Icon Energy Annual Report 2025 51 CODE OF CONDUCT Further general principles of conduct under the Company’s Code of Conduct and Ethics, include: − Ethical and Responsible Practices: Conducting business with the highest ethical standards and responsibility. − Sustainable Development: Integrating sustainable development considerations into our decision-making processes. − Economic Contribution: Promoting economic growth and business development, generating government revenue, providing commercial returns to the industry, and contributing to the wealth created by Australia’s natural resource base. − Risk Management: Implementing health, safety, environmental, and community risk management strategies that are based on sound science, transparency, and effective communication. − Continuous Improvement: Continuously seeking opportunities to enhance health, safety, and environmental performance, addressing risks posed by our operations to employees, contractors, the public, and the environment. − Biodiversity and Environmental Protection: Contributing to biodiversity conservation and environmental protection through responsible management of our operations and their impacts. − Community Development: Supporting the economic and social development of the communities in which we operate. − Human Rights: Respecting and protecting human rights and dignity at our operations and dealing fairly with employees and others. − Community Engagement: Engaging openly and effectively with our communities and reporting on our activities. − Share Trading Policy: Directors and Executives must notify the Chairman or Managing Director before trading in the Company’s shares and must comply with the Company’s Share Trading Policy. These principles underpin our commitment to ethical conduct and responsible business practices, ensuring we operate with integrity and contribute positively to all our stakeholders. OTHER KEY POLICIES The Company has implemented a Whistleblower Policy providing employees with a secure and confidential mechanism for reporting improper conduct. This policy ensures that all reports can be made without fear of discrimination or harassment and encourages staff to raise concerns about any conduct that may be inappropriate or unlawful. An Anti-Bribery and Corruption Policy is also in place, ensuring compliance with legal and regulatory standards concerning anti-corruption and bribery, emphasizing our commitment to acting ethically, honestly and responsibly. This Policy sets out the requirements for the management of gifts and benefits. The Board is informed if any material incidents reported under either policy. Code of Conduct and Ethics, Whistleblower Policy and Anti-Bribery and Corruption Policy are available in the Corporate Governance Section of the Company’s website. TRADING IN THE COMPANY’S SECURITIES BY DIRECTORS AND EMPLOYEES The Board has established a formal Share Trading Policy to regulate trading in the Company’s securities by Directors and employees. The policy defined permitted trading periods (“Trading Windows”) and restricted periods (“Blackout Periods”). Generally, all Icon Energy personnel who do not possess unpublished price-sensitive information may only buy, sell or otherwise deal in the Company’s securities during designated Trading Windows.
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