Well, according to the 1907 Hague Convention, XIII, Article 18:
"Belligerent war-ships may not make use of neutral ports, roadsteads, or territorial waters for replenishing or increasing their supplies of war material or their armament, or for completing their crews."
So no refuelling and rearming in Neutral ports
As for Penang, I don't believe any other WWII German warship ever docked there (Except for submarines, that is), I could be wrong though
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