The Company has adopted this Code of Conduct and Ethics (the “Code”) which is applicable to all Company’s employees, managers, agents and ship personnel serving on board vessels managed by the Company (hereinafter the “Individuals”).

The Code provides basic guidelines regarding the minimum requirements expected by the Individuals and reflects the Company’s core values and commitment to manage its business with integrity.

Conflicts of Interest

A conflict of interest occurs when an individual’s private interests interfere or appear to interfere, with the interests of the Company. While it is not possible to describe every situation in which a conflict of interest may arise, Individuals must never use or attempt to use their position within the Company or their rank on a vessel to obtain personal benefits. Any Individual aware of a conflict of interest, or concerned that such a conflict might arise must address the matter with his Manager/Supervisor immediately.

Corporate Opportunities

Individuals owe a duty to promote the Company’s legitimate interests and not to use corporate property/information, their position in the Company or their rank on a vessel to advance personal interests.

Confidentiality and Personal Data Privacy

Confidential information includes any internal information obtained in the course of employment, including but not limited to non-public information concerning the Company’s business, the Company’s customers and suppliers, the Company’s contracts, agreements and transactions and any legal proceedings commenced by or against the Company as well as any non-public information that might, if disclosed, be harmful to the Company or its customers.

Any individual in possession of such information must maintain the highest degree of confidentiality and must not disclose same, unless authorized by the Company Management. This obligation remains in effect during the employment of each Individual as well as thereafter.

The privacy of personal data must be protected and treated with confidentiality. Any personal data processing will be made in accordance with the applicable laws and regulations.

The consequences to the Company and the Individuals concerned can be severe if unauthorized disclosure of any non-public, privileged or proprietary information takes place and/or if any unlawful processing of personal data takes place.

Environmental Compliance

All individuals are aware, understand and agree to the Company’s Policy for environmental compliance. In this respect, they accept responsibility for working towards achieving environmental protection continual improvement. No environmental violation whatsoever is to the benefit of the Company and therefore there is zero Company’s tolerance against any such kind of act/omission.

Anti-Money Laundering and Combatting Terrorist Financing

It is Company’s policy to comply with all applicable laws, regulations and recommendations in relation to anti-money laundering and combatting terrorist financing. The identifying information of Company’s existing and potential business partners and customers, as well as the purpose and nature of its business with them are reviewed by the Company on a regular basis. In case the purpose and intended nature of the business relationship are or become suspicious, the Company will refuse the commencement of the business relationship or its continuation, as the case may be. The Company implements procedures ensuring that sanctioned entities and individuals listed in the OFAC (USA), UN and EU sanctions lists, as updated from time to time, are identified and no business is conducted with such entities and individuals.

Anti-corruption, Gifts and Hospitality

It is Company’s policy to comply with all applicable anti-corruption laws, deny any form of bribery and conduct its worldwide business in an ethical, fair and transparent manner. It is strictly prohibited for individuals to offer payment, pay, authorize payment or promise to pay money or anything of value, directly or indirectly, to a Government Official, an existing or potential business partner or any other party, when such payment is intended to influence the latter’s act or decision, to award or retain business, or to induce or reward unethical or illegal behaviour or a breach of duty. The Individuals must not request, receive, solicit, agree to receive, directly or indirectly, money or anything of value that may reasonably be regarded as a bribe or as an improper incentive for the Company’s business activities. Gifts and hospitality must never be offered or provided with a purpose of trying to improperly influence business conduct.

Market Abuse and Market Conduct

While in the course of dealing with charterers, brokers, vendors, suppliers or any other party, an individual becomes aware of material non-public information (“inside information”), accidentally or otherwise, he must report this to his Manager/Supervisor immediately and must not misuse such information.

Ethical conduct

Individuals must act honestly, ethically and fairly towards the Company’s customers, suppliers, competitors and employees. No kind of harassment and/or bullying, including cyber bullying, manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice should take place. The Company has a zero-tolerance approach towards fraud and deception.

Protection and Proper Use of Company Assets

The Company’s assets are only to be used for legitimate business purposes and only by authorized Individuals. This applies both to tangible assets (such as office equipment, telephone, copy machines, etc.) and intangible assets (such as trade secrets, software, confidential information, etc.). Individuals have a responsibility to protect the Company’s assets from theft and loss and to ensure their efficient use. If an Individual becomes aware of theft, waste or misuse of the Company’s assets, such Individual must report this to his Manager/Supervisor or to the Company’s Legal department immediately.

Compliance with Laws, Rules and Regulations

It is the Company’s policy to strictly comply with all laws, rules and regulations that apply to its business. It is the personal responsibility of each Individual to adhere to the standards and restrictions imposed by these laws, rules and regulations and to prevent, detect and report instances of non-compliance. There are no circumstances where the Company will allow that any law or regulatory requirement be disregarded in the conduct of its business.

Harassment and Bullying

The Company promotes a working environment in which harassment & bullying, including cyber bullying are not tolerated, supports the right of everyone to be treated with dignity & respect at work and ensures that all individuals are aware of their responsibilities. Incidents of harassment and/or bullying must be reported to the Company, in order to be treated confidentially and effectively. For further details, please refer to Harassment & Bullying Policy.

Enforcement and Duty to Report

Individuals must report any actual or suspected violation of the Code to their Manager/Supervisor.

All must organize their area of responsibility in such way that violations of the Code can be observed and relevant reports are received and looked into. Violations may result in reprimand, claim for damages and/or termination of employment. Failure of compliance with

the Code of Conduct and Ethics and/or failure to notify the Company of any violation of the Company’s Code of Conduct and Ethics is ground for disciplinary action and/or dismissal.

Open Reporting Line

The Company has adopted an Open Reporting Line by means of which individuals are encouraged to report any known or suspected violation of the Code. The Company has selected an independent supplier to handle such reports. Details for filing a report can be found in the Company’s website under the section “Open Reporting”.

Prohibition of forced labour, child labour and human trafficking

The Company is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour. The Company will not tolerate or condone such activities in any part of its organisation. Company employees, contractors, subcontractors, vendors, suppliers and others through whom the Company conducts business must avoid complicity any practice that constitutes trafficking in persons, forced or child labour and must comply with all applicable laws, regulations and recommendations in relation to the above.

The Company ensures that its employees are of legal working age for their position and complies with ILO and MLC standards, as well as with the laws of Greece for youth employment or student work, such as internships or apprenticeships.

The Company takes measures to verify, evaluate, promote awareness about, and address risks associated with forced labour, child labour and human trafficking in its direct business dealings. Examples of actions undertaken include the following:

• Evaluating and addressing business risk in the area of forced labour and human trafficking.
• Supplier verification of compliance with applicable anti-slavery and human trafficking.
• Awareness of Company employees.

Definitions:

“Child Labour” according to ILO refers to work that deprives children (our Company considers as “children” any person under 18) of their childhood, their potential and their dignity, and that is harmful to their physical and/or mental development. It refers to work that is mentally, or morally dangerous and harmful to children and/or interferes with their schooling by:

• Depriving them of the opportunity to attend school.
• Obliging them to leave school prematurely.
• Requiring them to attempt to combine school attendance with excessively long and heavy work.

Child Labour does not include youth employment or student work, such as internships or apprenticeships, which comply with local laws and regulations.

“Forced Labour” according to ILO Forced Labour Convention or compulsory labour is all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself voluntarily.

“Human Trafficking” means the recruitment, transportation, transfer, harbouring or receipt of persons, by means of threat or use of force or other forms of coercion, abduction, fraud, deception, abuse of power or of a position of vulnerability or of giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs.