Code of Business Ethics and Employee Code of Conduct. Version 1.0

Code of Business Ethics and Employee Code of Conduct Version 1.0 October 2013 1

Contents Directors Foreword..3 Contents... 4 References... 5 1. Introduction... 8 Company Ethos... 6 Background and Application..... 6 Implementation... 7 Raising Concerns.... 7 2. Ethical Trading... 8 Introduction...... 8 Human Rights...... 8 Competition... 10 Export Controls... 10 Conflicts of Interest... 11 Bribery and Corruption... 12 3. Health and Safety and Risk Assessment... 13 Introduction... 13 Health and Safety Policy..... 13 Risk Management Policy..... 14 4. Environmental Policy... 15 5. Interaction with Government... 16 6. Business Procedures and Management... 17 Introduction.... 17 Integrity in Business Records... 17 Quality and Continuous Improvement... 18 Safeguarding our Assets..... 18 Respecting the Confidential and Propriety Information of Others... 19 Privacy... 19 Media...... 20 Working with Clients, Suppliers and Partners... 20 7. Employee Charter... 22 Introduction... 22 Diversity and Equality... 22 Performance and Reporting... 22 Engagement..... 22 4

References A. United Nations, Universal Declaration of Human Rights (UDHR) (1948). B. United Nations, International Convention for the Safety of Life at Sea (SOLAS) (1974). C. United Nations, UN Convention on the Law of the Sea (UNCLOS) (1982). D. United Nations, Convention for Suppression of Unlawful Acts of Violence against the Safety of Maritime Navigation (SUA Convention) (2005). E. United Nations, Guiding Principles on Human Rights in Business (UNGP) (2011). F. UNHCR, Refugee Convention (1951, as modified by the Protocol of 1967). G. IMO, International Convention for the Prevention of Pollution From Ships (MARPOL) (1973, as modified by the Protocol of 1978). H. IMO, International Convention on Maritime Search and Rescue (SAR) (1979). I. IMO, Maritime Labour Convention (2006). J. IMO, MSC.1/Circ.1339 Best Management Practices for Protection against Somalia Based Piracy (BMP 4) (Revised Version, 2011). K. IMO, MSC.1Circ./1406 Interim Recommendations for Flag States regarding the use of Privately Contracted Armed Security Personnel on board ships in the High Risk Area (Revision 1, 2011). L. IMO, MSC.1Circ./1405 Interim Guidance to Shipowners, Ship Operators, and Ship masters on the use of Privately Contracted Armed Security Personnel on board ships in the High Risk Area (Revision 1, 2011). M. IMO, MSC.1/Circ.1408 Interim Recommendations for Port and Coastal States regarding the use of Privately Contracted Armed Security Personnel on board ships in the High Risk Area (2011). N. International Committee of the Red Cross (ICRC), The Montreux Document on Pertinent International Legal Obligations and Good Practices related to Operations of Private Military and Security Companies during Armed Conflict, (2008). O. Council of the European Communities, European Framework Directive on Safety and Health at Work (Directive 89/391 EEC) (1989). P. Swiss Ministry of Foreign Affairs, International Code of Conduct for Private Security Service Providers (ICoC) (2010). Q. International Standards Organisation, Guidelines for PMSCs providing PCASP on board ships (ISO/PAS 28007) (First Edition, 2012). R. HM Government, UK Firearms Act (1968). S. HM Government, Health and Safety at Work Act (HSW) (1974). T. HM Government, Personal Protective Equipment at Work Regulations (1992). U. HM Government, Data Protection Act (1998). V. HM Government, UK Export Control Order (2008). W. HM Government, UK Bribery Act (2010). X. HM Government, Reporting of Injuries Diseases and Dangerous Occurrences Regulations (RIDDOR) (2013). Y. UK Home Office, Firearms Security Handbook (HMSO, 2005). Z. UK Department for Business, Innovation and Skills (BIS), Open General Trade Control Licence (Maritime Anti-Piracy) (BIS, 2012). 5

1. Introduction 1.1 The Company ethos 1.1.1 The Company ethos is professional excellence, transparency, ethicality and client satisfaction. 1.1.2 In delivering our service, we recognise that we will be scored and assessed by many organisations from governments to coastguards, from port agents to clients. Our competitive advantage relies on us adhering to the highest standards and We will therefore submit ourselves to the scrutiny of industry standards accreditors and our clients due diligence regimes, with enthusiasm. We constantly strive to be world-class and expect to set new industry standards. We desire to be the pre-eminent supplier of our product by developing the strongest relationships with our clients. To meet this we are committed to operating to the highest ethical standards, with a conviction that this will give us a very strong competitive edge. In short, our ethical standards match those of our clients. Professional excellence is the only standard we understand. Nothing that we offer is second rate, and our personnel will be fully committed to meeting the demands of our clients. The levels of security and protection afforded to our clients weapons and equipment will always far exceed the perceived threat, and the health and safety of the client personnel entrusted to our care is paramount. Transparency and ethicality are at the centre of our business model. In a trade which handles large quantities of weaponry on a daily basis, nothing short of completely open, transparent, fully licensed and approved operations will meet the aspirations of governments and coastal states. At all times, we operate with honour, honesty and propriety, within the laws of the UK where we are based and registered and within the laws of the countries in which we are flagged, operate and which we transit. Client satisfaction is at the core of everything we do. In the first instance we will ensure that our clients critical equipments are properly protected, secured, accounted and cared for and maintained. We will ensure that our clients personnel are appropriately protected and hosted and we will deliver our services at a price which is competitive. 1.2 Background and Application High standards of ethical behaviour and compliance with laws and regulations are essential to protecting the reputation and long-term success of our business. Whichever element of the business we operate in, whether it be in the Head Office, on ship, or representing the Company in conferences or meetings, each individual, through our actions and decisions, has a personal responsibility to enhancing the Company s reputation. This Code of Business Ethics (CBE) sets out the ethical principles that underpin our ethos and the way in which we conduct our business. This Code provides guidance on how to apply these principles in everything we do. Consequently this Code applies to all employees of MNG Maritime Ltd., who are required to comply with the Code. 6

We will request that our suppliers, subcontractors, temporary workers and other third parties, with whom we work, apply the principles of this Code, if they do not already work to their own similar standards. We welcome feedback on the content of this Code, and will consider all comments carefully. 1.3 Implementation 1.3.1 All Company personnel are required to read and fully comprehend the principles and rules set out in this Code. If there is any doubt about what is being asked for, or what is required, it is imperative that they raise the issue with the Directors immediately. Ship s Security Officers (SSOs) have additional responsibility to ensure that they: maintain absolute integrity in all that they do; comply with all applicable laws and regulations at all times; lead by example by promoting ethical behaviour and business conduct; ensure that their team members have read and understood the Code; create an atmosphere where team members feel duty bound to raise issues of ethical concern; ensure that ethical concerns raised to them are passed on up the Company. 1.3.2 Breaches of the Code will not be tolerated and will result in the Company taking action, which may include disciplinary action up to and including dismissal. It is not possible for this Code to be explicit regarding every possible ethical dilemma, so common sense and good judgement will need to be used to make ethical decisions based on the Code s principles. If personnel are faced with a dilemma and are unsure how to solve it, then they should ask for help. 1.4 Raising Concerns The Company is committed to creating an atmosphere where questions and concerns about business ethics can be raised without fear of retaliation. If personnel experience or witness unethical behaviour, including illegal acts, they are duty-bound to report it. Guidance should be sought if there is any doubt - better to raise a concern at an early stage than to ignore an ethical issue that could have more serious consequences later. 7

2. Ethical Trading 2.1 Introduction This Ethical Trading Policy serves as a guideline for all the company's business practices. Through its business practices the company seeks to support the principles of the Universal Declaration of Human Rights (UDHR) 1 and the Guiding Principles on Human Rights in Business (UNGP) 2. The Company's position on human rights reflects the core requirements of the UDHR, such as freedom from torture, unjustified imprisonment, unfair trial and other oppression. It also includes freedom of expression, religion and political or other representation. The Company recognises and supports states and businesses obligations expressed in UNGP. 2.2 Human Rights 2.2.1 The Company will strive to avoid causing or contributing to adverse human rights impacts through our activities, and we will address such impacts when they occur. 2.2.2 We will seek to prevent or mitigate adverse human rights impacts that are directly linked to our operations, products or services by our business relationships, even if they have not contributed to those impacts. 2.2.3 The Company will comply with all applicable laws and respect internationally recognised human rights, wherever we operate and seek ways to honour the principles of internationally recognized human rights when faced with conflicting requirements; 2.2.4 We expect this policy to be embraced by our own personnel, our business partners and other parties who are directly linked to our operations, products or services; 2.2.5 On the basis of this policy the company will not provide support to or work with: (a) Oppressive regimes (b) Suppliers or clients with links to an oppressive regime regimes where basic human rights, as set out in the UDHR, are denied in a systematic manner over time. (c) Suppliers or clients which fail to uphold basic human rights within their sphere of influence. The company recognises that businesses have the opportunity to ensure that human rights are upheld in all those aspects of their operations that they could reasonably expect to control. (d) Suppliers or clients operating in states governed by oppressive regimes, whose activities are considered to support or benefit the regime, usually at the expense of the indigenous population. (e) oppressive regimes are defined by: Absence of the rule of law; arbitrary detention and trial; disappearances; 1 United Nations, Universal Declaration of Human Rights (UDHR) (1948). 2 United Nations, Guiding Principles on Human Rights in Business (UNGP) (the Ruggie Principles) (2011). 8

extrajudicial executions; Persecution of sections of the community that may include statesanctioned killings or ethnic inspired genocide; Torture routinely or commonly employed as part of a judicial or extrajudicial process; Arbitrary surveillance, detention or violent intimidation by state security agencies; Suppression of civil society institutions as a platform for opposition or community self-expression; Little or no freedom of expression, persecution of human rights defenders, trades unions etc.; Little or no freedom of religion, persecution of minority religions not sanctioned by the state; State-sponsored racial segregation or discrimination e.g. apartheid; Little or no freedom of movement; people forcibly prevented from leaving the country; Absence of a free media including press and broadcast; internet censorship, surveillance and persecution; Prevalence of state sanctioned slave or bonded labour; prevalence of systemic child labour, including child soldiers recruited as an instrument of war and conflict; Persecution and/or forcible eviction and re-settlement of ethnic, indigenous or tribal minorities; and State sponsored persecution or discrimination of women and girls by virtue of their gender. 2.2.6 We are opposed to the use of any form of child labour or practices which inhibit the development of children. We believe that employment should be freely chosen and commit to refrain from using any form of forced or involuntary labour. 2.2.7 Where personnel believe that the Company s activities in area, threaten the basic human rights of others, they are to report the matter to the Directors. 2.2.8 Where appropriate the Company will compile relevant human rights impact assessments for activities where the human rights of others may be affected. 9

2.3 Competition 2.3.1 The Company complies with competition laws and adheres to the principle of free competition. We win our business through fair comparison of quality of service and price, and reject protectionist measures and threats, conditional denial of services offered as a threat, protectionist pricing and other dishonest practices. 2.3.2 Our personnel must never: Make any deals with competitors which could lead to, or be interpreted as, pricefixing, bid-rigging, dividing up the market or restricting supply of services; agree to any restrictions on customers, joint venture partners or suppliers as to who they can sell to or buy from and on what terms, unless their doing so breaches the principles of the Company s ethical policy in some other way; share commercially sensitive information with competitors (in particular pricing information, ongoing bids, terms and conditions of sales, market share, costs and margins); plan to compel, influence or oblige clients or potential clients to use our services by employing behaviours which aim to restrict the clients full freedom of competitive choice, by means other than fair and legitimate business practices. 2.3.3 If personnel have any concerns, they should report in the first instance to the operations team, especially any suspicions or allegations of anti-competitive behaviour. 2.4 Export Controls 2.4.1 As a UK-registered company, we comply with all UK import and export laws, regulations and procedures, as well as those that apply to us in the conduct of our business, whether those of the flag state, coastal state, jurisdiction of our client or territory in which we operate. 2.4.2 Movement of controlled goods, specifically firearms and ammunition and other military-use items (body armour, helmets, radios and sighting systems) is subject to controls by international organisations, home state, flag state and other interested states. We therefore comply with all applicable export control and import laws, regulations and procedures wherever we operate. 2.4.3 Our personnel must therefore ensure that they: comply with applicable export and import laws and regulations when transferring controlled goods between vessels or across international boundaries; 10

comply with national and international sanctions and embargoes, noting specifically the Schedule 2 listed countries which are located within the theatres we operate 3 ; understand the laws and regulations that apply if involved in the transfer of controlled goods, including if deploying with personal body armour and helmet in their baggage; satisfy the terms and conditions of any import or export authorisations, including those of clients, stated on their import/export licences; seek advice from the operations team if in any doubt. 2.4.4 Our clients will be requested to supply to us documentation that proves that: their firearms and ammunition have been procured legally under the laws of the state in which their company is registered; they possess the appropriate import-export licence issued by the state in which their company is registered; that firearms and ammunition that they seek to check out of our armouries belong to them; their personnel, who check controlled goods out of our armouries and equipment stores, have been vetted in accordance with the requirements of ISO/PAS 28007; that those personnel are legitimate employees or contractors of the company. 2.5 Conflicts of Interest 2.5.1 Conflicts of interest must be declared immediately by employees who might be seen to have the influence to exploit them. In practice this means declaring immediately any relationship, influence or activity that could impair the ability to make fair and objective decisions. 2.5.2 Personnel must, therefore, ensure that they: disclose all potential conflicts of interest, real or perceived, including any personal, professional or familial relationships that could give rise to a conflict of interest; do not provide any services to a competitor or potential competitor; do not place business with any company owned or controlled by themselves, a fellow employee or a family member, unless cleared in advance by the Directors; 3 Namely, in the Red Sea, Gulf and Indian Ocean: Yemen, Somalia, Sudan, Eritrea, Iran and Iraq. 11

do not own, or have a significant holding in, any client, supplier or competitor, unless cleared in advance by the Directors; do not use confidential Company information for personal gain, or pass such information to anyone else (either inside or outside the Company) who does not need the information for the furtherance of Company interests; do not recruit or supervise a family member or close personal friend, including someone with whom they are having a romantic relationship, without declaring the interest. The Company encourages recruitment of personnel who are personally known to current employees, but the connections must be fully declared. 2.6 Bribery and Corruption 2.6.1 Under no circumstance will the Company, or its employees pay any bribes for any purpose whatsoever, whether directly or through a third party. 2.6.2 The Company does not condone any form of bribery and corruption, and will not offer, give or accept anything of value that could be seen as improperly influencing business decisions including so-called facilitation payments, either directly or indirectly. All applicable anti-bribery laws will be fully respected 4. 2.6.3 Our personnel must: declare all gifts and hospitality; refuse all requested bribes except where not doing so may put themselves, or others at risk. In the latter case, the situation should be reported to the operations team without delay. 4 UK legislation in particular, namely The Bribery Act, 2010. 12

3. Health and Safety and Risk Management 3.1 Introduction The Company has a strong commitment to Health and Safety, where the protection of our personnel, as well as the personnel of clients and suppliers, is of the highest importance. 3.2 Health and Safety Policy 3.2.1 The Company is committed to providing and maintaining safe and healthy working conditions, equipment, and systems of operation on all our vessels, and in our offices. It is also Company policy to provide adequate control of the health and safety risks arising from our business activities. We will ensure safe handling and use of substances. We will also provide such information, training, and supervision, as is needed for this purpose. 3.2.2 We will periodically consult our employees on matters affecting health and safety, and we will always strive to prevent accidents and cases of work-related ill health. 3.2.3 Allocation of responsibilities for health and safety issues is set out in the H&S Procedures, as part of the Company s Safety Management System (SMS) and the particular arrangements that we make to implement the policy are set out in that document. This policy will be kept up to date, particularly as the business changes in nature and size. To ensure this, our policy and the way it is managed will be reviewed annually. 3.2.4 We expect all of our personnel to assist in fulfilling our key health and safety objectives, focused on creating a safe and healthy work environment. 3.2.5 We require our personnel to: strive to conduct their work in a safe and secure manner, taking no more risk in their activities than is reasonable and necessary, in accordance with Company risk assessments; make sure that they understand additional health and safety related responsibilities relevant their role; identify any areas of risk, and ensure that risk assessments are in place for such activities; always work to the Company s health and safety policy, standards and requirements; stop work if they think what they are doing is unsafe; intervene if they are concerned that an action or decision might result in us not meeting Company health and safety policy objectives, standards and requirements; report and actively support identifying lessons from accidents and incidents, including near misses and unsafe acts/conditions; 13

not put themselves or others at risk from their actions. 3.3 Risk Management Policy 3.3.1 The Company s Risk Management Policy is designed to provide the framework to identify, assess, monitor and manage the risks associated with the Company s business. Company procedures aim to identify significant areas of business risk and to manage those risks effectively in accordance with the Company s risk profile. The Directors are responsible for ensuring that risks are properly identified and that the Company s objectives and activities are aligned with the risks and opportunities so identified. The potential exposures associated with running the Company are managed by the Directors. The Company s main areas of risk include: market risk changes in economic conditions, fuel prices and shipping companies own acceptance of risk; political risk changes to the political situation and regulatory environment in countries from which logistic support is derived, and in which import-export licences and licences to operate are issued; health and safety risk operating ships in a high risk area is an inherently risky undertaking, and the management of standard health and safety risks is of vital importance; operational risk increase in threat to the vessels themselves. 3.3.2 Additionally, it is the responsibility of the Company Directors to ensure a robust and effective internal control systems for risk and also to ensure that its financial affairs comply with applicable laws and regulations and professional practices. The finance director will state in writing to the Company Directors that the integrity of the financial statements is founded on a sound system of risk management and internal compliance and control and that the Company s risk management and internal compliance and control system is operating efficiently and effectively. The Company is not currently of a size to justify the formation of a separate risk management committee. 14

4. Environmental Policy 4.1 Operations at sea bring Company personnel into close proximity with a fragile and exposed part of the globe. The Company has a strong commitment to the environment and to the sea and expect our personnel to do all they can to protect them. We strongly support and abide by applicable international conventions, especially the MARPOL Convention 5. 4.2 We expect our personnel to share this commitment, in particular by: not allowing themselves, or others to commit acts which would impact adversely on the environment, or breach the Convention; setting high standards for environmental behaviour and expecting the same of others; intervening or reporting if they witness an action or decision that would breach the Convention. 5 The International Maritime Organisation s International Convention for the Prevention of Pollution from Ships, 1973 as modified by the Protocol of 1978, including Annexes I-VI. 15

5. Interaction with Government 5.1 We will necessarily engage with government, and its organs, in order to conduct our business. We will do so in compliance with applicable laws, and we will behave ethically and appropriately in all our dealing with them, their agencies and their representatives. 5.2 In engaging with governments, their agencies and representatives, we will: do so to communicate with them on matters relating to our business; not make corporate contributions or donations to political parties or to any organisations, think-tanks, academic institutions or charities closely associated to a political party or cause; remain apolitical at all times; permit personnel to take part in party politics and/or make personal political donations, but only outside the business and in their own time. 5.3 Our personnel must at all times: work to all applicable laws and conduct themselves with integrity, honesty and transparency in all dealings with governments, their agencies and representatives; and refrain from using Company time or resources to engage in personal political activities, without specific prior authorisation. 16

6. Business Procedures and Management 6.1 Introduction It is vital to the Company s credibility that our records are maintained accurately and precisely. Many of our clients will rely on data provided by us and therefore any inaccuracies would reflect poorly on the Company. 6.2 Integrity in Business Records 6.2.1 The Company is committed to ensuring the integrity and accuracy of our business records at all times. We maintain accurate and complete records of all of our business transactions, including those between our business and external individuals and organisations, and all expenditure and labour charges. We act at all times in accordance with applicable law as technical and professional standards. 6.2.2 The Company will file our financial returns in a timely manner, representing the facts accurately and completely and we maintain a rigorous system of financial, operational and compliance controls and an effective system of risk management. 6.2.3 We are committed to the prevention and detection of fraud and will investigate any suspicion of fraudulent activity. Fraud is a criminal offence which we will always investigate. 6.2.4 In order to achieve this Company personnel must: record all expenditure, hours worked, transactions or any other aspect of the Company s business, accurately and in a timely manner; preserve documents, receipts and records in accordance with Company policy; seek approval for all spend on the Company s account; report immediately any suspicion of fraud; maintain true and accurate records, including electronic, of all weapons and ammunition transactions and movements in accordance with Company SOPs; not allow themselves to be influenced or influence others to do anything that would compromise the integrity of our business records, reports, products or services; and not make a false or deliberately misleading entry in a report, record or expense claim or falsify any corporate records (e.g. financial, safety, environmental or quality results). 17

6.3 Quality and Continuous Improvement 6.3.1 The Company delivers a high quality product and that quality is central to everything we do and we are committed to continuous improvement by constantly striving to refine and update all aspects of our product. 6.3.2 The Company requires its personnel to: take responsibility for their part in delivering a high quality experience that meets the expectations of our clients on board ship; take action and respond promptly to any concerns or complaints about our levels of service; and actively identify ways continuously to improve the way we operate and the product we deliver. 6.4 Safeguarding our Assets 6.4.1 Company assets, whether human, financial, physical or intellectual are essential to the delivery of our services, and our employees must do all that they can to preserve and protect these resources, through diligent health and safety procedures, attentive equipment husbandry and robust intellectual property procedures. In particular much of our commercial information is sensitive and vital to our business and we must protect it from unauthorised use and disclosure. 6.4.2 We require our personnel: only to use Company assets for Company business, unless authorised; to husband Company resources with care, guarding against waste and abuse; not to seek personal gain from the use, sale, transfer or other disposal of Company resources without authorisation; value the Company s time, and work diligently to fulfil the responsibilities of their role; not to try and circumvent IT security controls; to protect Company documents securely; and not to disclose confidential information to other parties, such as suppliers, clients or joint ventures, without confirming that there is an appropriate agreement in place to protect intellectual property rights. 18

6.5 Respecting the confidential and propriety information of others 6.5.1 The Company will absolutely protect the confidential, proprietary or trade information of our clients, suppliers and partners with integrity and in compliance with the relevant laws and regulations. Moreover, we will not seek to obtain competitive intelligence by illegal or unethical means. Neither do we solicit, acquire, read or use confidential information of other parties that we know to be sensitive. 6.5.2 Our personnel must: avoid placing themselves or the Company in the position of receiving other parties confidential, proprietary or trade secret information (including software) when not authorised to do so; not receive or copy documents or material (including software) unless they have explicit permission; maintain securely all documents provided to the Company by other parties; and not disclose commercially sensitive information about a customer, supplier, joint venture or other partner company, either internally or externally, without their permission to do so. 6.6 Privacy 6.6.1 The Company is committed to protecting the privacy and confidentiality of our people in accordance with the law 6 and Company policies. The Company will only collect, process and store personal information to meet necessary business needs and legal requirements. All Company personnel are to be fully aware of the responsibility to keep personal information secure and observe the privacy of individuals. 6.6.2 Our personnel must: respect the rights of individuals whose personal information they process; only create, save, process, hold, disclose and transfer that personal information that is required by the Company, in line with applicable laws; and not access or disclose personal information to anyone inside or outside the organisation unless the disclosure is in line with applicable laws and Company policy. 6 In the UK, the Data Protection Act, 1998. 19

6.7 Media 6.7.1 The Company s reputation is a key asset and personnel must behave in a manner that reflects well on the Company at all times. We will engage with the media in activities that will meet commercial objectives and have a positive effect on the reputation of the Company, including assisting them in understanding the nature of the business, providing accurate information as required. 6.7.2 Company personnel are: to act in a way that protects or enhances our reputation and brand at all times; to use care and good judgment when talking about the Company or personnel, especially when not in the workplace; not to speak to the media about our business without prior authorisation from the Directors; not to use social media to post or display information about the Company, its clients, suppliers, partners or competitors; and not to engage in social media forums for business purposes while acting on behalf of the company in an official capacity, without prior written approval from the Directors. 6.8 Working with Clients, Suppliers and Partners 6.8.1 The Company treats all our clients and suppliers with fairness and integrity to build mutually beneficial relationships, regardless of the value of the transaction or the length of that relationship. Additionally we aim to build and maintain high levels of client satisfaction through our commitment to improving quality, delivery, responsiveness and reliability. 6.8.2 The Company will respect at all times the confidentiality of commercially sensitive information provided to us by clients, suppliers and partners and we will only use it appropriately for legitimate business purposes. Equally we expect our suppliers and partners, their employees and their supply chains to operate to similarly high standards of quality and integrity. 6.8.3 We select suppliers and partners whose core values and commitment to ethical conduct match our own. 6.8.4 Company employees must ensure that they: communicate clearly and honestly with clients, suppliers and partners, but take care to protect our intellectual property and not disclose confidential information unless authorised; make sure that all communications in bid preparations and contract negotiations with potential clients are accurate and honest; 20

select suppliers solely on merit; and contract with clients, suppliers and partners on clear terms and operate in accordance with them, making sure all communications are accurate. 21

7. Employee Charter 7.1 Introduction Our personnel are the people who represent the Company on a daily basis to our clients and client personnel. It is they who sell the Company and ensure its success. Personnel are a key Company resource and we will do what we can to treat them properly and fairly, reward them appropriately, and discipline them sensitively should they err. 7.2 Diversity and Equality 7.2.1 MNG Maritime treats all personnel openly, honestly and courteously and expects its personnel to do the same to others. The Company will not tolerate bullying, harassment or unlawful discrimination of any kind and we encourage employees to take action about any instance of such that they experience or observe. We really value diversity and promote equal opportunities for all employees in a working environment free from unlawful discrimination. 7.2.2 We recruit, select and develop our people on merit, irrespective of their race, colour, religion, gender, age, sexual orientation, marital status, disability or any other characteristic protected by applicable laws 7. 7.2.3 Our employees must: treat everyone with fairness, respect and dignity (e.g. job applicants, employees, clients, competitors and suppliers); report any behaviour that they believe constitutes bullying, harassment or discrimination; not behave in a manner that is disrespectful, bullying, intimidating, offensive or malicious, or make jokes which are discriminatory or inappropriate; not engage in sexual harassment including unwelcome physical contact, expressions, gestures, comments or invitations; not exclude others from projects, discussions and opportunities due to their race, colour, religion, gender, age, sexual orientation, marital status, disability, or any other protected characteristic as required by law; and not make decisions about the recruitment, selection and development of employees based on other than objective criteria, including qualifications, skills and experience. 7 Except on certain vessels where only single sex accommodation is available, and certain disabilities would pose an additional risk. 22

7.3 Performance and Reporting 7.3.1 Personnel will be rewarded for the respective contribution they make towards the Company s success. 7.3.2 We expect personnel to: deliver the output stated in their terms of reference to the best of their ability, seeking support and feedback as required; contribute to the Company reporting process, either reporting on others, or being reported on; assist in the personal development of others where applicable. 7.3.3 In turn we agree to: assist in personal development; manage under-performance fairly; report on performance fairly and consistently, providing regular feedback. 7.4 Engagement 7.4.1 The Company operates under the following principles: We demand openness and honesty. We expect mutual respect and collaboration between all Company personnel. We expect personnel to contribute positively to improving our business and we welcome their feedback. Equally, we commit to sharing information and discussing Company issues with our personnel when appropriate. We resolve disputes fairly. 7.4.2 What this means for you. You must: ask for, provide and act on feedback; accept accountability for delivering the best results for our customers; be open with the people you work with; as an SSO or MSTL, involve your team, make sure they know what you expected of them and talk regularly to them about the contribution they make; and 23

as an SSO or MSTL, be aware of how your decisions and actions affect your team and make sure they have the help and support they need. 24