Floatel International Code of Conduct

Floatel International enjoys an invaluable reputation for corporate trustworthiness around the world, based on consistently conducting business with integrity and in compliance with the laws and regulations governing its activities. The Group’s corporate values and commitment to sustainable development are, and will continue to be, reflected, promoted and implemented in policies, decisions and actions.

Scope of Application

The Floatel International Code of Conduct has been adopted to underscore the principles by which the Group conducts its relations with employees, business partners and other stakeholders. It applies to all members of the Board of Directors, and all staff employed by the Group.

The Group encourages suppliers, consultants and other business partners within its sphere of influence
to adopt these principles. In the assessment of potential and current suppliers, the principles described in this document shall be applied.

Business Principles

Legal Compliance

In every country in which it operates, the Floatel Group shall abide by the laws and regulations of thatcountry. In situations where the law does not give guidance, the Group applies its own standards based on its corporate values and culture. In cases of conflict between mandatory law and the principles contained in this code, the law shall prevail.

Relations with Business Partners

The Group’s dealings with its business partners are characterized by fairness. The Group shall not offer customers, potential customers, governments, agencies of governments, or any representatives of such entities, any rewards or benefits in violation of either applicable laws or reasonable and generally accepted business practices. Group employees must not accept payments, gifts, or other kinds of reimbursement from a third party that could affect or appear to affect their objectivity in their business decisions.

Integrity

Individually and collectively, our personal integrity supports the honest use of time, funds and propertyin ethical dealing with employees and others. Business needs take priority in the allocation of our time at work. Use of Group time and property is for business purposes only, unless otherwise authorized by management. We consciously set high standards of courtesy, professionalism, respectfulness and honesty in our interactions with our customers, suppliers, employees and the community.

Privacy of communications

Floatel will abide by all applicable legal requirements protecting the privacy of a customer’s or employee’s personal information. We must all ensure that appropriate processes and systems are in
place to safeguard access to this type of information. We respect customer and employee related information and protect its security, confidentiality and integrity. All customer and employee personal information is confidential and may not be disclosed except as permitted by law and applicable regulations. Access to customer and employee personal information is strictly controlled on a “need to know” basis and is used for legitimate business purposes only.

Accounting and Reporting

All financial transactions by the Group must be reported in accordance with generally accepted accounting practices, and accounting records must show the nature of all transactions in a correct and non-misleading manner. The Group will provide disclosure that is open, truthful, relevant, comprehensible and timely.

Conflicts of Interest

Employees and members of the Boards of Directors of the Group shall conduct their private and other external activities and financial interests in a manner that does not conflict or appear to conflict with the interests of the Group. Should such a conflict of interest arise, it must be reported immediately by the person subject to the conflict to his/her immediate supervisor.

Political Involvement

The Group observes neutrality with regard to political parties and candidates. Neither the name nor the assets of Floatel shall be used to promote the interests of political parties or candidates.

Shareholder Communications

The Group encourages an ongoing dialogue with its shareholders.

Environmental Principles

Resource Efficiency

The Group assets and services are designed in such a way that energy and raw materials are used efficiently, and waste and residual products are minimized over the life cycles.

Precautionary Principle

Floatel supports the precautionary principle by avoiding materials and methods posing environmental and health risks as far as reasonably practicable.

Environmental Performance

The Group routinely audits, follows up and reports on its environmental performance, with particular emphasis on evaluating the potential risks of present and future assets and operations.

Human Rights and Workplace Practices

Human Rights

Within its sphere of influence, Floatel supports and respects and commits to the principles set out in the international recognized social and ethical standards for protection of human rights and ensures that it is not complicit in human rights abuses.

Non-Discrimination

The Group hires and treats its employees in a manner that does not discriminate with regard to gender, race, religion, age, disability, sexual orientation, nationality, political opinion, union affiliation, social or ethnic origin. Workplace diversity at all levels is encouraged.

Labour

No form of forced, compulsory or child labour is tolerated within the Group. The minimum employment age is the age of completion of compulsory school. Freedom of association and the right to collective bargaining and agreements shall be respected in all Floatel operations.

Work Environment

The necessary conditions for a safe and healthy work environment shall be provided for all Floatel employees.

Work Environment

The necessary conditions for a safe and healthy work environment shall be provided for all Floatel
employees. Responsibility of Managers and Employees It is the responsibility of Floatel managers to communicate and demonstrate the content as well as the
spirit of this document within their organizations, and to encourage employees to reveal behaviour that may be non-compliant with these principles. Explicit or implicit approval of questionable actions will not be tolerated.

Reports of violations of this code may be done anonymously and confidentially to the chairman of the audit committee. Persons reporting violations in good faith will not be subject to retaliation.

This Code of Conduct will be promptly and consistently enforced. Failure to comply with its provisions can result in disciplinary action.

February 27, 2015