30 June 2022

To our Stakeholders:

I am pleased to confirm that SEATOBAG Pte Ltd reaffirms its support of the Ten Principles of the United Nations Global Comp[act in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Albert Tay
Managing Director & Founder

The Management of SEATOBAG PTE. LTD. (“SEATOBAG®” or “The Company”) has adopted the following Equal Employment and Human Rights Policy to apply to all employees. This Policy is intended to direct executives, managers and employees on understanding the need to respect others and succeed together. SEATOBAG®’s Equal Employment and Human Rights Policy aligns with our Code of Conduct.

SEATOBAG® greatest assets is our People, we are committed to equal opportunity, fairness, respect and inclusion and do not tolerate discrimination or harassment. It is the policy of SEATOBAG® to recruit, hire and advance qualified people based on job-related standards, education, training and related work experience and to offer equal opportunities without discrimination. We recognise the importance of maintaining and promoting the fundamental human rights of employees by operating under programs and policies that:
• Promote a workplace free of discrimination and harassment
• Prohibit child labour, forced labour, and human trafficking
• Provide fair and equitable wages, benefits, and other conditions of employment in accordance with local laws
• Provide humane and safe working conditions, including safe housing conditions as applicable
• Recognise employees’ rights to freedom of association and collective bargaining

Failure to adhere to the following SEATOBAG® standards of conduct intended to respect the human rights of our employees may result in disciplinary action, up to and including termination of employment.

i. Forced Labour and Human Trafficking
SEATOBAG® will not use any forms of forced or involuntary labour, including indenture labour, bonded labour, slave labour and any form of human trafficking. No use of physical punishment or threats of violence or other forms of physical, sexual, psychological or verbal abuse as method of discipline or control will be tolerated in the workplace.

ii. Child Labour
Child labour is work that deprives children of their childhood, their potential and their dignity, and that is harmful to their physical and mental development. The minimum age of employment for all employees in SEATOBAG® is 18 years old. No workers younger than 16 years old may be employed unless it is company approved, short-term internships, apprenticeships or work experience programs, but they are never permitted to carry out work that may threaten their health and safety or hinder their education or vocational orientation and training.

iii. Safe and Healthy Working Conditions
SEATOBAG® provides and maintains a safe and healthy workplace and complies with applicable safety and health laws, regulations, and internal requirements. Safety in the workplace is a primary concern to SEATOBAG®. We are dedicated to ensuring a safe workplace by minimising the risk of accidents, injury and exposure to health risks. We are committed to engaging with our employees to continually improve health and safety in our workplaces, including the identification of hazards and remediation of health and safety issues.

iv. Freedom of Association and Collective Bargaining
SEATOBAG® respects all employees’ right to advocate for and protect work right, therefore without the management interference and without fear of harassment, intimidation or reprisal, the Company guarantees the freedom of association and the right of collective bargaining. The Company does not place employees at disadvantages just because they joined, formed or engaged in a labour union, etc.

v. Working Hours, Wages, and Benefits
SEATOBAG® compensates employees competitively relative to the industry and complies with all applicable local laws governing the payment of wages and benefits to employees.

Employees or job applicants may seek assistance if they believe they have been subject to unlawful employment discrimination practices. Each of us must support an individual’s right, without fear of retaliation and to oppose employment practices which are perceived as discrimination in the workplace. Employees who feel the need may reach out to the HR manager / director directly without prejudice.

All employees are made aware as well as provided in their Employee Handbook that he/she can report any incidence of abuse, harassment and or discrimination to their supervisor or to the management and or HR manager/director. Here is the procedures:

Employees Responsibility:
If employees suspect or feel they are being discriminated against or harassed, they can promptly take the following steps:
a. Place the offending person upon notice and request that the offensive behaviour stop.
b. Any employee, who may be uncomfortable in performing the above step, or in instances where the behaviour continues, should immediately notify their supervisor, requesting that a written record be made of the alleged offence and the efforts made to solve the problem. The report will cite dates, times, places, witnesses and be signed by the complainant to facilitate the investigation process. If the supervisor is the individual committing the alleged offence, such conduct will be reported tothe HR Manager / Director. Due to the personal nature of this type of complaint, if an employee feels uncomfortable speaking to their supervisor, he or she may report the alleged activity to the HR Manager/ Director with the understanding that whomever they speak to will advise the employee’s immediate supervisor, unless that supervisor is the subject of the complaint. Employees who witness or become aware of any incident of possible discrimination or harassment towards another employee can report the incident immediately to their supervisor. The “victim” does not have to be the person discriminated against or harassed but could be anyone affected by the offensive behaviour.

Management Responsibility:
Supervisors or managers, who observe, experience or are told of any incidents or alleged incidents of discrimination or harassment must immediately report them directly to the HR Manager / Director. The initial report will be followed by a written report documenting the incident within one working day. Supervisors will review and discuss this policy with new employees during the onset of their employment or post and provide them with a copy for their personal reference.

The Company takes complaints of discrimination or harassment seriously. Any complaint will be investigated promptly, impartially, and discreetly. All investigations will be completely documented. Upon completion of the investigation, the appropriate parties will be notified of the findings. Any employee found to have engaged in discrimination or harassment will be subject to appropriate disciplinary action, this may include warning, transfer, counselling, demotion or dismissal, depending upon the circumstances.

Reports of discrimination or harassment will be kept confidential to the extent possible, consistent with the need for a thorough investigation. SEATOBAG® will not retaliate or take any form of reprisal against any victim of or witness to discrimination or harassment expressed in good faith. Any employee who intentionally initiates a false allegation, retaliates against another member or witness because of a complaint of discrimination or harassment, or because of participation in any investigation, will be subjected to disciplinary action, up to and including termination.

For FY2021, the management is pleased to report there is no incident nor reports of any violations of Human Rights of employees as well as business associates of SEATOBAG.

SEATOBAG has written policy on the following principles:

i. Forced Labour and Human Trafficking
SEATOBAG® will not use any forms of forced or involuntary labour, including indentured
labour, bonded labour, slave labour and any form of human trafficking. No use of physical punishment or threats of violence or other forms of physical, sexual, psychological or verbal abuse as a method of discipline or control will be tolerated in the workplace.

ii. Child Labour
Child labour is work that deprives children of their childhood, their potential and their dignity, and that is harmful to their physical and mental development. The minimum age of employment for all employees in SEATOBAG® is 18 years old. No workers younger than 16 years old may be employed unless it is company approved, short-term internships, apprenticeships or work experience programs, but they are never permitted to carry out work that may threaten their health and safety or hinder their education or vocational orientation and training.

iii. Safe and Healthy Working Conditions
SEATOBAG® provides and maintains a safe and healthy workplace and complies with applicable safety and health laws, regulations, and internal requirements. Safety in the workplace is a primary concern to SEATOBAG®. We are dedicated to ensuring a safe workplace by minimizing the risk of accidents, injury and exposure to health risks. We are committed to engaging with our employees to continually improve health and safety in our workplaces, including the identification of hazards and remediation of health and safety issues.

iv. Freedom of Association and Collective Bargaining
SEATOBAG® respects all employees’ right to advocate for and protect workers rights, therefore without the management interference and without fear of harassment, intimidation or reprisal, the Company guarantees the freedom of association and the right to collective bargaining. The Company does not place employees at a disadvantage just because they joined, formed or engaged in a labour union, etc.

v. Working Hours, Wages, and Benefits
SEATOBAG® compensates employees competitively relative to the industry and complies with all applicable local laws governing the payment of wages and benefits to employees.

The policy is clearly printed and made known to all employees in their Employee Handbook as well as elaborated during their induction upon joining the company as new employee.

Employees or job applicants may seek assistance if they believe they have been subject to unlawful employment discrimination practices. Each of us must support an individual’s right, without fear of retaliation and to oppose employment practices which are perceived as discrimination in the workplace. Employees who feel the need may reach out to the HR manager / director directly without prejudice.

The Company places great emphasis on employee performance. The criteria for the evaluation during performance appraisal shall be based on several factors such as:
• Ability to perform on assigned duties;
• Compliance with Company’s rules and policies;
• Positive Attitude towards job and the Company;
• Attendance;
• Productivity & Efficiency.

Performance appraisal will be carried out at least once a year. Any salary increment will depend on the company overall business performance as well as merits of Employee's performance within the guidelines lay down by the Company.

During the appraisal, Employees will have the opportunities to discuss their past performance with the immediate supervisor and to set goals and objectives that will be reviewed in the future appraisal.

The way we treat our employees is fundamental to the way we want to do business, and our employees are essential to the success of SEATOBAG®. This begins with ensuring respect for internationally recognised human rights and labour standards in all our workplaces. We are committed to ensure that all our employees will be treated fairly in a safe and healthy working environment, and we strive to create a working environment where each employee feels valued and can prosper. We operate in accordance with international frameworks and conventions from the UN, ILO, as well as in compliance with local legislation where we operate. The COVID-19 pandemic did not lead to any SEATOBAG® employee losing their job. All new employees are provided with our Employee Handbook, which includes details on the company’s policies and procedures related to employment benefits, company regulations as well as code of business conduct. We have clear policies in place stating that we do not accept discrimination, and we have a whistleblower system with a range of options for our employees to communicate grievances.

In FY2021, we had a total of eight (8) new hires bringing our total staff strength to nine (9) persons. We hire based on merit and skills across different age groups, and believe that age diversity is important in the workplace as each generation brings with them unique skillsets and helps to strengthen the company as a whole. Hiring older workers also provides us with traditional skills that help to reach different types of customers more effectively.

In FY2021, 37.5% of our new hires were under 30 years old, 12.5% were between 30-50 years old and 50% were above 50 years old. 67% of our employees also comprise of females, and females make up 25% of our senior management roles.

Since our inception in 2018, SEATOBAG® is motivated to making a positive difference to our food sources, particularly in achieving consistency in quality and quantity, as well as making it commercially sustainable for all partners in the supply chain. We mission ourselves to develop feasible solutions to address the growing levels of food insecurity and issues surrounding food safety, right at the beginning of the supply chain or food source.

Through microbiome and genomic studies, we have developed our proprietary postbiotic, biocrobeX™ (biologics of microbes with multiplier effects) to formulate our Miiiome™ Aqua Feed (fermented) and Miiiome™ Biosphere Farming System. SEATOBAG® developed its range of Miiiome™ Aqua Feed (fermented) with the fundamental objective of improving the gut health of fish, and concurrently introduced high density polyethylene (“HDPE”) cages for healthier fish farming to the fish farm located in Pulau Kukup, Johor, Malaysia. This strategic collaboration with the fish farm allowed SEATOBAG® to refine its formulation of Miiiome™ Aqua Feed with biocrobeX™ (biologics of microbes with multiplier effects) and rolled out its aquaculture production system progressively with the aim of assisting the fish farmers to overcome their challenges. This includes confronting the key challenge of the high mortality rate of fish which impacts the livelihoods of fish farmers. The reduction in the mortality rate and positive results such as improved overall health of the fish, along with desirable traits, especially in the texture and taste of the fish after cooking, spurred SEATOBAG® to explore other applications of biocrobeX™.

biocrobeX™ postbiotic has been successfully applied in the downstream value chain, specifically in the cleaning (gutting of fish) and packaging process, where it has shown to maintain the freshness and extend the shelf life of the blast frozen seafood products. LACTOSEAFOOD® was launched in 2019, enabling the production of healthier fish and nutrient-rich seafood from the waters of Kukup. The seafood products are currently marketed and sold under its proprietary brand ‘LACTOSEAFOOD®’ through retail outlets in Johor and Singapore, as well as e-commerce platforms.

As the seafood products met the nutritional criteria laid out by the Health Promotion Board of Singapore, LACTOSEAFOOD® is awarded the Healthier Choice Symbol (“HCS”). LACTOSEAFOOD® is also recognised by the WWF-Malaysia (“WWF”) as an ‘Aquaculture Improvement Projects’ (“AIP”) partner effective 26 January 2022. SEATOBAG® is continuing with new innovative applications beyond aquaculture through further research and development to maximise the potential of its proprietary postbiotic, biocrobeX™. One of the immediate applications is using the discarded fish guts from the fish farm to produce postbiotic fertilisers for plants.

Surprisingly, LACTOSEAFOOD® also had a beneficial impact on the surrounding environment and appeared to promote restorative properties in the livestock’s natural habitat. With these results, SEATOBAG® continued further research and development in the area of microbiome studies and in 2021, pilot studies were done on SEATOBAG® biocrobeX™ postbiotic in collaboration with Enterprise Singapore – Innovation Partner for Impact, and fish farms in Singapore, namely Smith Marine.

THE CHALLENGES WE TACKLE FOR AQUACULTURE:
HIGH MORTALITY PROBLEM IN THE AQUACULTURE INDUSTRY
Through the use of Miiiome™ Aqua Feed, the fish have a healthy gut and a lower prevalence of diseases. This in turn results in a faster growth rate, more efficient feed conversion ratio and a lower mortality rate.

ACHIEVING OPTIMAL FISH HEALTH NATURALLY
The active ingredient which we use for our Miiiome™ Aqua Feed is biocrobeX™, a postbiotic which is manufactured from naturally occurring beneficial bacteria and free of antibiotics.

ENSURING FOOD AND NUTRITION SECURITY
Cleaned and processed raw fish coated with biocrobeX™ postbiotic can be vacuum sealed and flash frozen to help retain the freshness and taste of the fish even after an extended period of storage of 2 years.

ENABLING CIRCULAR ECONOMY IN OUR VALUE CHAIN
GRI 306-2
Fish waste can be composted with biocrobeX™ postbiotic to be used as fertiliser for farming.

BUSINESS ETHICS
SEATOBAG® supports the Ten Principles of the United Nations Global Compact, and formally joined as a participant in July 2021. The UN Global Compact provides a universal management framework for sustainable development that will help SEATOBAG®’s long term strategy and also to set out broad guidelines on human rights, labour, environment and anticorruption practices. The Company has in place policies and practices in place for business ethics, covering anti-corruption and bribery, as well as gifts and entertainment policy for all employees. These policies are part of the orientation materials shared with all new employees who join the Company.

COMPLIANCE
GRI 307-1, GRI 419-1
Responsible business starts with compliance. We take steps to ensure that all our activities adhere to relevant laws, regulations and ethical standards. This also helps us to protect our reputation as an employer and business partner. We have stringent requirements for effective compliance management and seek to emphasize compliance by acting in line with our company values. In addition to ensuring that the Code of Conduct, various policies and procedures governing business ethics, environmental performance and health and safety are communicated to all employees, we also maintain clear roles and responsibilities for all employees. We continuously review our compliance requirements and update our initiatives and programs where necessary. This approach reflects new requirements as well as internal and external risks, such as those resulting from amendments to legislation, relevant industry codes or changes affecting our company.

In FY2021, there were no cases of significant fines or non-monetary sanctions in the social, economic area, and environmental area.

FOOD SAFETY
GRI 416-2
It is important that the aquaculture feed and food industry ensure that the aquaculture food produce reaching the consumer is safe and wholesome. biocrobeX™, our proprietary postbiotic which is applied to LACTOSEAFOOD® and the Miiiome™ Aqua Feed, has been put through various laboratory tests to ensure that it is safe for human consumption, and that it does not contain any harmful microorganisms, heavy metals or banned substances. We have also engaged independent laboratories to conduct detailed tests on the Miiiome™ Aqua Feed to ensure that it does not contain heavy metals, antibiotics, toxins or pathogens which would otherwise be toxic to the fish or accumulate in the body of the fish over time.

In FY2021, we have not received any cases of recall for LACTOSEAFOOD® or Miiiome™ Aqua Feed.

ENERGY AND EMISSIONS
GRI 302-1, GRI 305-1, GRI 305-2
Feed, more specifically the production and processing of raw materials, represents the largest component of the carbon footprint of farmed seafood prior to transport to the end consumer. The amounts of feed needed to grow the animals, along with their welfare, health, mortalities and feed management all contribute to the total carbon footprint. Fish quality and processing yields also impact significantly on the carbon footprint.

Within our feed mill, we are working to reduce our greenhouse gas (“GHG”) emissions through energy efficiency schemes, which will also help to reduce costs. Our feed mill started operations in 2021 and we are monitoring our energy consumption so as to have a better understanding of our baseline emissions. At the same time, we are conscious of the emissions attributable to suppliers in our supply chain where we procure our raw materials, and thus we aim to partner with suppliers who are located within the South East Asia region to reduce the need for long distance freight.

In FY2021, all our energy consumed was all from electricity use, which was a total of 18,054 kWh. 62% of the electricity consumption is attributable to the lab, while approximately 30% is used by the office, and the feed manufacturing process utilises about 8% of the total electricity consumption. We do not use any fuel in our operations. Our total GHG emissions in FY201, all of which was Scope 2 emissions, was 2,065 kgCO2e.

WATER
GRI 303-3
Water consumed in our operations in FY2021 amounted to 137m3, 69% of which was used by the office, 19% by the lab and 12% by the feed manufacturing process. All the water consumed is withdrawn from municipal water. We are aware of the importance to conserve water, which is a precious resource for Singapore. Some of the initiatives we have in place to minimise our use of water include:
• Implement guidelines set by the Public Utilities Board to avoid excess use of water;
• Install water-saving devices for washbasins and plumbing systems;
• Regularly check water consumption to find water leakage early.

WASTE
GRI 306-1, GRI 306-3
At SEATOBAG®, we are working to reduce waste by reducing, reusing and recycling resources in our feed mill, office and laboratory, for example, product packaging boxes, cartons and other plastics. The total amount of waste disposed in FY2021 was 50.68kg, majority of which was generated from our office activities. All the waste generated was non-hazardous waste and disposed by licensed waste vendors engaged by the building owner.

Our key stakeholders are suppliers, customers, non-governmental organisations (NGOs), industry associations and local authorities. We
meet and communicate with our various stakeholders on a regular basis and information from these discussions is fed back into the
organisation at different levels as required. This enables us to proactively work to meet stakeholder expectations and also to ensure our
policies and practices are aligned to internationally recognised standards for sustainable aquaculture.

SEATOBAG® conducted our first materiality assessment in 2021 through an internal review based on inputs from stakeholders, scientific information, management considerations and our sustainability performance. The UN Global Compact’s Sustainable Ocean Principles and the United Nations High Level Panel for a Sustainable Ocean Economy were also reviewed for aquaculture focused material topics.

Our leadership team is involved in determining the matrix, which guides our focus and sets our priorities from year to year. The material topics have been prioritised based on perceived importance to our external stakeholders and significance of the topics to SEATOBAG®.

Our sustainability performance on these material topics has been described under three sustainability focus areas in our Sustainability Report 2021: Our Business, Our Environment and Our People. Sustainability reporting against our material topics is currently carried out internally on a monthly, quarterly, or annual basis, depending on the topic and data types, across all our operational facilities. External reporting is annual, through our Sustainability Report, based on these data. Our Managing Director and Communications Manager oversee and interpret the data and communicate regularly with appropriate business leads and functional team leaders to ensure everyone is aligned to the same goals.

In FY2021, SEATOBAG® has not received any cases of recall for LACTOSEAFOOD® or Miiiome™ Aqua Feed.

SEATOBAG® has adopted a zero-tolerance policy against all forms of bribery and corruption. We are committed to conducting our business in a fair, honest, with integrity and in compliance with applicable laws in all jurisdictions where it operates including Anti Bribery & Corruption Act. The Acts prohibit corrupt practices in any form, including bribery, kickbacks, payoffs, and other unlawful payments, in both the public (government) and the private (commercial) sectors.

Nobody within SEATOBAG®, or acting on behalf of SEATOBAG®, may give or accept, directly or indirectly, a bribe in any form. Any questions with respect to the Prevention of Corruption Act should be addressed to employees’ most senior level of their department or to the Managing Director. All employees and any third party acting on SEATOBAG®’s behalf must comply with all applicable anti-bribery laws and regulations.

This Policy is clearly stated in Employee’s Handbook and elaborated during the new employee's induction briefing.

It is our policy to conduct our business in an honest and ethical manner.

a) SEATOBAG® does not pay bribes directly or indirectly through means such as excessive
entertainment or gift giving or making facilitation payments.

b) SEATOBAG® does not pay bribes to the government officials, private executives or to any other individual or entity to obtain or maintain business, include improper performance, or
gain an unfair advantage.

c) SEATOBAG® does not pay bribes directly or indirectly through brokers, agents, consultants, or other associated persons or third person.

d) SEATOBAG® maintains detailed and accurate books and records and internal controls.

e) SEATOBAG® does not conceal bribes or other improper payment by “off book” arrangement or by falsifying its book and records.

Additional Guidance:
Trading in Influence
Trading in influence exists when an improper benefit is provided to someone in order indirectly to influence the performance of the duties of a third party (for instance a relative, an acquaintance or others with access to a potential business partner or decision maker). This prohibition applies both to the party giving or offering an improper benefit, and to the party who requests, receives, or accepts such advantage. For the matter to be considered illegal, it is sufficient that a demand or an offer of improper benefit is made. Any behaviour which might cause the suspicion of bribery or trading in influence is forbidden. This applies to the use of irregular ways of payment.

Facilitation Payments to Government Officials
Facilitation are bribe and are prohibited by SEATOBAG®. Facilitation payments to government officials refer to small payments to government officials to expedite or secure performance of a routine, non-discretionary government action, such as obtaining permits, licenses or clearing customs or other government papers. Facilitation payments to Government Officials are prohibited by law in all circumstances. Employees must not pay or give anything of value to any Government Officials directly or indirectly for an improper purpose or to achieve or affect an improper end.

Facilitation Payment, Inducement and Kickbacks to Agents and Business Partners
SEATOBAG® prohibits the payment of any amount as kickbacks to agents, intermediary consultants, suppliers, subconsultants or any other business partners in exchange for a business benefit as it is contrary to our values and should not be made. Kickbacks are typically payments made in return for a business favour or advantage. Under no circumstances should any SEATOBAG® employee or agents receive payment from a third party in exchange for agreement to that SEATOBAG® will provide services, or for agreeing to collude on or for not partaking in a bid. Any request for a facilitate payment must be refused and the matter must be reported immediate to the Company through the Whistleblowing Policy and procedures.

Gifts & Hospitality
The Company has separately provided the employees with guidelines on the giving or receiving of gifts or hospitality to external parties. If employees are any in doubt as to the appropriateness of any gift or hospitality, they should the department manager or the director before it is given or accepted or otherwise as soon as possible.

SEATOBAG® does not engage in any kind of corruption such as embezzling or improperly receiving or providing gifts and hospitality. We do not receive or offer relevant stakeholders any form of monetary gains that may undermine fairness.

Gifts, meals, travel, entertainment, or anything else of value that has been given or received should be recorded and monitored. Gifts received will need to be logged in the Register of Gifts and Hospitality and the gift may not be put to private use by the intended recipient. Giving or accepting a gift of cash is prohibited, regardless of the value.

Charitable Donation and Sponsorship
Charitable donations refer to any financial resources provided voluntarily to a charitable organization to support a cause of initiative with no expectation of commercial gain in return. Donations differ to sponsorship which provide commercial benefits.

Sponsorship refers to support for an event, initiative or organization, by providing financial, property and/ or other resources, in return for certain rights, benefits or associations that may be exploited.

Sponsorship is intended to be mutually beneficial.

The Company’s charitable donation or sponsorship must not be: -
• Made to gain an unfair business advantage
• Made to individuals
• Politically connected

All donations or sponsorships must comply with the following: -
• Ensure the contributions are allowed by applicable laws.
• Obtain all necessary internal and external authorisation.
• Be made to well established entities having an adequate organisational structure to guarantee proper administration of the funds.
• Be accurately stated in the company’s accounting book and records.
• Not be used as a means to cover up any illegal payment or bribery.

Political Contributions
SEATOBAG® will NOT:
• Participate directly in any party-political activity.
• Make political contributions or contribute to a political party or individual involved in politics, whether in cash or in-kind.
• Pay admissions to an event organised by political or individual politicians, for example, a conference or dinner.
• Make contributions to organisations which are used as channels to provide funding to political parties or individual politicians.

Record-Keeping & Internal Controls
Employees must ensure that corporate books and records accurately and fairy reflect, in reasonable detail, all transactions and dispositions of assets. It is the Company’s policy to have effective systems of internal controls, including financial, accounting, and tax accounting systems to prevent incidents of bribery; unrecorded, unidentified or misidentified accounts or creation of false records.

Controls around these areas are to be monitored by the Finance Manager or Director who will conduct the anti-corruption audits to detect and deter potential corrupt activities in violation of this Policy.

Reporting / Consultation
SEATOBAG® expects individuals to take proactive steps in preventing bribery and corruption. If any employee has information concerning noncompliance or suspected violations of this Policy, report may be made via albert@seatobag.com .

If any employee is unsure whether a particular act constitutes bribery, or has any other queries, they should likewise consult the department manager or the director.
SEATOBAG® strictly prohibits any form of retaliation against employee or individual who makes a report in good faith out of genuine concern. All reported incidents will be recorded and investigated in a timely manner. Where deemed necessary, the Director may engage external consultants, such as forensic accounts / investigators to conduct an investigation into the suspected violation.

Any employee who knowingly violates this Policy will be subject to appropriate disciplinary action, up to and including termination of employment. Failure to comply with anti-bribery laws may lead to criminal or civil penalties for the Company and the employee personally, which could harm to the Company’s reputation and significant business disruptions.

In FY2021, there has been no incidents or reports of any violation of bribery or corruption incidents.