Anti-Corruption Policy

Anti-Corruption Policy

Document ID: APM002

01 Dec 2024

Anti-Corruption Policy and Procedures are applicable to all shore-based employees and seafarers of the Company against Bribery and Corruption.

The Company complies with all applicable national and international anti-bribery legislation and all applicable laws within the areas of business and locations where the Company or its subsidiaries operate.

Shore-based employees shall also refer to the Company’s Code of Conduct and Anti- Corruption Procedures which sets out the conduct when obtaining business and guidelines on accepting or offering personal advantages.

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value (including money or other inducements) (herein under called “Payment”) in order to induce or influence an action or decision.

Other than in extreme circumstances, the Company requires that all shore-based employees and seafarers must not make Payments to or receive Payments from any third party, including Public Officials (e.g. Pilots, Customs & Immigrations Officers, Port State Control Officers, Quarantine Officer, etc.) anywhere in the world nor must they initiate or solicit any request to make or receive Payments where such Payments are illegal, unusual, invalid or not in the ordinary course of business, whether it is made directly, passively, or through a third party (such as an agent or distributor).

If any seafarers are being demanded to make or accept Payment which is illegal, unusual, invalid, or not in the ordinary course of business and could be considered a bribe, they must:

• Resist, and
• Report to Company through the

When any shore-based staff is being forced to make or accept Payment which is illegal, unusual, invalid, or not in the ordinary course of business and could be considered a bribe, they must:

• Resist, and
• Seek timely advice from their immediate supervisor who will in turn escalate the matter to a higher level where necessary.

Despite having resisted and reported the Payment demand described above, and it is concluded that there is no other option but to make such Payment taking into account the safety and security of the crew and the vessel, this transaction must be recorded by sending an email to the DPA, with the following information:

• Date of Incident
• Vessel Name
• Port
• Nature of demand made, by whom, and consequence if demand not met
• Actions taken
• Monetary value of cash payment or non-cash

NAME :Capt Shravan Kumar

Designation :CEO