Anti-Bribery and Anti-corruption Policy

It is the Policy of the Company to conduct business in an honest, sincere lawful and ethical manner. Acts of bribery and corruption are condemned and the Company is committed to act professionally, fairly and with dignity and integrity in all business dealings and relationships. This is irrespective of the exact time and location of any operation. Effective systems such as the auditing of accounts are in place to counter bribery and corruption.

In addition to the above principle the Company will respect all laws (international laws and those local laws that have become known to us through the appointment of local Agents in foreign countries) in an effort to counter bribery and corruption. Bribery and corruption are punishable for individuals committing a relevant offence and the Company could face severe consequences that could include imprisonment, fines and damage of its reputation.

The Company employees should always act on a good faith basis, enter into commitments that are feasible to be met, fulfil the Company obligations, never mislead people, never participate in corrupt business practices, and treat people with merit and respect.

Sometimes ethical decisions involve dilemmas; in such cases it is necessary for the relevant issues to be brought to the attention of the Company management and employees should seek instructions within the framework of this policy.

This policy is applicable to both shore and shipboard employees at all levels.