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Business ethics

Good governance and ethical behaviour are fundamental principles of our work. Global Ports is committed to complying with all relevant laws and regulatory requirements, while striving to maintain the highest standards of ethical behaviour. We expect all our employees, as well as contractors and suppliers, to share our values and to act responsibly and ethically.

Our Code of Ethics sets the framework for all aspects of our business practices. The principles of the Code are developed in detail in specialised documents covering important issues such as anti-corruption, whistleblowing, human rights, and supplier relations.

The purpose of the Code is to clearly define our ethical standards and provide employees with clear guidance on the behaviour and business activities expected of them. The Code also provides guidance on how they should act if they become aware of misconduct. We regularly send employees up-to-date information on the Holding’s governance policies and provide training to familiarise them with ongoing changes affecting corporate governance.

Code of Ethics and Conduct Responsible procurement

We are committed to building strong, long-term relationships with our suppliers. We expect our suppliers to adhere to high ethical standards and behaviour as defined in the Company’s Code of Ethics. Global Ports’ Procurement Policy sets out the basic principles for dealing with suppliers, ensuring that ethical standards are upheld in all aspects of our business.

All information on ongoing procurements is posted on the electronic trading platforms Federal Specialised Marketplace 223-FZ , Fabrikant and Roseltorg, as well as on the official website of the Unified Information System for Procurement.

To ensure the fairness and transparency of bidding, all bids are published on the above sites. Global Ports regularly inspects and audits its suppliers to ensure that they comply with all necessary requirements. The Procurement Department closely monitors and promotes responsible procurement practices, reinforcing the principles of integrity and transparency in all our business operations.

The Procurement Department adheres to the following principles:

Full compliance with the legislation of the Russian Federation Competitiveness and transparency Supplier selection based on price, quality, and the promptness of delivery Total operating costs Whistleblowing hotline

Global Ports encourages its employees, customers, and other stakeholders to report any potentially unethical, illegal, or suspicious acts or practices.

The Company operates a confidential whistleblowing service (hotline) that is available 24 hours a day, 7 days a week. The hotline can be contacted by:

Sending a request to the email address Calling the toll-free anonymous telephone number Through a personal meeting with a senior member of the Company’s Internal Audit Department

Detailed information about the hotline is available on the Global Ports website, as well as on information boards in the offices and in prominent places at the Company’s terminals. All reports are logged and evaluated by the Internal Audit Department to determine if a further investigation is necessary. Regardless of the method of reporting, all allegations are treated confidentially and investigated thoroughly and impartially, ensuring the anonymity of the complainants and protection from retaliation.

The hotline is managed by the Internal Audit Department, which operates independently of executive management and reports directly to the Audit and Risk Committee of the Board of Directors1. The chairman of the committee is kept informed about all referrals received, the outcome of all investigations, and recommendations for further action.

In 2023, the corporate hotline received seven calls, including two calls containing accusations of fraud. For comparison: 10 calls were received in 2022. All enquiries were investigated and reported to the Audit and Risk Committee and senior management. The hotline enquiries containing allegations of fraud were not substantiated by the investigation.

Key topics of hotline enquiries (2023) Whistleblowing Policy

1 As of 31 December 2023. Currently, the Internal Audit Department remains independent of executive management, but reports directly to the Board of Directors.