Supplier Code of Conduct

Updated as of 15 April 2026

This Code of Conduct (“Code”) applies to all current and future suppliers of SPH Media Limited and/or its related entities, affiliates and subsidiaries, and their respective successors-in-title (individually and collectively, "SPH Media") and conveys the expectation for suppliers to adhere to the highest ethical standards when conducting business.

A supplier refers to any individual or business that supplies goods or services to any part of SPH Media’s business, and includes all persons employed by the supplier, as well as sub-contractors and service providers engaged by the supplier.

It is the responsibility of the supplier to ensure its employees and representatives understand and comply with this Code. Failure to adhere to the Code may be grounds for SPH Media to terminate the supplier relationship, depending on the circumstances and the seriousness of the violation.

1. Compliance with Laws and Regulations

Suppliers undertake that they will comply with all laws and regulations that apply to them in the countries that their operations are based, and where they provide goods and services to SPH Media.

2. Ethical Dealings

Suppliers must conduct all business dealings with integrity, transparency, and honesty. Any form of fraud, bribery, corruption, extortion, or attempt to improperly influence SPH Media’s procurement or tender process, employees or representatives is strictly prohibited.

Suppliers must not engage in any anti-competitive conduct, including but not limited to bid rigging, price-fixing, market sharing or collusion. Suppliers must participate in SPH Media’s procurement and tender process independently and are strictly prohibited from coordinating bids, entering into unauthorized arrangements with competitors or exchanging commercially sensitive information (such as pricing, margins, or bidding strategies) with any other party prior to or during the procurement or tender process. To ensure fair competition, companies sharing directors, shareholders, key management personnel or controlling interests must not participate in the same procurements or tenders. Multiple bids submitted by related parties, affiliates, subcontractors, or proxies to manipulate the procurement or tender outcome are strictly prohibited unless expressly disclosed as a legitimate consortium bid and approved by SPH Media in writing.

Suppliers must avoid and immediately disclose any actual, perceived, or potential conflicts of interest. Suppliers must not offer gifts, entertainment, inducements, favors or rewards to any SPH Media employee or representative that could influence, or appear to influence, the procurement or tender process or business decisions.

SPH Media reserves the right to audit and verify compliance with these provisions at any time and Suppliers shall provide such assistance as SPH Media may reasonably require. Suppliers found in breach of these provisions or engaging in any other unethical conduct may be immediately disqualified from ongoing procurements or tenders, have existing contracts terminated without compensation and without prejudice to any other right or remedy of SPH Media, and be suspended or blacklisted from future dealings with SPH Media.

3. Confidentiality

Suppliers must respect SPH Media’s intellectual property, trade secrets and all other confidential, proprietary or sensitive information, and may not use or disclose any such information except in accordance with the terms of their contract with SPH Media, and for the benefit of SPH Media.

4. Competition / Anti-trust

Suppliers commit to conduct their business in compliance with all competition laws (known as antitrust laws in the U.S.) applicable to them

5. Equality

Suppliers shall apply fair standards in its treatment of all its employees, and this entails not subjecting any employee to discrimination based on race, national origin, ethnicity, religion, gender, age, marital status, sexual orientation, disability, or any other reason. Suppliers will comply with all national laws on wages and working hours as well as international standards regarding child labour and minimum age.

6. Health and Safety

Suppliers are required to provide a safe and healthy working environment for all its employees and are encouraged to have in place policies that are designed to promote the general health of employees and prevent work-related injuries and illness.

7. Environment

Suppliers shall comply strictly with local environmental laws and practices, such as those pertaining to waste disposal, air emissions and pollution. Suppliers must endeavour to minimize the impact of their operations on the environment.

8. Industry Practices

SPH Media will only do business with suppliers that produce, package, store and deliver products in accordance with good manufacturing practices prevailing in their respective industries. Suppliers are expected to provide goods and services that consistently meet required specifications.

9. Personal Data Protection

Suppliers shall comply with the Personal Data Protection Act in Singapore and/or applicable data protection laws in the relevant jurisdiction when collecting, using, disclosing, transferring, storing and/or processing any personal data information that are controlled or owned by SPH Media and to ensure they have equivalent data protection policies and controls in place. In the event of any data breach, Suppliers shall inform SPH Media within 24 hours of discovering the breach.

10. Monitoring

Suppliers are expected to actively monitor their day-to-day management processes with respect to this Code, as may be amended from time to time.

This Code does not create any binding obligations on SPH Media.