CODE OF ETHICS ON BUSINESS CONDUCT

The Company adopted its Code of Ethics on Business Conduct (the “Code”) in 2014. The Code serves as a guide and a reference for the Company’s employees and management on how to carry out their duties effectively, lawfully and safely.

CODE OF CONDUCT AND CORPORATE CULTURE

The core values underpinning the Code are: Integrity, Respect for People and the Environment, and Continuous Improvement. The articles of the Code provide guidance for employees on fulfilling their work responsibilities and interacting with others effectively, safely, lawfully and with integrity. The Code applies equally and without exception to all employees and all levels of management, including the members of the Board of Directors and the Board of Commissioners. Every employee of the ANJ Group is required to pledge to uphold the Code; our investors, stakeholders and business partners are also required to make such a commitment where relevant. The Code was formally adopted in January 2014, and has been disseminated to all employees. Since October 2017, the Code has been an integral part of our Management Trainee program curriculum as well as the induction program provided for all new employees, and is embedded into the learning and development curriculum at our ANJ Learning Center.

ANJ’S CODE OF ETHICS ON BUSINESS CONDUCT COVERS:

• Corporate Values
• Compliance with laws and regulations;
• Workplace safety, health and the environment;
• Work relations, including professionalism, fairness and the separation of personal and corporate interests;
• Relationships with suppliers and customers, including responsibility for product quality;
• Relations with the government;
• Conflicts of interest;
• Use and maintenance of company property;
• Company information and financial disclosure;
• Relationships with investors and the media; and
• Insider trading.

The Code is reviewed regularly and periodically updated to ensure that it remains aligned with the growth of our business, our strategic objectives and developments in our external environment.

BREACHES OF THE CODE OF ETHICS AND SANCTIONS IMPOSED IN 2021

The following Code violations were substantiated in 2021:

1. Fraud and Manipulation (integrity related).
2. Non-Compliance with Internal Control SOP.
3. Operational Inefficiency.

With regard to the violations above, the Company imposed the following sanctions:

1. Warning letter.
2. Report to police to be processed according to law.
3. Work termination.

Critical Concerns Reported in 2021