1. Prohibition on Insider Trading
   • No person covered by this Policy Statement may trade in the Company's securities while in possession of material non-public information.
   • Material non-public information is any information that could reasonably be expected to affect the price of the Company's securities or that a reasonable investor would consider important in making an investment decision. Examples include, but are not limited to, financial results, significant business developments, mergers and acquisitions, and changes in senior management.
2. Trading Windows and Blackout Periods
   • Insiders and Covered Persons (as defined below) are prohibited from trading the Company's securities during Blackout Periods (as defined below). These restrictions help prevent the misuse or appearance of misuse of inside information, particularly around the announcement of financial results.
   • “Blackout Periods” are times when trading is prohibited due to the possession of material non-public information. These periods may be imposed around the time of significant corporate events or announcements.
   • “Insiders” are any people that possess information that: (a) relates directly or indirectly to the Company; (b) has not been disclosed to the public by the Company and is not otherwise in the public domain; and (c) a reasonable investor would consider important in deciding whether to purchase, sell, or hold the Company’s securities.
   • “Covered Persons” are Group directors, committee members, chief executive officers, executive managers, vice presidents, employees (including full-time, part-time and seconded employees), and certain external parties (including Group consultants, auditors and relatives of the aforementioned parties in this defined term).
3. Pre-Clearance of Trades
   • Insiders and Covered Persons shall obtain pre-clearance from the Group Assurance Department before engaging in any transactions involving the Company's securities. The pre-clearance process helps ensure that trades are not made while in possession of material non-public information.
4. Reporting and Compliance
   • All Group employees must report any suspected violation of this Policy Statement to the Group Assurance Department immediately.
   • The Company will investigate any reported violations and take appropriate disciplinary action, which may include termination of employment and legal action.
5. Education and Training
   • The Company will provide and/or make available, regular training and education on insider trading laws and this Policy Statement to all persons covered by this Policy Statement.
   • Persons covered by this Policy Statement are encouraged to seek guidance from the Group Assurance Department if they have any questions or concerns about this Policy Statement.

Policy Statement Owner: Group Assurance Department

Effective Date: 11-Feb-2025

Version: 0001