CODE OF CONDUCT

Document M anagement

This docum ent is availa ble i n m ultiple langu ages and m ay be updated from tim e to tim e. For the avoi dance
of dou bt, it is therefore e xp licitly m entioned that the English version published and distributed by t he
COFCO Inte rnati onal Lim ited (‘CI L”) Co rpo rate Co de Comm ittee (“CCC”) is al ways leading. If you are not
sure your (p rinte d) docum ent is the latest version, pl ease consult CIL’s web pag e
(www.cofcoint ern ationa l .com).

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Dear COFCO International employees,

Our Code of Conduct is at the heart of what we do in COFCO International.

COFCO’s philosophy is driven by the balance between people and the planet on which we live. This
philosophy is represented in our company logo, with people at the heart of the logo in green, the colour
of life. It symbolises people holding hands and hearts beating as one. The blue sky represents our
goals, ideals and pursuits. The orange stands for the land and its harvest. COFCO’s philosophy is the
foundation of COFCO International’s purpose.

That’s why we, at COFCO International, believe that agricultural products, which we need to support
our daily life, should be available for every person on this planet, now and in the future. It’s all about
‘Meeting Tomorrow’s Demand’, and if we want to look after people, we must also look after our planet.

For this reason, we need to reflect this responsibility in the way we go about our business, by ensuring
that our business is being conducted with integrity and with respect for our stakeholders. We have
formalised this in our Code of Conduct. The principles of this Code apply to everyone at COFCO
International, because each one of our people is an ambassador for our company.

Together we have to ensure that we live by our Code of Conduct and the values it represents. This is
the only way we are able to play our part in maintaining the balance between people and the planet
on which we live.

In case you have any questions or concerns, please do not hesitate to discuss these with your
manager or anyone in our leadership team.

Thank you for being an ambassador for COFCO International.

Johnny Chi

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THE CODE OF CONDUCT

CIL’s Code of Conduct is grounded in our Corporate Values of Sunshine, Integrity, Inclusiveness,
Innovation and Sustainability. We have translated these Corporate Values into 5 main principles of
how to behave towards our stakeholders, our Business Principles:

• We comply with the law and conduct our business with transparency and high ethical standards.
• We treat people fairly with dignity and respect.
• We act as long term and trustful partners throughout our value chain.
• We strive to conduct our business contributing to sustainable development.
• We strive to make a positive difference in the communities where we work and live.

This Code of Conduct sets more detailed behavioural standards on each Business Principle and
dictates the behaviour of all employees in conducting business around the world. Every individual
employee has a personal responsibility to comply with the Code. In addition, every supervisor and
manager has the responsibility of being an ethical role model. The Code should also be leading in
situations where it is difficult to decide on the proper actions to take.

Scope of the Code

Our Code applies to all employees of (subsidiaries of) CIL, wherever they are located. We also expect
our distributors, agents, contractors, suppliers and other business partners who work on our behalf to
comply with the principles and standards of this Code.

Policies and procedures under the Code

The company issues policies and procedures as further elaboration of this Code and its principles.
These policies and procedures are considered to be an integral part of the Code and have to be
adhered to accordingly.

Violations of the Code

Anyone who violates the Code will be subject to disciplinary action, up to and including suspension or
termination of employment. All disciplinary measures will be applied fairly, equitably and in accordance
with applicable law. Employees are required to speak up if they have or gain knowledge or suspicion
of non-compliance with this Code.

Reporting violations of the Code

If you become aware of violations of our Code, you have an obligation to speak up. The company
encourages employees to report any concerns to either their local Human Resources manager, the
CIL Corporate Code Committee ([email protected]) or the CIL “Concerns Reporting
Channel”. These reports may be submitted in person, by phone, by email or by regular mail. Further
details are included in the “Concerns Reporting Procedure”.

All reports of misconduct are taken seriously and will be treated confidentially, consistent with a full
and fair inquiry.

No retaliation

We respect those who raise concerns about improper behaviour and will never tolerate any
form of retaliation against anyone for making a report of actual or potential misconduct in good
faith.

All reports will be investigated and if a violation has occurred, appropriate disciplinary action will be
taken.

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COMPLIANCE

We comply with the law and conduct our business with transparency and high ethical
standards.

Compliance with the law

At CIL we seek to act in the best interest of the company while complying with all laws and regulations
of the countries in which we operate.

Fair competition

Antitrust laws are designed to ensure a fair and competitive free-market system. At CIL we are
encouraged to compete vigorously in the marketplace, but always in compliance with the applicable
antitrust and competition laws in place where we do business. This means we compete within
appropriate legal boundaries and on the basis of price, quality and service, without engaging in any
unfair, misleading or deceptive trade practices. Moreover, we expect all our employees to conduct our
commercial activities in a fair, honest and ethical manner.

Anti-money laundering

CIL condemns any possible conduct aimed at facilitating offences such as receiving, laundering or
using money, goods or any other utility of unlawful origin. All employees must promptly report any
suspected money laundering activity to their supervisor, Compliance, Legal or the Concerns Reporting
Channel.

Anti-corruption

At CIL we refrain from any illegal action or incentive aimed to induce or reward improper performance
or to influence someone in the performance of his/her function. We foster good business practices
and prohibit bribery and all other forms of improper payment. All dealings must be carried out with
integrity and must comply with applicable laws. We expect third parties representing CIL to abide by
these laws when they conduct business.

Trade sanctions

CIL adheres to all applicable laws and regulations relating to trade sanctions, embargoes, controls
and anti-boycotts. Employees involved in international business transactions must be familiar with and
comply with all trade sanctions and anti-boycott laws applicable to their work. If you are ever in doubt
about whether your operations may violate these laws, you must consult Legal immediately.

Offering and accepting gifts

CIL allows its employees to receive and offer gifts and entertainment courtesies solely if they serve a
legitimate business purpose, and provided that such courtesies are proportionate and do not
compromise their ability to make objective and fair business decisions. Further, special care must be
taken in this area when any government official is or may be involved. The Legal Department must be
notified prior to any offer of gifts or entertainment to a government official.

Cash, and cash equivalents, such as gift cards or securities, may never be given or received
by CIL employees.

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Conflict of interest

CIL employees shall do business ethically and with integrity. This includes conducting business
transactions with CIL’s best interests at heart. Employees shall avoid any situation that may involve a
conflict between their personal interests, including those of their family members, friends and
associates, and the interests of the company. They are not allowed to undertake any business activity,
investment or outside job which may cause others to doubt their impartiality or which interferes with
their ability to perform at CIL objectively and effectively. Employees dealing with customers, suppliers,
contractors or competitors must always act in the best interest of the company regardless of any
personal advantage.

Accurate business and financial records

We do and must keep accurate and reliable records. Accurate and reliable records are critical to
making sound business decisions and to maintaining the integrity of our financial reporting. Our
business information, in whatever form, shall reflect the true nature of our transactions.

Protection of Company resources and information

All employees shall protect company assets and may use them only in the interests of the company,
not for personal gain or any other improper purpose. Information generated within CIL is CIL´s property
and should be disclosed only to CIL employees with a need to know such information. Further,
company information should not be disclosed outside CIL without the proper authority, unless there is
a legal requirement to do so. All employees who have access to proprietary and confidential
information are required to take all reasonable steps to safeguard this information from unauthorised
access.

Intellectual property

At CIL we protect and assert our intellectual property rights because we are aware that our continued
success and future growth depend on innovative products and solutions. CIL also respects the
property rights of others. Under no circumstances are employees allowed to infringe upon third party
copyrights, trademarks or patents.

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OUR EMPLOYEES

We treat people fairly, with dignity and respect.

Human and labour rights

CIL complies with national and international labour laws and respects internationally recognised
human rights as expressed in the International Bill of Human Rights. CIL also respects the principles
and rights set out in the International Labour Organization (“ILO”) Declaration on Fundamental
Principles and Rights at work.

Freedom of association

We respect the right of our employees to freely and voluntarily join trade unions pursuant to applicable
legal regulations. CIL also encourages employees to take their concerns directly to management. The
company aims to create an environment where direct dialogue is the preferred avenue for resolving
issues.

No forced or child labour

We do not accept or tolerate any form of child, forced or involuntary labour. We expect our suppliers
and business partners to adhere to these same principles. Our rejection of forced and child labour is
consistent with the ILO´s Core Labour Standards and the United Nations Global Compact principles.

Diversity and equal opportunities

We require all CIL companies to provide equal employment opportunities to all employees, regardless
of race, gender, religion, political opinion, disability, sexual orientation, marital status or age. Success
within CIL must depend solely on personal skills and work performance.

No harassment

At CIL we do not tolerate harassment of any type, including verbal, physical, mental and visual
harassment. All types of harassment are destructive to a positive work environment and will not be
tolerated. We strive to create an environment of mutual respect, free from harassment and
unprofessional behaviour in the workplace.

Workplace health and safety

We are committed to providing a safe and healthy work environment in accordance with applicable
laws and regulations. Extensive and continuous training and regular safety audits are essential for the
understanding of and compliance with safety laws. All CIL´s operations and facilities must have
adequate Health, Safety and Environment procedures and practices in place.

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BUSINESS PARTNERS

We act as long-term and trustful partners throughout our value chain.

Relationships with business partners

We seek mutually beneficial relationships with clients, customers, suppliers and service providers. We
expect compliance with the law throughout our supply chain and promote the adoption of
environmental and social principles, as well as a respect for human rights.

Product safety and quality

At CIL we uphold the highest quality and safety standards for our products and assure they meet all
legally required standards for consumer health and safety. We guarantee adequate training of our
employees and encourage the use of environmentally sound technologies for better, safer, cleaner
and more sustainable production.

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SUSTAINABLE DEVELOPMENT

We strive to conduct our business contributing to sustainable development.

Contributing to sustainable development

Along with our global reach comes a responsibility to manage our impact and create shared value.
We recognise that it is essential to conduct our business in a way that meets the needs of the present
without compromising the ability of future generations to meet their own needs.

CIL affirms its commitment to sustainable development via five key pillars: safeguarding standards,
taking care of our people, connecting supply and demand responsibly, managing our environmental
impact and building strong communities. These five strategic objectives provide the foundation upon
which all actions are taken to address our sustainability issues and manage our impact.
Implementation of these strategic objectives is guided by the company’s sustainability policies.

Environmental responsibility

We commit to conducting our activities in an environmentally responsible manner, in compliance with

legal regulations and rules or standards to which the organisation subscribes. We direct our efforts to
the continuous improvement of our environmental performance, prevention of pollution and the
analysis of risks and opportunities in the decision making and business planning process. Accordingly,
we encourage the use of technologies and production processes oriented towards sustainable
development. All employees must follow applicable environmental laws and regulations, and report
any environmental incidents or violations.

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COMMUNITY

We strive to make a positive difference in the communities where we work and live.

CIL is committed to having a positive impact on economic and social welfare in local communities
through relationships with our neighbours and civil organisations. We promote local development by
striving to bring better education, income and labour conditions to the communities in which we
operate. We respect these communities´ rights to voice their needs and concerns and we make efforts
to engage with them to address those needs.

All CIL employees are encouraged to engage in communities´ needs assistance with their personal
contributions, in-kind donations and volunteer efforts.

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