1.1 SPCI HELM GROUP HOLDING PTE. LTD. together with its subsidiary companies (collectively known as “SPCI HELM”) is committed to conducting business ethically and responsibly with a focus of sustainable growth. We prioritize supplier/contractor management and uphold corporate governance principles while ensuring social, community, and environmental responsibility.

2.1 This Code is based on internationally recognised environmental and social standards, as well as relevant laws and regulations. It serves as an irrevocable foundation for all business relationships and establishes guidelines for monitoring its implementation.

3.1 Supplier/contractors are required to comply with all applicable laws and regulations of the countries where they operate in and where goods and services are provided. In case of discrepancies between this Code and prevailing laws/regulations, the stricter standard shall apply.

4.1 Supplier/contractors are expected to conduct their business in an ethical manner and with integrity.

4.2 Anti-Bribery and Corruption

Any form of fraud, corruption, extortion or other behavior involving improper benefits is strictly prohibited. Supplier/contractors must not offer or accept bribes or other unlawful/improper advantages from their business partners and/or SPCI HELM’s employees to obtain an unfair business advantage.

4.3 No Gift Policy

Supplier/contractors are encouraged to refrain from offering any Gift, Entertainment, Hospitality or Travel to SPCI HELM and/or its employees. Should any SPCI HELM employees try to solicit any Gift, Entertainment, Hospitality or Travel, Supplier/contractors can report it to SPCI HELM’s email address as described below.

4.4 Conflict of Interest

Supplier/contractors shall disclose, at first instance, if there is a potential conflict of interest relating to its potential and/or existing contractual relationship with SPCI HELM. Supplier/contractors shall also disclose, at any time during an ongoing contractual relationship with SPCI HELM, any actual or potential conflict of interest.

4.5 Fair Competition

Suppliers/contractors shall adopt fair practices and ensure their business practices are in line with all applicable antitrust or competition laws.

4.6 Privacy & Intellectual Property

Supplier/contractors shall comply with all relevant data privacy laws and regulations regarding the collection, disclosure, retention and/or processing of the personal data of SPCI HELM and its employees. Suppliers/contractors are reminded not to infringe any intellectual rights, copyrights, patents and trademarks. Where any intellectual property rights are developed as part of the contractual arrangement with SPCI HELM, the ownership of such intellectual property right shall be as defined in the signed contract.

5.1 Suppliers/contractors must ensure their employees meet the minimum standards as required by applicable local laws and regulations. This includes, but not limited to payment of the minimum wage, contributions to provident or retirement funds, overtime compensation, mandatory rest periods, and compliance with minimum working age requirements.

6.1 Supplier/contractors are required to provide a safe and healthy working environment that ensures the well-being of their employees. Suppliers/contractors must meet generally recognized or contractually agreed quality, health, safety, and environmental standards to consistently meet SPCI HELM’s needs. Suppliers/contractors are also responsible for obtaining, maintaining, and updating all necessary permits, licenses, and registration. SPCI HELM reserves the right to audit business/facilities location to ensure compliance.

7.1 Suppliers/contractors and Supplier/contractor’s representatives are prohibited from engaging in sexual exploitation and abuse, and sexual harassment. For purposes of this Code:

• Sexual exploitation is any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.
• Sexual abuse means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.
• Sexual harassment is any unwelcome conduct of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation. Sexual harassment may involve any conduct of a verbal, nonverbal or physical nature, including written and electronic communications, and may occur between persons of the same or different genders.

7.2 Suppliers/contractors are expected to have policies and measures in place to prevent and respond to sexual exploitation and abuse and sexual harassment. They are expected to facilitate or provide assistance to victims and survivors related to their safety and protection, medical care, psychosocial support and legal services, as well as to facilitate survivor and victims’ timely, safe and confidential access to a remedy.

7.3 Suppliers/contractors and Supplier/contractor’s Representatives are required to report all cases (including any allegations) of sexual exploitation and abuse, and sexual harassment to the SPCI HELM.

8.1 Suppliers/contractors shall maintain processes and standards that are designed to assure the integrity of each shipment to SPCI HELM from its origin through to its destination and all points in between.

9.1 Suppliers/contractors are expected to implement management systems to facilitate compliance with all applicable laws and to promote continuous improvement with respect to the expectations set forth in this Code. This includes the following aspects:

9.2 Communications

Suppliers/contractors shall ensure adequate communication on the principles set forth in this Code to their managers, employees as well as their supply chain and ensure strict compliance with this Code.

9.3 Risk Management

Suppliers/contractors are expected to implement appropriate measures to manage any compliance risk exposures stated in this Code and/or mechanisms to identify, determine and manage risks in all areas addressed by this Code and with respect to all applicable legal requirements.

9.4 Compliance with this Code

SPCI HELM reserves the right to conduct checks on Supplier/contractor’s compliance with the requirements of this Code. Any breach of the obligations stated in this Code may be considered as a material breach of contract by the Supplier/contractor for which SPCI HELM will reserve the right to exercise its rights to terminate the service or act in accordance with the provisions as stated in the Contract.

SPCI HELM will adhere to the following principles when addressing concerns or issues raised in good faith:

1. Confidentiality: All reports can be sent to legal@spci-helm.com and the identities of whistleblowers will be kept strictly confidential, to the extent permitted by law and as required by the investigation.
2. Non-Retaliation: SPCI HELM strictly prohibits any form of retaliation, reprisal, or harassment against whistleblowers.