Business Ethics and Code of Conduct

Purpose

This Business Ethics and Code of Conduct sets out InTalent Asia’s general expectations relating to professional behaviour, ethical conduct, integrity, and responsible business practices. It is intended to describe the standards of conduct the company seeks to promote across its operations and stakeholder relationships.

InTalent Asia recognises that ethical conduct is fundamental to trust, reputation, and business sustainability. The company seeks to conduct its affairs in a lawful, professional, and responsible manner and expects persons acting on its behalf to uphold appropriate standards of integrity and behaviour.

Scope

This policy applies generally to directors, management, employees, consultants, contractors, temporary personnel, and other persons acting on behalf of InTalent Asia.

Relevant aspects of this policy may also be communicated to suppliers, service providers, agents, and business partners where appropriate.

Policy Statement

InTalent Asia seeks to promote a culture of honesty, professionalism, fairness, accountability, and respect. Persons acting on behalf of the company are generally expected to conduct themselves in a manner that supports lawful business operations, ethical decision making, responsible use of company resources, and respectful engagement with colleagues, candidates, clients, suppliers, and other stakeholders.

Key Governance Principles

InTalent Asia may expect persons acting on its behalf to:

• act honestly and in good faith in business dealings
• avoid conduct that may harm the company’s reputation, operations, or stakeholder trust
• comply with applicable laws, regulations, contractual duties, and company policies relevant to their role
• treat others professionally, respectfully, and fairly
• protect confidential, personal, and commercially sensitive information
• use company assets, systems, and resources responsibly
• disclose and manage conflicts of interest where appropriate
• avoid improper payments, inducements, gifts, or other conduct inconsistent with company standards
• raise genuine concerns regarding suspected misconduct through appropriate channels

Conduct Areas of Focus

01. Professional Behaviour

Persons acting on behalf of InTalent Asia are generally expected to behave professionally, responsibly, and respectfully in internal and external interactions.

02. Integrity in Business Dealings

The company seeks to discourage dishonest, misleading, fraudulent, or improper conduct in relation to sales, recruitment, candidate handling, client engagement, procurement, finance, reporting, or other business activities.

03. Respect in the Workplace

InTalent Asia does not support unlawful discrimination, harassment, bullying, intimidation, or victimisation in its workplace environment.

04. Confidentiality and Information Use

Persons acting on behalf of the company are generally expected to protect confidential information, candidate data, client information, internal records, and business sensitive materials, and to use such information only for proper business purposes.

05. Conflicts of Interest

Actual, potential, or perceived conflicts of interest should be avoided where possible and disclosed through appropriate channels where relevant.

Gifts, Hospitality, and Benefits

Gifts, hospitality, favours, or benefits that may improperly influence, appear to influence, or compromise business judgment should generally be avoided or disclosed as appropriate in line with company standards.

Roles and Responsibilities

01. Leadership

Leadership may support ethical culture, set expectations, and oversee the general application of conduct standards across the business.

02. Managers

Managers may encourage appropriate behaviour within their teams, address conduct concerns, and escalate material issues where necessary.

03. Employees and Representatives

Employees and other persons acting on behalf of InTalent Asia are generally expected to follow applicable conduct standards, act within lawful and professional boundaries, and raise serious concerns where appropriate.

Reporting Concerns

Suspected misconduct, unethical behaviour, serious policy breaches, fraud, conflicts of interest, or other material concerns may be raised through appropriate internal channels or designated company contacts.

InTalent Asia may review such matters and determine any action it considers appropriate, taking into account the seriousness of the issue, available information, confidentiality, legal considerations, and operational practicality.

Monitoring and Review

InTalent Asia may review this policy and related conduct expectations from time to time to support consistency, awareness, and continual improvement in ethical business practices.

Policy Status

TThis policy is intended as a general statement of InTalent Asia’s ethical expectations and conduct standards. It does not form part of any employment contract and does not create guaranteed rights or legally enforceable obligations for any third party, except to the extent required by applicable law.

InTalent Asia may interpret, amend, replace, suspend, or withdraw this policy at any time, subject to applicable legal and regulatory requirements.

Related Standards and Policies

his policy should be read together with the Corporate Governance Policy, Anti Bribery Policy, Supplier Code of Conduct, ESG Policy, Equal Employer Policy, Candidate Privacy Notice, Full Privacy Policy, and other related company policies and notices adopted by InTalent Asia from time to time.

Where relevant, aspects of this policy may also be supported through the company’s broader management, quality, information security, and privacy practices aligned to ISO 9001, ISO 27001, and ISO 27701.

Contact Us

If you have any questions regarding this Business Ethics and Code of Conduct, you may contact:

• By email: legal@intalent.asia