Employee code of conduct

1.0 PURPOSE

1.1 Globalink Transportation and Logistics Worldwide (the “Company”) is committed to achieving and promoting the highest standards of Business Ethics, Integrity and Sustainability in daily operations and
complying with all applicable laws and internationally recognized norms and business standards, especially
with respect to anti-corruption, equal opportunity, human rights, employee health & safety, the environment, and product & service safety.

1.2 We expect full compliance from all employees of all our operations, subsidiaries and affiliates to the
standards set in this Employee Code of Conduct (the “Code”). We take a zero-tolerance approach for
unethical, illegal and unsustainable business practices or conduct in any form in any country / territory in
which we operate and do business with. All acts of employees must be socially responsible and aligned with the Company’s philosophies and interests.

1.3 This Code sets out the Company’s global standards on business operations and outlines the rules and
regulations that govern our business and personal behavior, to act ethically, legally and sustainably. If you
are ever in doubt as to whether any action may breach this Code, please consult the Head of Human
Resources and Administration Department of the country / territory in which you are located before
proceeding.

2.0 APPLICABILITY

2.1 This Code takes immediate effect and applies to all employees in all countries and territories in which we operate and do business. This Code should be communicated to all employees and posted in a place readily accessible to employees always. This Code only outlines the principles and should be supplemented
by detailed policies, guidelines and/or standard operating procedures, if any, in relation to each specific
aspect.
2.2 Any practice that conflicts with or violates this Code is strictly prohibited by the Company.
2.3 You must read and familiarize yourself with this Code and abide by its terms. If you have any questions
about this Code, please seek advice from the Head of Human Resources and Administration Department
of the country / territory in which you are located.

3.0 CONSEQUENCES OF FAILURE TO COMPLY

3.1 Any failure to comply with this Code will be treated seriously. Any employee who violates the standards set out in this Code can expect to face disciplinary action, including the possibility of summary dismissal from the Company in accordance with applicable laws. Violation of this Code may also constitute violation of the law and may result in civil and criminal penalties for you, your colleagues and/or the Company.

3.2 In the event that the Company sustains any losses and/or damage arising out of any violation of this Code, the Company may hold those responsible accountable for such losses and/or damages.

4.0 BUSINESS ETHICS

4.1 We expect all employees to adhere to high standards of ethical conduct and comply with all applicable laws and regulations regarding human rights, product & service safety, anti-money laundering and financial
information and records in any country / territory in which we operate and do business.

4.2 Human Rights
4.2.1 We expect all employees and business partners to respect human rights and jointly adopt the principles regarding ethical employment practices and laws in any country / territory in which we operate and do business.
4.2.2 We prohibit employment of underage children or forced labor or any form of physical punishment or abuse.
You should take steps to ensure that slavery and human trafficking are not taking place in the Company.
4.2.3 We should ensure that there are no involuntary prison labor and any situation requiring employees to surrender / deposit their identity documents prior to commencing employment.
4.2.4 We are committed to upholding human rights in the workplace by treating all employees equally and fairly in human resources matters. Harassment, abusive behavior, any forms of abuse, inhumane or degrading treatment, corporal punishment or intimidation are strictly prohibited in the workplace.

4.3 Product & Service Safety
4.3.1 All employees should comply with industry standards, applicable laws and regulations in relation to the safety of products or services.
4.3.2 You should check the applicable regulations, the availability and validity of specific license and/or permit that is/are required for providing the products or services before delivery.

4.4 Anti-Money Laundering
4.4.1 Employees shall abide by all laws in relation to anti-money laundry and sanctions designed to deter criminal enterprise, prevent terrorism and protect national security of the countries and territories where we do business.
4.4.2 You should exercise good judgment when dealing with customers or other business partners to prevent inadvertent use and/or involvement of the Company, its assets and/or resources for money laundering or terrorist financing. In the event of doubt, please seek advice from the Head of Finance and Accounting Department of the country / territory in which you are located.

4.5 Financial Information and Records
4.5.1 We are committed to maintaining accurate and proper records and all business transactions in our financial and accounting books and records, in accordance with all applicable accounting and audit standards.
4.5.2 You should provide all necessary records, documents, materials and information to the Finance and
Accounting Department to ensure that they could keep accurate, complete and up-to-date financial records
and reports of any business transactions handled by you. You must not attempt to create any false or
misleading statements or entries in the financial records.

5.0 WORK STANDARDS

5.1 It is the responsibility of each employee to protect and make proper use of Company property and contribute
to an equal, safe and harass-free work environment. Employees should comply with all applicable laws
regarding occupational health and safety, diversity and discrimination, protection of company property and
intellectual property in any country / territory in which we operate and do business.

5.2 Occupational Health and Safety
5.2.1 Occupational health and safety is an integral part of the Company’s operation. We aim high to provide a safe and healthy workplaces for all employees that comply with and surpass standards required by all
applicable Occupational Safety and Health regulations.
5.2.2 Every employee is responsible for identifying opportunities for continually improving our Occupational
Health and Safety system. Competent contractors should be selected and monitored to ensure applicable
occupational health and safety standards are observed. Please refer to the “Occupational Health and Safety
Policy”, which is available on the Company website and Internet for further details.
5.2.3 You should fulfil all Occupational Health and Safety requirements prescribed by the Company and
stakeholders in any countries / territory in which you are located, and eliminate hazards and reduce
occupational health and safety risks.

5.3 Diversity and Discrimination
5.3.1 We commit to establishing a culture that respects and reflects the diversity of the communities in which we operate, we treat employees equally and fairly compensate them by providing wages and benefits in accordance with applicable laws. We recognize and respect the rights of employees to form and join trade unions and bargain collectively in accordance with applicable laws. We expect our employees to share this commitment and to ensure free of unlawful discrimination and harassment, abusive conduct and bullying.
5.3.2 We disallow any direct or indirect discrimination based on race, color, religion, sex, sexual orientation, age, gender identity or gender expression, national origin, political orientation, or disability. We prohibit harassment, abusive behavior, any forms of abuse, inhumane or degrading treatment, corporal punishment or intimidation.
5.3.3 No discrimination in hiring and employment practices in any form is allowed. Everyone will be
assessed based on the job requirements and their relevant capabilities, and not on other irrelevant
considerations.
5.3.4 You should not take part in, encourage or condone cases of any forms of harassment, which offends equality of opportunities. Please refer to the “Global Equal Opportunities Policy”, which is available on the Company internal network for further details.

5.4 Company Property & Intellectual Property
5.4.1 We respect and treasure our assets and strive to prevent them from misuse, manipulation, damage, loss, theft or, in the case of information, disclosure to unauthorized parties. You are requested to preserve our reputation and brand.
5.4.2 Assets of the Company, no matter if they are tangible, intangible, electronic and/or digital, are for the
Company’s business use only. You should never use them for personal benefit, outside work, in an unlawful
or unauthorized manner.
5.4.3 We respect our trademarks, copyrights, patents and other assets (including internal publications and
software programs developed for or by our company). This intellectual property belongs to the Company
and must be protected and managed appropriately according to the applicable laws and in the manner
stipulated in our employment letter, other contract and/or non-disclosure agreement, if any, with you.

6.0 BUSINESS INTEGRITY

6.1 We expect all employees to adhere to high standards of Integrity in daily operations and comply with all applicable laws and regulations regarding bribery, fair competition, sanction and trade compliance, data
protection and insider information in any country / territory in which we operate and do business.
6.2 Conflict of Interests
6.2.1 We require all employees to declare their family relationship with all directors, officers and employees of all
our operations, subsidiaries and affiliates (“Company Personnel”) and with whom we do business,
including our customers, agents, intermediaries, consultants, contractors, sub-contractors, suppliers, joint
venture partners and service providers (“Business Partners”) and any trustee of any trust of which the
employee and/or his/her family is/are beneficiary, and/or a company in which the employee and his/her
family together are entitled to exercise or control the exercise of 50% or more of the voting power at general
meetings, or the employee and his/her family can control the composition of a majority of the
board of directors or similar organ which might be considered as a conflict of interest.
6.2.2 You should declare the family relationship with the personnel included in Section 6.2.1 above to the
Company by completing the “Personal Declaration Form – Acceptance / Offering of Advantage / Related
Parties Relationship” in the Company’s prescribed form (may be downloaded from the Company’s Internet)
and submit it to the Human Resources Department of the country / territory in which you are located at the
first reasonable opportunity upon any update in information. Please refer to the “Global Anti-Bribery Policy”,
which is available on the Company website and Internet for further details.

6.3 Bribery and Corruption
6.3.1 We expect all employees to comply with all applicable anti-bribery laws in every jurisdiction in which we operate and do business.
6.3.2 You must never engage in any act of bribery. You may not offer, authorize, give, promise, accept or offer to accept, anything of value in exchange for an improper advantage.
6.3.3 You should ensure that there are no unreasonable or substantial gifts or entertainment received from or given to the Company’s existing or potential Business Partners in the context of your relationship with the Company, particularly if it could be construed as or give rise to a reasonable suspicion of being for the
purpose of gaining an unfair business advantage for the Company or for yourself or influencing your or the
relevant personnel’s objectivity in decision making.
6.3.4 You should politely refuse and not offer any gifts or entertainment from or to the Company’s existing or potential Business Partners. If there is no reasonable opportunity to refuse or you need to inform the Head of Human Resources.
Please refer to the “Global Anti-Bribery Policy”, which is available on the Company website and Internet for further details.

6.4 Fair Competition
6.4.1 We comply with all antitrust and global competition laws where we operate and expect our employees and business partners to always act with integrity and business ethics and never enter into any agreement that unlawfully restricts competition as well as never deceive, defraud or mispresent the facts.
6.4.2 You should compete fairly when doing business and share your unwavering commitment to conducting business and win business with integrity and quality.

6.5 Sanction and Trade Compliance
6.5.1 We comply with laws, regulations and international conventions that regulate our business activities,
including without limitation, laws and regulations on export controls, sanctions and customs clearance in all regions and countries. Please note that these relate not only to movement of goods but also other
operational activities such as financial transactions, procurement and even recruitment. Please refer to the
“Trade Compliance Policy”, “Sanction Policy” and “Anti-drug Trafficking Policy” which are available on the
Company website and Internet for further details.

6.6 Data Protection
6.6.1 You should ensure that all Company information and data you received or encountered is treated with
complete confidentiality and maintain integrity of all such information. You should never share any
confidential information of the Company with any unauthorized persons even if your employment ends.
6.6.2 We respect data privacy and expect all employees to comply with all applicable local, national and
international data privacy laws, information security laws, regulations and industry standards.

6.7 Inside Information
6.7.1 All unpublished information about the Company and the Company’s business partners gained through your position in the course of work should be considered confidential information. You should observe the
applicable laws, rules and regulations governing the trading of the Company’s stocks and/or shares and
restricting disclosure and misuse of price sensitive information. Additionally, you should not disclose or make such information available to others for their own benefit in trading.

7. ENVIRONMENTAL COMPLIANCE AND SUSTAINABILITY

7.1 We are committed to being environmentally responsible by integrating sustainability into our corporate
strategies. We have set our sustainability vision with reference to the technological developments in the
logistics industry, as well as the evolving dynamics of global challenges.

7.2 We expect all employees and business partners to adhere to our sustainability initiatives and comply with all applicable environmental laws and regulations in any country / territory in which we operate and do business.

7.3 You should take a proactive approach to environmental matters to minimize the environmental
impact of the products and services we provide. We encourage you to actively identify ways to reduce
carbon emissions during operations to mitigate climate change and strive to protect the environment by
conserving energy and natural resources throughout your work. Please refer to the “Environmental Policy”, and “Climate Change Policy”, which are available on the Company website and
Internet for further details.

8.0 WORKING WITH BUSINESS PARTNERS

8.1 We expect our Business Partners to conduct their business ethically and base their activities on principles like those under this Code. You shall share with and/or make available to suppliers, vendors and other Business Partners, whom you work with, our “Business Partner Code of Conduct” which is available on the Company internal network. You shall also review if Business Partners follow the “Business Partner Code of Conduct” upon engagement of such Business Partners, contract renewal and on a regular basis.

9.0 REPORTING OF VIOLATIONS

9.1 You must report any actual or suspected violations of this Policy to the Company at the earliest possible
opportunity by contacting the Head of Business Unit / Department or the Head of Human Resources and
Administration Department of the country / territory in which you are located through the internal mailing
system, email or post giving the facts and evidence (if any) you have or are aware of and your contact
details (if possible). Anonymous reports with insufficient information on the suspected violation will not be
processed. We encourage you to provide your contact information when reporting, to help us investigate
the matter fully. Your confidentiality will be respected.

9.2 The Company does not tolerate retaliation against anyone who in good faith reports a concern, even when allegations are found to be unsubstantiated. Anyone who retaliates against any other person who in good faith reports a concern is in violation of this Policy and may be subject to disciplinary action, including
possible dismissal. If you suspect retaliation, you should report it immediately to the Head of HR&A. The
regional Managing Director of the country / territory in which you are located or the General Director
of the Company for the retaliation concerning the regional Managing Director is responsible for ensuring
that such reports are investigated, and appropriate action is taken.