1. Introduction

VAI TECHNOLOGIES PTE. LTD. (“VAI TECHNOLOGIES” or “the Company”) is committed to conducting business with

the highest standards of integrity, ethics, professionalism, and compliance with applicable laws and regulations. This

Code establishes the principles and standards expected from all employees, directors, contractors, consultants, and

business partners.

2. Compliance with Laws and Regulations

VAI TECHNOLOGIES complies with all applicable laws, regulations, and industry standards in Singapore and other

jurisdictions where it operates. Employees shall conduct business responsibly, maintain accurate records, cooperate with

lawful investigations, and avoid activities that may expose the Company or customers to legal or reputational risks.

3. Anti-Bribery and Anti-Corruption

VAI TECHNOLOGIES maintains a zero-tolerance policy toward bribery, corruption, fraud, and unethical business

practices. Employees shall not offer, promise, give, request, or accept improper payments, illegal commissions,

kickbacks, or any advantage intended to improperly influence business decisions. The Company complies with applicable

anti-corruption laws including Singapore’s Prevention of Corruption Act.

4. Fair Competition and Antitrust Compliance

VAI TECHNOLOGIES believes in fair and open competition. Employees shall compete based on quality, innovation, and

value, and shall not engage in price fixing, market allocation, bid manipulation, or other anti-competitive practices.

5. Privacy and Protection of Personal Data

VAI TECHNOLOGIES respects personal data privacy and complies with applicable data protection requirements,

including Singapore’s Personal Data Protection Act (PDPA). Personal data shall only be collected, processed, stored, and

used for legitimate business purposes.

6. Protection of Intellectual Property

VAI TECHNOLOGIES protects its own and third-party intellectual property, including software, algorithms, technical

documents, designs, confidential information, and business materials. Employees shall respect intellectual property rights

and protect proprietary information.

7. Confidentiality and Information SecurityEmployees must safeguard confidential customer information, business strategies,

technical information, and commercial data, and follow appropriate cybersecurity practices.

8. Conflict of Interest

Employees must avoid situations where personal interests conflict with Company responsibilities and must disclose any

actual or potential conflicts.

9. Responsible Business Practices

VAI TECHNOLOGIES promotes respectful workplace practices, ethical sourcing, professional conduct, and responsible

engagement with customers, suppliers, and partners.

10. Reporting Violations

Employees and business partners are encouraged to report suspected violations. VAI TECHNOLOGIES prohibits

retaliation against individuals who raise concerns in good faith.

11. Supplier and Business Partner Expectations

VAI TECHNOLOGIES expects suppliers and business partners to maintain similar standards of ethical conduct, including

compliance with laws, prevention of corruption, protection of confidential information, intellectual property protection, and

privacy compliance.