Code of conduct

Our standards. Our responsibility.

This is the Code of Conduct of Gulf Titans International Offshore Crude Oil Trading L.L.C. It is owned by the Compliance Team and applies to everyone who works for or represents the Company.

1. Purpose

This Code of Conduct (the Code) sets out the ethical principles, standards of behaviour and professional conduct expected of all directors, managers, employees, agents, consultants and representatives of Gulf Titans International Offshore Crude Oil Trading L.L.C (Gulf Titans International or the Company).

The Code aims to promote integrity, transparency, accountability and compliance with applicable laws and regulations in all business activities.

2. Scope and applicability

This Code applies to:

• All employees and management of the Company
• Directors, officers and shareholders when acting on behalf of the Company
• Agents, intermediaries, contractors and business partners representing the Company

Mandatory compliance

Compliance with this Code is mandatory.

3. Core values

The Company is committed to:

• Integrity and honesty in all dealings
• Compliance with applicable laws and regulations
• Fair competition and ethical business practices
• Respect, professionalism and accountability
• Zero tolerance for corruption, bribery or illegal activities

4. Compliance with laws and regulations

All individuals covered by this Code must:

• Comply with all applicable local and international laws, regulations and standards
• Adhere to UAE laws, including commercial, anti-money laundering and anti-corruption regulations
• Cooperate fully with regulatory authorities when required

5. Anti-bribery and anti-corruption

The Company strictly prohibits:

• Offering, giving, soliciting or accepting bribes or improper payments
• Facilitation payments of any kind
• Any form of corruption, whether direct or indirect, including through agents or intermediaries

Gifts and hospitality

Gifts, hospitality or entertainment must be reasonable, transparent and not intended to improperly influence business decisions. Particular care must be taken in dealings with national oil companies, government officials and state-owned entities.

6. Conflicts of interest

Individuals must avoid situations where personal interests conflict, or appear to conflict, with the interests of the Company.

Any actual or potential conflict of interest must be disclosed promptly to management, including:

• Personal financial interests in customers, suppliers or competitors
• Family or close personal relationships affecting business decisions
• Outside employment or business activities that may interfere with Company duties

7. Anti-money laundering and sanctions compliance

The Company is committed to preventing money laundering, terrorist financing and proliferation financing. All individuals must:

• Comply with the Company's AML and CTF Policy
• Conduct proper due diligence on customers, counterparties and intermediaries
• Report suspicious activities immediately to the Compliance Officer or MLRO
• Comply with applicable sanctions and watchlist requirements, and never deal with sanctioned persons, entities or vessels, or in product of sanctioned origin

8. Confidentiality and data protection

All confidential, proprietary or sensitive information must be protected and used only for legitimate business purposes. Individuals must not:

• Disclose confidential information without authorisation
• Use Company information for personal gain

After an engagement ends

This obligation continues after the termination of employment or engagement.

9. Fair dealing and competition

The Company supports fair competition and prohibits:

• Fraud, misrepresentation or deceptive practices, including in trade, shipping and quality documents
• Collusion, price fixing or market manipulation
• Unfair or unethical competitive behaviour

10. Health, safety and environment

The Company is committed to:

• Providing a safe and healthy work environment
• Complying with applicable health, safety and environmental laws, including marine and shipping standards
• Conducting operations in a responsible and environmentally conscious manner

Safety procedures

All individuals must follow safety procedures and report unsafe conditions.

11. Use of Company assets

Company assets, including funds, equipment, systems and information, must be:

• Used responsibly and for legitimate business purposes only
• Protected against misuse, loss or theft

12. Reporting violations and whistleblowing

Any suspected violation of this Code must be reported promptly to management or the Compliance Officer. The Company:

• Prohibits retaliation against individuals who report concerns in good faith
• Treats reports confidentially to the extent permitted by law

13. Disciplinary action

Violations of this Code may result in disciplinary action, including:

• Warnings or corrective measures
• Termination of employment or contract
• Legal action where applicable

14. Acknowledgment and compliance

All individuals subject to this Code are required to:

• Read and understand this Code
• Acknowledge compliance in writing
• Uphold the standards set out herein at all times

15. Review and updates

This Code shall be reviewed at least annually and updated as necessary to reflect changes in laws, regulations or business practices.

Approval

This Code is approved by the management of Gulf Titans International Offshore Crude Oil Trading L.L.C and is effective from 30 September 2026.