Code of Ethics and Code of Conduct

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Code of Ethics and Code of Conduct

The Code of Ethics and the Code of Conduct are based on MYBULK SHIPMANAGEMENT INC.’s beliefs and values, establishing its commitment to honesty and integrity. The primary function of these Codes is to make the fundamental values and principles, guiding the activities of the Company, known within the organization and its managed ships and to all agents, contractors, suppliers, and other cooperating third parties. These Codes aim to ensure that robust and precise values and highest standards of behavior unite the Company and orient individual conduct to confirm the image of correctness, prestige, and good reputation, which have always been MYBULK SHIPMANAGEMENT INC.’s assets. These
Codes are binding to all employees (crew and shore) and to all agents, thus failure to adhere to these Codes will result in our disciplinary procedure being applied and may lead to dismissal (for employees) or to termination of any commercial relationship (for agents). All personnel must behave according to the established principles, laws, rules, and standards.
Employees must:

  •  NEVER be involved in harassment, abuse, discrimination, or child pornography.
  •  NEVER conceal any identified unsafe act or event which affects or could affect health, safety, the environment, and property.
  •  Impartially perform their duties and act in honesty and good faith.
  •  Treat all information regarding operations, projects, or any other work carried out as confidential to the extent that such information does not conflict with Company Policies and is not already disseminated or made generally available to third parties.
  •  Read, understand, and comply with the information contained in these Codes and with any training or other anti-bribery and anti-corruption information they are given.
  •  Avoid any activity that is contrary to the spirit and letter of these Codes and that could lead to, or imply, a breach of these Codes.

MYBULK SHIPMANAGEMENT INC.’s:

  •  Commits to carry out its business fairly, honestly, openly and with integrity in all business transactions and relationships, wherever it may operate.
  •  Does not tolerate bribery, i.e. any type of financial or other advantage of any kind offered, promised or given, whether directly or indirectly, to a Government Official or any other person with the intention to induce or reward the recipient to misuse their position, improperly to perform a function or to provide an unfair business advantage (including facilitation payments, i.e. small bribes to facilitate routine government action).
  •  Has zero tolerance against fraud and corruption, and any allegations of such conduct by any person performing duties on behalf of the Company will be treated with the utmost seriousness. By avoiding bribery, fraud and corruption, the Company can enjoy enhanced reputation, legal compliance, customer and business partner confidence and in general have a competitive advantage in the market.
  •  Strongly prohibits any offer, gift or bribe in any form, including kickbacks in all operations as well as the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from agents, contractors, suppliers, or employees of any such party or government officials.
  •  Ensures compliance with institutional and regulatory framework regarding measures for the avoidance of bribery.
  •  Creates actions and procedures that reflect the “zero tolerance” stance of the Company towards any corruption practices and commits to the prevention, detection and proper investigation of bribery, corruption and fraud.
  •  Records all reports of bribery, corruption and fraud in an official Log, together with relevant information on the event, payment made and individuals involved, which is monitored quarterly so that targeted actions can be taken, and reports them officially.
  •  Aims to be a pioneer in the industry with respect to its initiatives against bribery, fraud and corruption, and participates in industry fora, thus ensuring it has access to the most recent developments in the field of Ethics and Compliance.

Gifts, Corporate Hospitality and Travel Expenses

The following areas are potentially vulnerable to allegations of bribery:

  •  Dealings with service providers and suppliers to the Company
  •  Facilitation payments
  •  Gifts, Corporate Hospitality and Travel Expenses
  •  Political and Charitable Donations
  •  Dealings with foreign public officials
  •  Introductions and referrals.

Persons representing the Company must not accept or offer gifts (including corporate hospitality and travel expenses payments). The Company prohibits employees from directly or indirectly seeking or accepting payments, fees, services or other gratuities outside the normal course of business duties from any person, company or organization. Gifts or cash or
cash equivalents (checks, gift certificates etc.) or other assets of any amount are strictly prohibited. The receipt of sale promotion items of nominal value, occasional meals and reasonable entertainment appropriate to a business relationship are generally acceptable.

All solicitation of or dealings with suppliers, customers and others doing or seeking to do business with the Company will be conducted solely on the basis that reflects both the Company’s best business interests and its high ethical standards. Providing common courtesies, entertainment and occasional meals to individuals involved with aspects of
Company’s business in a manner appropriate to the business relationship and associated with business discussions is permitted, provided expenses incurred are reasonable, customary and authorized. No employee shall authorize any payment or use of any funds for a bribe, “kickback” or similar payment, which is directly or indirectly for the benefit of any
individual, company or organization, or which is designed to secure favored treatment for the Company. Payments or gifts shall not be made directly or indirectly to any government official if such payment or gift is illegal under the laws of the applicable jurisdiction.
Anti-Money Laundering and Combating Terrorist Financing

Money laundering generally refers to financial transactions in which criminals, including
terrorist organizations, attempt to disguise the proceeds, sources or nature of their illicit
activities. Money laundering includes all forms of handling or possessing criminal property,
including possessing the proceeds of one’s own crime, and facilitating any handling or
possession of criminal property. MYBULK SHIPMANAGEMENT INC.:

  •  Prohibits any type of activity that constitutes money laundering.
  •  Requires all its employees to report any suspected event of such nature to the DPA.
  •  Has a very strict sanctions policy in line with the latest requirements of OFAC, OFSI, AMSA, DFAT, EU, Paris PSC MoU, etc. and complies with all applicable laws, regulations and industry recommendations in relation to anti-money laundering and combating terrorist financing.
  •  Regularly reviews information of existing and potential business partners and customers and ensures that persons listed in the OFAC (USA), UN and EU sanctions lists are identified and no business is conducted with them.

Prevention of Tax Evasion
Tax evasion is the offense of not paying or underpaying tax that is due.
MYBULK SHIPMANAGEMENT INC.:

  •  Prohibits any type of activity that constitutes tax evasion or facilitation thereof.
  • Requires all employees to report any request from a third party to facilitate tax evasion or any suspected tax evasion to the Company’s DPA.
  •  Prepares all accounts, invoices and other records relating to dealings with third parties, including suppliers and customers, with strict accuracy and completeness. Accounts are never kept “off-book” to facilitate and never conceal improper payments.

Conflicts of Interests
A conflict of interests occurs when an entity or individual becomes unreliable because of a
clash between personal (or self-serving) interests (e.g. money, status, knowledge,
relationships or reputation) and professional duties or responsibilities, which clash puts into
question whether their actions, judgment or decision-making can be unbiased. MYBULK
SHIPMANAGEMENT INC. requires all employees, crew members and directors to:

  •  Perform their duties and activities relating to their position with the highest level of integrity and independence, in a professional and ethical manner.
  •  Not take part or attempt to influence the Company’s decisions to serve their personal interests, if these are not aligned with the Company’s interests.
  •  Not use their position in the Company or information that they become aware of due to their position in the Company to promote their personal interests.
  •  Not engage in activities that will bring profit to a competitor of the Company.
  •  Not act in ways that compromise the Company’s compliance with the applicable laws.
  •  Report any conflicts of interest that they may face or that other persons relating to the Company are facing as soon as these may arise or come to their attention.

If a conflict comes to the Company’s attention, the Company will attempt to resolve it in a fair
and reasonable manner, after assessing all available facts, including by:

  •  Recusing the conflicted employee from certain decision-making processes
  •  Transferring the conflicted employee to another position or department
  •  If the conflict is unavoidable, creating a mitigation plan to manage the effects of the conflict on the Company
  •  In case of a failure to report a conflict, or in any event of fraudulent behavior, taking disciplinary action
  •  With respect to a conflicted transaction, engaging in such transaction only if after review it has been deemed to be to the best interest of the Company.

 

Date: 15
th July,2025