Business Ethics

Sea Oil Public Company Limited and Subsidiaries ("Company"), The Company is committed to conducting its business with integrity and in accordance with the highest ethical standards. It operates with transparency, accountability, and good governance, while taking responsibility for society and the environment. The Company treats all stakeholders equitably and fairly, in line with its Corporate Governance Policy, to support resilient, sustainable, and long-term growth.

To establish a practical standard for conducting business, the Company has adopted a written Code of Business Conduct that serves as a guideline for directors, executives, and employees at all levels. The Code sets out the principles and standards expected in the conduct of business and promotes ethical behavior, integrity, honesty, and respect for human rights across all aspects of the Company's operations.

The Company requires all directors, executives, and employees to adhere to the Code of Business Conduct and to perform their duties with responsibility, professionalism, and accountability. In carrying out their responsibilities, they are expected to treat all stakeholder groups fairly, equitably, and with due respect, while upholding the highest standards of business ethics and corporate governance.

Through these principles and practices, the Company seeks to ensure that its business operations are conducted in alignment with its corporate vision and values, while creating long-term value for stakeholders and supporting sustainable and continuous growth.

For additional information on the Code of Conduct, please refer to Company's website.

Targets and Performance

Targets

• Maintain certification as a member of the Thai Private Sector Collective Action Against Corruption (CAC)
• Achieve 100% completion of corporate governance, anti-corruption, and Code of Business Conduct training and assessments for employees
• Maintain zero complaints relating to corporate governance, ethics and business conduct, and corruption

Performance in 2025

• Maintain certification as a member of the Thai Private Sector Collective Action Against Corruption (CAC)
• Achieve 100% completion of corporate governance, anti-corruption, and Code of Business Conduct training and assessments for employees
• Maintain zero complaints relating to corporate governance, ethics and business conduct and corruption

Compliance with Laws, Regulations and Applicable Requirements

1. Directors, executives, and employees must comply with all applicable laws, regulations, rules, and requirements, including those prescribed by the Stock Exchange of Thailand (SET), the Securities and Exchange Commission (SEC), and other relevant regulatory authorities
2. Directors, executives, and employees must adhere to all legal and regulatory requirements applicable to the jurisdictions in which the Company operates, both domestically and internationally
3. Directors, executives, and employees are required to comply with the Company's Corporate Governance Policy, Code of Business Conduct, and other relevant internal policies and procedures
4. Directors and executives are responsible for regularly reviewing compliance with applicable laws, regulations, and the Company's policies and procedures, as well as promoting and supporting a strong culture of compliance throughout the organization
5. Subsidiaries, affiliates, business representatives, and business partners under the Company's control or influence are expected to acknowledge and adhere to the principles and requirements set forth in the Company's Code of Conduct

Corporate Governance Compliance Monitoring

The Company assigns the Board of Directors the role of establishing corporate governance policies and overseeing compliance with such policies. The Board is responsible for reviewing the Corporate Governance Policy, Code of Business Conduct, Board Charter, and Board Committee Charters on at least an annual basis to ensure that these policies and guidelines remain appropriate and aligned with current business operations and prevailing circumstances.

In 2025, the Company adopted the Corporate Governance Code for Listed Companies 2017 (CG Code) issued by the Securities and Exchange Commission (SEC), as well as the Guidelines on Good Practice for Boards of Directors in Setting Business Strategy for Sustainability issued by the Thai Institute of Directors (Thai IOD), as a framework to enhance corporate governance practices in accordance with the Company's business context. This adoption aims to ensure that the Company's operations are aligned with the current business environment, while strengthening governance effectiveness and driving the Company toward tangible and sustainable business development.

Conflict of Interest Management Policy

The Company has established good governance guidelines to demonstrate its commitment to conducting business with transparency, accountability, and verifiability. These principles are considered a responsibility of directors, executives, employees, as well as related parties and persons with relationships to the Company. All such individuals are required to avoid becoming involved in situations where they may have an interest or be considered related parties in any matter that could potentially give rise to a conflict of interest. Accordingly, the Company has established the following guidelines and practices to ensure proper conduct and prevent conflicts of interest:

1. Directors, members of the Audit Committee, and executives are required to carefully consider any potential conflicts of interest in relation to related-party transactions, in accordance with the Securities and Exchange Act, applicable regulations, notifications, orders, and requirements of the Stock Exchange of Thailand. Such consideration must be conducted with due care, integrity, and good faith, and with primary regard to the best interests of the Company
2. Not engage in any activity that constitutes or may constitute competition with the Company's business
3. Related parties of the Company are prohibited from seeking personal benefits in transactions with the Company. This includes, but is not limited to, engaging in any activity for the sale of goods or services to the Company for personal gain. In cases where such transactions are necessary, they must be conducted on an arm's length basis, under normal commercial terms comparable to those applied to general third-party transactions, and without any undue bargaining advantage arising from directors, executives, or related persons. In all cases, relevant documentation and full disclosure of information must be provided to the Company
4. Any action or circumstance is suspected to constitute, or may potentially result in, a conflict of interest with the Company, the relevant individual is required to submit a written disclosure report of the suspected transaction or situation using the prescribed form. Such disclosure must be submitted through the respective line of supervision and forwarded to the Corporate Governance and Company Secretary Office for further consideration. The matter will then be reviewed to determine whether a conflict of interest exists and to define the appropriate course of action in accordance with the Company's policies and procedures

Equitable Treatment of Shareholders

The Company encourages shareholders to exercise their fundamental rights and is committed to conducting its business in a manner that supports continuous and sustainable growth. This approach is aimed at delivering appropriate and sustainable returns to shareholders over the long term. The Company has established the following guidelines:

1. Perform duties with honesty, integrity, and transparency, and treat all shareholders fairly and equally
2. Provide shareholders who are unable to attend the meeting in person with the opportunity to appoint an independent director or another person as their proxy to attend the meeting and vote on their behalf
3. Provide shareholders with the opportunity to propose agenda items for inclusion in the shareholders' meeting and to nominate candidates for election as directors in advance of the meeting, in accordance with the Company's established criteria and procedures
4. The Company shall not add any agenda items to the shareholders' meeting that have not been previously disclosed to shareholders in advance, unless it is necessary
5. The Board of Directors provides shareholders with the opportunity to vote for the appointment of directors on an individual basis and encourages the use of voting ballots to enhance transparency and ensure verifiability
6. The Board of Directors has established measures to prevent the improper use of insider information (insider trading) by relevant persons, including directors, executives, employees, and workers, as well as their spouses and minor children who may have access to such information. These measures are implemented to ensure fairness and equality among shareholders. The Company has also defined penalties for any unauthorized disclosure of the Company's information
7. Report the Company's financial position, including future outlook, to shareholders in a fair, regular, complete, and accurate manner

The Company is committed to conducting its business with integrity and in accordance with the principles of good corporate governance. It upholds good governance, business ethics, and moral standards in its operations, while maintaining accountability to society and all stakeholders. The Company conducts its business with transparency, fairness, and verifiability.

The Company has zero tolerance for all forms of corruption, covering all business activities and transactions in every country and all related entities. Directors, executives, and employees of SEAOIL Public Company Limited and its subsidiaries are required to strictly comply with the Anti-Corruption Policy and are prohibited from engaging in any form of corruption, whether directly or indirectly.

The Company also supports and encourages its stakeholders, including customers, business partners, contractors, and subcontractors, to adopt and adhere to the same anti-corruption standards and practices as the Company.

The Company has a policy of not demoting, penalizing, or taking any adverse action against employees who refuse to engage in corruption, even if such refusal results in the Company losing business opportunities.

For additional information on the Anti-Corruption Policy, please refer to Company's website.

Anti-Corruption Structure

Board of Directors

The Board of Directors is responsible for establishing the Anti-Corruption Policy and defining the overall direction of the Company's anti-corruption efforts. The Board monitors the effective implementation of the Policy across the organization to ensure that business operations are conducted in accordance with good corporate governance principles and business ethics.

Audit and Risk Management Committee

The Audit and Risk Management Committee is responsible for reviewing and overseeing the Company's and its subsidiaries' operating processes to ensure compliance with the Anti-Corruption Policy and related anti-corruption measures.

• To ensure that an appropriate internal control system and corruption risk management framework are in place
• To receive complaints or whistleblowing reports relating to corruption involving directors, executives, or employees
• To consider, investigate, and monitor the handling of complaints or allegations related to corruption
• To propose appropriate remedial actions and disciplinary measures in coordination with the Board of Directors
• To report on anti-corruption performance to the Board of Directors on a quarterly basis

Anti-Corruption Working Team

The Company has appointed an Anti-Corruption Working Team to support the implementation of its Anti-Corruption Policy and to drive its operations in accordance with the requirements of the Thai Private Sector Collective Action Against Corruption (CAC).

Roles and Responsibilities

• To assess corruption-related risks in each operational process of the Company and its subsidiaries
• To review and ensure that operational practices are aligned with the Anti-Corruption Policy
• To communicate the Anti-Corruption Policy to employees at all levels of the organization and ensure consistent adherence to its principles and practices
• To report performance results to Audit and Risk Management Committee on a quarterly basis

Guidelines on Anti-Corruption Practices

1. Not engage in any conduct that may be perceived as corruption, including offering or accepting bribes to or from government officials, private sector parties, or other relevant beneficialry for the purpose of obtaining or retaining business, gaining competitive advantage, or securing benefits for the Company, oneself, or related persons
2. Not neglect or ignore any suspected acts of corruption related to the Company, and consider it a duty to report such matters to a supervisor or the responsible person, as well as to fully cooperate in any investigation of the facts
3. The Company shall ensure fairness and provide protection to individuals who refuse to engage in corruption or who report suspected corruption to the Company, in accordance with the whistleblowing protection measures established for complainants and persons who cooperate in reporting corruption
4. Any person found to have engaged in corruption shall be deemed to have committed a breach of the Company's Code of Business Conduct and shall be subject to disciplinary action in accordance with the Company's employee regulations. In addition, such actions may also result in legal penalties if they constitute violations of applicable laws
5. The Company recognizes the importance of communicating, providing knowledge, and ensuring understanding among individuals who perform duties related to the Company or who may have an impact on the Company, regarding compliance with the Anti-Corruption Policy
6. The Company conducts corruption risk assessments and has established robust, appropriate, and effective internal control measures and systems, covering operational controls, environmental controls, and financial controls, including accounting records and document retention
7. The Company has established internal control review processes covering key operational activities, including sales, marketing, procurement, financial recording procedures, accounting processes and the retention of the Company's data and documents. The results of such reviews are regularly reported to senior management, the Audit and Risk Management Committee, and the Board of Directors for acknowledgment
8. The Company has established human resource management processes that reflect its commitment to anti-corruption measures throughout all stages, including recruitment, training and development, performance evaluation, compensation, and promotion

The Company has established a Whistleblowing Policy to provide opportunities for employees and all stakeholder groups, both internal and external, to raise concerns or report complaints regarding non-compliant practices or to submit information related to illegal acts, violations of business ethics, human rights infringements, or behaviors that may indicate corruption by directors, executives, or employees within the organization. The Company has defined channels for whistleblowing and complaint reporting, as well as procedures for handling received reports. In addition, the Company has established measures to ensure the protection and confidentiality of whistleblowers and complainants, ensuring that all reports are handled fairly, appropriately, and effectively.

For additional information on the Whistleblowing Policy, please refer to Company's website.

Whistleblowing Channels

The Company has established the following channels for whistleblowing and complaint reporting:

By Post
Chairman of Board of Directors, Chairman of the Audit and Risk Management Committee, or President and Chief Executive Officer
Sea Oil Public Company Limited
88 Soi Bangna-Trad 30 Debaratna Road, Bangna Tai, Bangna, Bangkok 10260

By Email
Chairman of the Audit and Risk Management: ruth@banomyong.com
President and Chief Executive Officer: neeracha@seaoilthailand.com
Compliance and Company Secretary: compliance@seaoilthailand.com

By Website
https://www.seaoilthailand.com/th/corporate-governance/declaration-of-anti-corruption

Complaints may be addressed to the following recipients:

• Chairman of the Audit and Risk Management
• President and Chief Executive Officer
• Compliance and Company Secretary

In addition to the above whistleblowing and complaint channels, employees may also seek clarification or submit complaints if they observe any actions suspected of violating or failing to comply with the Code of Conduct through the following channels:

• President and Chief Executive Officer
• Compliance and Company Secretary manager
• Any trusted supervisor at all levels

Process for Whistleblowing Reports and Complaints, and Disciplinary Measures

1. Receipt of Reports and Collection of Relevant Facts

The recipients of complaints under the established channels acknowledge receipt of the complaint and, where the whistleblower has consented to disclose their identity, notify the whistleblower of such receipt. The recipients then gather relevant facts and evidence and escalate the matter to Audit and Risk Management Committee for further consideration. The Audit and Risk Management Committee shall assign the Internal Audit function or appoint an investigation committee, as appropriate, to review and investigate the facts. The Committee will ensure that the progress and outcomes of the investigation are periodically communicated to the whistleblower or complainant, where applicable.

2. Investigation of Facts

The assigned investigator or the appointed investigation committee shall conduct the fact-finding process, analyze and evaluate all relevant information, and assess the potential impact, as well as determine appropriate procedures and actions for each case. The investigation findings shall be reported to Audit and Risk Management Committee for review and consideration. If the investigation identifies sufficient evidence or reasonable grounds to believe that the accused person has engaged in corruption, the Company shall ensure that the accused is informed of the allegations and is given the opportunity to defend themselves by providing additional information or evidence demonstrating non-involvement in the alleged misconduct. If the accused is found to have committed the wrongdoing, such conduct—whether by directors, executives, or employees—shall be deemed a disciplinary violation and subject to penalties in accordance with the Company's regulations. In cases where the misconduct constitutes a violation of applicable laws, the offender may also be subject to legal sanctions. All disciplinary decisions of Audit and Risk Management Committee shall be considered final under the Company's procedures.

3. Conclusion and Reporting

The assigned investigator, Internal Audit function, or the appointed investigation committee is responsible for preparing a summary report of all whistleblowing reports received by the Company and its subsidiaries. In cases where the matter has been considered and/or is under investigation, including the review of evidence and facts, the findings shall be reported to Audit and Risk Management Committee on a case-by-case basis. The Audit and Risk Management Committee shall subsequently report the outcomes to the Board of Directors for acknowledgment.

Related Policies and Documents

Code of Conduct Training

New Employees

The Company requires all new employees to undergo training and assessment on Code of Conduct. The training program covers key topics including good corporate governance principles, the Code of Business Conduct, the Anti-Corruption Policy, human rights principles, and the Personal Data Protection Act (PDPA). This mandatory training is designed to ensure that new employees understand and comply with the Company's ethical standards, policies, and relevant legal requirements from the beginning of their employment. The Company also evaluates employees' understanding to ensure effective implementation and continuous adherence to these principles.

In 2025, 100% of newly hired employees completed Code of Conduct training program and successfully passed the related assessment.

Current Employees

The Company requires all employees to complete refresher training and assessments covering Code of Conduct, Anti-Corruption Policy, Human Rights Policy, Personal Data Protection Act (PDPA), as well as the Company's rules, regulations, and procedures. This refresher training program is incorporated into the Company's Training Master Plan to ensure that employees at all levels regularly review and reinforce their knowledge and understanding of these important topics. The training is conducted at least once a year to promote continuous compliance and adherence to the Company's governance, ethical, and regulatory requirements.

In 2025, 100% of current employees completed Code of Conduct training program and successfully passed the related assessment.