GLP operates its business in accordance with the highest ethical standards and according to all applicable laws. The foundation of our success is in the trust and confidence that we establish with our customers, employees, shareholders, investors, suppliers, and communities. This trust and confidence is earned by providing quality products and services through efficient, ethical and responsible business practices.

GLP has adopted a Code of Ethics and Standards of Business Conduct which describes our company values and principles. The Code of Ethics and Standards of Business Conduct is our guide to the GLP value system of ethical conduct. It helps us make good decisions by applying values and principles to specific issues that arise in the workplace. Used in conjunction with the company’s published policies and practices, the Code of Ethics and Standards of Business Conduct will help each of GLP employees apply our institutional and personal values of honesty, fairness, and integrity to everything we do at GLP.

Among several rules, we highlight the following in our Code of Ethics and Standards of Business Conduct applicable to all employees across the globe:

• In no event, no value is allowed for improper contribution to an Agency and Public Official Agent, as well as cash payments to service providers.
• No supplier, service provider and business partner should have (i) a relationship with an Agency or Public Official, which should be construed as a potential undue favor to GLP or the Agency or Public Official; and (ii) criminal actions or related to failure to comply with anti-corruption legislation.
• No facilitation of payments is allowed. Facilitation payments are defined as any payments or consideration in contravention of any applicable laws or regulations and/or which are not formalized in writing.
• When offered a business courtesy or before giving a business courtesy, employees are expected to use good business judgment in determining whether it is appropriate to accept/give the courtesy according to GLP relevant company rules (including check whether the business courtesy does not violate any law or regulation);
• Employees cannot (i) ask for a business courtesy; and (ii) use GLP position as a means of obtaining business courtesies, such as personal discounts or credits on products, services, or other items.
• Procurement decisions must be made on the basis of quality, service, price, delivery, best value, and other similar factors.

GLP operates its business in accordance with the highest ethical standards and in accordance with all applicable laws. The foundation of our success is in the trust and confidence that we establish with our customers, employees, shareholders, investors, suppliers, and communities. This trust and confidence is earned by providing quality products and services through efficient, ethical and responsible business practices. Employees of GLP are expected to conduct themselves with integrity, impartiality and honesty. GLP's success is dependent on each member's commitment to these enduring values.

Inquiries and Reports

If you have any questions about GLP's code of conduct policy or if you have any concerns, you are encouraged to share these concerns. You can do so by:

• Sending an e-mail to ethics@glp.com or
• Calling +86 (21) 6105 5808 or
• Filing a report through third party reporting channel

Confidentiality

To the extent that it is lawful and the investigative process reasonably allows, all reports received and the identity of the reporting party will be handled in strict confidence. However, please note that a reporting party may be requested to make a statement to the relevant law enforcement authority(ies) or otherwise give evidence to facilitate the investigative process and/or to the extent otherwise required by law.

GLP is committed to ensuring the highest standards of corporate governance as a means of enhancing corporate performance and accountability. To demonstrate its commitment towards excellence in corporate governance, the Company has established a series of well-defined policies and processes to protect key stakeholder interests.

Management of the Company recognize the importance of strong corporate governance and the maintenance of high standards of accountability to our shareholders, and remain firmly committed to seeing that those standards are satisfied through an evolving suite of governance practices that are woven into the fabric of the Company’s business.

The Company continually reviews and refines its processes in light of best practice, consistent with the needs and circumstances of the Group.

GLP is committed to strengthening and adopting necessary procedures to manage conflicts of interest within the business aimed at enhancing the protection of GLP Pte. Ltd. and its stakeholders.

The amended Related Party Transaction (“RPT”) governance policy regulates RPTs across the Group. RPTs at GLP Pte. Ltd. and/or its subsidiaries (“GLP Pte. Group”) will be managed by a Related Party Transaction Committee (“RPTC”) that will report to the independent chairman of the Audit Committee.

The RPTC is responsible for reviewing and approving applicable financial transactions or arrangements, or series of similar financial transactions or arrangements, including indebtedness, loans and guarantees of indebtedness, in each case over US$50,000,000 in value involving the GLP Pte. Group and in which GLP Holdings L.P. and/or GLP Bidco and/or their respective subsidiaries (excluding any member of the GLP Pte. Group) (the “Parent Group”) have a direct or indirect material interest (and in each excluding for the avoidance of doubt distributions, dividends, returns of capital or equivalent by the GLP Pte. Group and other matters arising in the ordinary course of business) (each a “GLP Pte Group RPT”).

In determining whether to approve a GLP Pte. Group RPT, the RPTC shall take the following considerations into account, along with any other factors that it deems appropriate:  

• the best interests of the GLP Pte. Group and its stakeholders;
• the potential benefits to the GLP Pte. Group, including to the credit quality of the GLP Pte. Group;
• the impact of the GLP Pte. Group RPT on the ability of the GLP Pte. Group to continue to comply in all respects with the terms of its financings, including its financial covenants, and on other relevant credit metrics used by rating agencies to assess GLP Pte. Ltd.’s credit worthiness;
• whether the terms of the GLP Pte. Group RPT are arm’s length and no less favorable to the GLP Pte. Group than terms that could have been reached with an unrelated third party; and
• any other information regarding the GLP Pte. Group RPT or any party to it that would be material to the consideration of the RPTC or to creditors of GLP Pte. Ltd. in light of the circumstances of the particular transaction.

The RPTC will only approve a GLP Pte. Group RPT if it determines in good faith that, under all of the circumstances, the GLP Pte. Group RPT is in the best interests of the GLP Pte. Group.