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Code of Conduct for MCGlobe 

(Applies to all individuals and entities that engage with MCGlobe) 
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Date: 12.02.2026 

1. INTRODUCTION AND PURPOSE 

1.1. MCGlobe PTE. LTD. and its affiliates, including entities that directly or indirectly control, are controlled by, or are under common control with MCH Holding DK ApS (CVR no. 42600288), are collectively referred to as “MCGlobe”. “Control” means direct or indirect ownership of more than fifty percent (50%) of the voting rights or equivalent decision-making authority. 

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1.2. The purpose of this Code of Conduct is to establish clear, global standards for lawful, ethical, and responsible conduct, and to promote integrity, transparency, and accountability in all dealings with MCGlobe. 

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1.3. This Code applies to all individuals and organizations that have any form of engagement with MCGlobe, including employees, management, contractors, agents, suppliers, business partners, and other third parties.  

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1.4. MCGlobe is committed to ensuring that all interactions and business operations uphold the highest standards of integrity, compliance, and sustainability. 

2. COMPLIANCE WITH LAWS 

2.1. All parties must comply with all applicable international, regional, national, and local laws, rules, and regulations, including but not limited to:  

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  • Anti-corruption and anti-bribery legislation. 

  • Labor, employment and human rights standards. 

  • Environmental protection and sustainability regulations. 

  • Trade compliance, sanctions and customs requirements. 

  • Data protection and privacy laws, including PDPA, GDPR and other relevant frameworks. 

  • Strict compliance with export control regulations, sanctions regimes, and dual-use legislation. 

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2.2. All parties are responsible for staying informed of applicable legal requirements relevant to their role and must seek guidance from MCGlobe when uncertainties arise. 

3. BUSINESS ETHICS AND ANTI-CORRUPTION 

3.1. All engagements with MCGlobe must be conducted with honesty, fairness, integrity, and ethical behavior, including: 

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  • Prohibition against offering, giving, soliciting, or receiving bribes or other improper advantages. 

  • Ensuring transparency and accuracy in all transactions. 

  • Refraining from offering or accepting gifts or hospitality that could influence or appear to influence business judgment. 

  • Avoid, disclose, and manage any actual or potential conflicts of interest. 

  • Conducting business in a manner that fosters fair competition and market integrity. 

  • Where required by MCGlobe, participate in and complete anti-corruption and ethics training. 

4. LABOUR AND HUMAN RIGHTS 

4.1. All individuals and entities must respect internationally recognized human rights and labor principles, including: 

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  • Prohibition of all forms of forced, bonded, or child labor. 

  • Fair and non-discriminatory employment practices. 

  • Safe, respectful, and harassment-free workplace environments. 

  • Freedom of association and collective bargaining rights. 

  • Equal employment opportunities. 

5. HEALTH, SAFETY, AND ENVIRONMENT 

5.1. All parties must support safe, healthy, and environmentally responsible operations, including: 

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  • Compliance with all applicable health, safety, and environmental (HSE) laws and regulations and procedures. 

  • Minimizing environmental impact through responsible resource use, waste reduction, and pollution prevention. 

  • Reporting unsafe conditions or environmental risks immediately. 

  • Continuously monitor and improve health, safety, and environmental performance. 

6. CONFIDENTIALITY AND DATA PRIVACY 

6.1. All parties must maintain the confidentiality of non-public, proprietary, or sensitive information disclosed by MCGlobe and handle personal data in compliance with applicable data protection laws and contractual terms. 

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6.2. Confidential information must not be disclosed to unauthorized individuals, duplicated without permission, or used for personal gain. 

7. MONITORING, REPORTING, AND ENFORCEMENT 

7.1. All parties agree to: 

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  • Cooperate fully with any internal audit, review, risk or compliance checks initiated by MCGlobe. 

  • Promptly report any actual or suspected violations of this Code of Conduct or applicable law through designated channels. 

  • External parties may raise concerns or report suspected violations by contacting MCGlobe management or the Compliance team. 

  • Understand that material breaches may result in suspension, termination of contractual relations, or other remedies available to MCGlobe. ​

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7.2. All reports will be treated confidentially and without retaliation. 

8. ANTI-CORRUPTION DECLARATION 

8.1. As a condition of engaging with MCGlobe, all parties are expected to confirm that: 

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  • They do not engage and have not engaged in any form of bribery, corruption, fraud, or other unlawful conduct. 

  • They comply with and adhere to all applicable anti-corruption and anti-bribery laws, including Singapore’s Prevention of Corruption Act, the UK Bribery Act 2010, and the U.S. Foreign Corrupt Practices Act (FCPA). 

  • They adhere to MCGlobe’s anti-corruption policies, internal controls, and procedures. 

  • They ensure subcontractors, agents, suppliers, or third parties under their supervision comply with these principles. 

  • They promptly notify MCGlobe management of any breach or suspected breach. 

  • They cooperate in all investigations and provide relevant information or documentation when requested. 

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