ensures that all our business is conducted in an honest and ethical manner and in compliance with the law. The policy applies to all employees of Global Ports, as well as those working on our behalf in any capacity.

Whistleblowing

Global Ports encourages its employees, clients and other stakeholders to report any potentially unethical, unlawful or suspicious conduct or practices. The Group operates a 24/7 confidential whistle blower service that offers a variety of routes to report concerns:

Via a dedicated e-mail address Via a free confidential telephone number Face-to-face with a senior member of Group Internal Audit Department responsible for managing the whistleblowing service

Details of the service are available on the Group’s intranet as well as on information boards located throughout the offices and prominently displayed at the Group’s terminals.

The service is run by the Internal Audit Department which operates independently of management and reports directly to the Audit & Risk Committee of the Board. Calls to the hotline service are treated in confidence, and investigated thoroughly and without bias.

In 2021, 20 reports were submitted to the confidential whistle blower service, 70% came via email, with the remainder reported via the telephone hotline. Out of the 20 reports submitted, 15 required full investigation and follow-up actions and five did not as these did not meet the threshold required. There was just one allegation relating to fraud, which on further investigation was not upheld.

Responsible Procurement

We aim to develop strong supplier relationships, working together to maintain the highest ethical standards. This is an important part of our approach to sustainability and important to how we manage risk in our business. We expect suppliers to comply with the Group’s high ethical standards and behaviours which are set out in the Group’s Code of Ethics.

The Group’s Procurement Policy sets out the guidelines for suppliers. The Procurement Department of Global Ports Management LLC has purchasing responsibility for the terminals of the Group based on the following principles:

Full compliance with the legislation of the Russian Federation Competitiveness and transparency Supplier selection based on price, quality and timeliness Total cost of ownership All procurement information is placed on www.etprf.ru and www.fabrikant.ru electronic marketplaces.

All necessary information is also shared on the EIS (Electronic Information System) website www.zakupki.gov.ru. All tender requests are published on the websites stated above to ensure fairness and transparency in the tendering process.

The Group conducts periodic reviews and audits of its suppliers to ensure compliance. And the procurement department continues to monitor the development of responsible procurement practices.