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In 2022, we continued to improve the Group’s performance in line with high standards of corporate governance. Business ethics

Proper governance and ethical behaviour are the cornerstones of our business and the foundation of our operations. 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. Our Code of Ethics establishes the governance framework for how we conduct business. The principles set out in the Code are detailed in separate policy documents that address specific aspects of 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, as well as guidance on their duty to report concerns when they are identified, basic ethical and legal responsibilities, and issues relating to employees, customers, shareholders, and the community. New employees are required to review the Code when they start work and sign the acknowledgement form to confirm that they have read and understood it.

All employees receive up-to-date information on the Group’s management policy. We conduct ongoing training to get familiar with any policy changes.

Anti-bribery and corruption

We are committed to maintaining the highest ethical standards and will not tolerate bribery or 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 Global Ports employees as well as those working on our behalf in any capacity.

Hotline for reporting violations

Global Ports encourages its employees, clients, and other stakeholders to report any potentially unethical, unlawful, or suspicious conduct or practices.

The Group has a confidential whistleblowing service open 24/7, which offers a variety of ways to report concerns:

Via a dedicated email address Via an anonymous call to a toll-free number Via a face-to-face meeting with a senior member of the Group’s Internal Audit Department responsible for managing the whistleblowing service

Details of the whistleblowing service are available on the Group’s website, as well as on information boards located in the offices and in prominent places at the Group’s terminals. The service is run by the Internal Audit Department, which operates independently of management and reports directly to the Board’s Audit and Risk Committee. The chairman of the Audit and Risk Committee is informed of all enquiries received and recommended follow-up actions.

Key topics of the enquiries

All referrals are immediately logged by the Internal Audit Department, which manages the service. The appeals are then evaluated to decide whether further investigation is required by the Internal Audit Department or by management at the appropriate level.

Regardless of how concerns are raised, all reports are treated confidentially and investigated thoroughly and impartially, while always ensuring the complainants’ anonymity and protection against retaliation.

The Head of the Internal Audit Department presents all investigation findings and follow-up actions to the Board’s Audit and Risk Committee.

In 2022, we received 10 calls to our corporate hotline. All enquiries were investigated and the results were communicated to the Audit and Risk Committee and senior management with the appropriate follow-up action. None of the calls received by the hotline contained allegations of fraud, corruption, wrongdoing, or misconduct.

Responsible procurement Global Ports supplier (executor, contractor) code of conduct

We aim to develop strong supplier relationships, working together to maintain the highest ethical standards. This is an important part of our sustainability approach and risk management system. We expect suppliers to comply with the Group’s high ethical standards and behaviour, which are set out in the Group’s Code of Ethics. The Group’s procurement policy prescribes the fundamental principles of working with suppliers.

When carrying out procurement for the Group’s terminals, the procurement department of Global Ports Management 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

All procurement information is posted on the electronic trading platforms and, as well as on the website of the electronic information system

To ensure fairness and transparency in the bidding process, all requests for bids are published on the websites listed above. The Group conducts periodic reviews and audits of its suppliers to ensure compliance. The procurement department continues to monitor the development of responsible procurement practices.

In 2022, Global Ports developed and implemented the Supplier Code of Conduct to inform current and potential counterparties of the basic principles of Global Ports and the companies it manages. The document states that the Company considers sustainable development an important condition for doing business due to such corporate values as team unity, professionalism, and safety. When selecting suppliers, the Company gives preference to those that are committed to sustainable development, taking into account the results of assessments on relevant indicators throughout the supply chain as a tool to ensure it. In accordance with the United Nations Global Contract, a sustainable supply chain involves responsible interaction with suppliers and management about the environmental, social, and economic impacts of business decisions throughout the entire lifecycle of goods and services. The Company highlights the following areas for creating a responsible supply chain:

Environmental impact Waste reduction Human rights Increasing the transparency of the supplier base Procurement Operational and product innovations Logistics and distribution

Facility management MC Global Ports maintains equal business relationships with suppliers and encourages them to work in compliance with the principles specified in this Code.