ANTI-BRIBERY AND CORRUPTION POLICY for DYNAMARINe SA

DYNAMARINe SA ("DYNAMARINe" or the "Company") is committed to conducting its business with honesty, integrity, transparency, independence and impartiality.

DYNAMARINe has zero tolerance for bribery and corruption in any form.

The Company shall not offer, promise, give, request, agree to receive or accept any financial or other advantage intended to improperly influence a business decision, secure an improper advantage, reward improper conduct or otherwise influence a person in the performance of their duties.

The purpose of this Policy is to establish the principles and controls applied by DYNAMARINe for preventing, identifying and addressing bribery and corruption risks arising from its activities.

This Policy supplements the Company's Corporate Business Ethics Policy and Code of Business Conduct.

Money laundering and sanctions compliance are addressed under separate Company policies.

This Policy applies to:

• Directors and Management;
• All employees;
• Consultants and contractors;
• Agents and representatives; and
• Any other person acting for or on behalf of DYNAMARINe.

DYNAMARINe also expects its suppliers, service providers and other business partners to conduct their activities in accordance with equivalent principles of integrity and lawful business conduct.

No person acting for or on behalf of DYNAMARINe may circumvent this Policy through the use of a third party.

DYNAMARINe prohibits bribery and corruption, whether direct or indirect, in connection with any of its business activities.

No person acting for or on behalf of DYNAMARINe shall:

• Offer, promise or give a bribe or improper advantage;
• Request, agree to receive or accept a bribe or improper advantage;
• Make or authorise an improper payment;
• Offer an advantage intended to improperly influence a decision;
• Provide an improper advantage in order to obtain or retain business;
• Provide an improper advantage in order to obtain favourable treatment;
• Use an agent, consultant, representative or other intermediary to make an improper payment or provide an improper advantage;
• Disguise an improper payment as a legitimate business expense, commission, consultancy fee or other transaction; or
• Retaliate against any person who refuses to participate in bribery or who reports a concern in good faith.

These principles apply irrespective of local business practices, commercial pressures, competitive circumstances or the value of the business opportunity concerned.

No business opportunity or commercial advantage justifies a violation of this Policy.

For the purposes of this Policy, bribery includes offering, promising, giving, requesting or accepting anything of value where the intention is to improperly influence the actions or decisions of another person.

An improper advantage does not have to consist of cash.

Depending on the circumstances, it may include:

• Gifts;
• Entertainment or hospitality;
• Travel or accommodation;
• Commissions or fees;
• Discounts or preferential commercial terms;
• Employment or internship opportunities;
• Services provided without appropriate charge;
• Personal favours;
• Charitable or other contributions;
• Benefits provided to family members, friends or associates; or
• Any other financial or non-financial advantage.

The value of an advantage is not the only consideration. Even an advantage of relatively low monetary value may be improper if its purpose is to influence a decision or secure preferential treatment.

Particular care shall be exercised in dealings with public officials.

For the purposes of this Policy, a public official may include persons employed by or acting on behalf of:

• National, regional or local governments;
• Government departments or agencies;
• Port, customs or maritime authorities;
• Regulatory authorities;
• State-owned or state-controlled organisations;
• International public organisations; or
• Persons performing public functions.

DYNAMARINe personnel shall not offer, promise or provide any improper advantage to a public official for the purpose of influencing an official action or obtaining an improper business advantage.

Where there is uncertainty regarding whether a person should be regarded as a public official, the matter should be referred to Management before providing any benefit or making any commitment.

DYNAMARINe prohibits facilitation payments.

A facilitation payment is an unofficial payment or benefit provided to secure or accelerate a routine action to which the Company or another party is already entitled.

Examples may include unofficial payments intended to accelerate:

• Permits or approvals;
• Customs processes;
• Port or administrative formalities;
• Inspections;
• Certificates or documentation; or
• Other routine governmental or administrative actions.

Such payments shall not be made even where they may be regarded as customary local business practice.

Where a payment is demanded and there is uncertainty regarding its legitimacy, personnel shall refer the matter to Management before proceeding whenever reasonably possible.

Nothing in this Policy requires personnel to place their personal health or safety at risk. Where a payment is made because of an immediate and credible threat to personal safety, the circumstances shall be reported to Management as soon as reasonably practicable and accurately recorded.

DYNAMARINe personnel shall not offer or accept gifts where the gift could reasonably be considered intended to influence a business decision, obtain preferential treatment, create an obligation or compromise the recipient's independence or impartiality.

Cash and cash-equivalent gifts shall not be offered or accepted.

Particular caution shall be exercised where gifts are offered:

• During contract negotiations;
• During a tender or supplier-selection process;
• Before or during an important business decision;
• In connection with an assessment, inspection, evaluation or other activity requiring independence or impartiality; or
• To or from public officials.

Where personnel are uncertain whether a gift is appropriate, the matter shall be referred to Management.

Reasonable and proportionate hospitality may be offered or accepted where it:

• Has a legitimate business purpose;
• Is appropriate to the business relationship;
• Is reasonable in nature and value;
• Is not intended to improperly influence a decision;
• Does not create an obligation on the recipient;
• Is permitted under applicable law and the recipient's organisational rules; and
• Would not reasonably cause embarrassment to DYNAMARINe if publicly disclosed.

Hospitality or entertainment that is excessive, frequent, inappropriate or intended primarily to obtain favour or influence shall not be offered or accepted.

Where DYNAMARINe pays travel or accommodation expenses for another party, or another party proposes to pay such expenses for DYNAMARINe personnel, there must be a legitimate business purpose.

The arrangements shall be reasonable and proportionate to that purpose.

Travel, accommodation or related benefits shall not be provided as a means of obtaining an improper business advantage or influencing a decision.

Where appropriate, travel and accommodation should be paid directly to the relevant service provider rather than provided as cash or reimbursement without supporting documentation.

DYNAMARINe recognises that the use of agents, consultants, representatives and other intermediaries may create increased bribery and corruption risks.

Such parties shall only be engaged for legitimate business purposes.

The nature of their services and remuneration shall be transparent.

Agreements shall, as appropriate, clearly establish:

• The services to be provided;
• The basis of remuneration;
• Commissions or fees;
• Responsibilities of the parties; and
• Relevant compliance obligations.

Fees and commissions must be reasonable and proportionate to the legitimate services provided.

Personnel shall be particularly alert where an intermediary:

• Requests unusually high commissions;
• Requests payment without providing identifiable services;
• Requests payment to an unrelated third party;
• Requests payment to an unusual or unrelated jurisdiction;
• Requests cash payments;
• Refuses to document the services being provided;
• Claims to have an unusually close relationship with a public official or decision-maker; or
• Suggests that payments or benefits are necessary to obtain business or approvals.

No agent, consultant or intermediary may make a payment or provide a benefit on behalf of DYNAMARINe that DYNAMARINe itself would be prohibited from making.

DYNAMARINe seeks to conduct business with organisations that operate legitimately and ethically.

Where the nature or circumstances of a business relationship indicate an increased corruption risk, reasonable due diligence may be undertaken before establishing or continuing the relationship.

DYNAMARINe reserves the right to refuse or terminate a relationship where there are reasonable grounds to believe that a business partner has engaged in bribery or corruption in connection with DYNAMARINe's activities.

Charitable contributions and sponsorships must be legitimate, transparent and made for genuine charitable, educational, social or commercial purposes.

They shall not be used as a means of:

• Influencing a business decision;
• Obtaining an improper advantage;
• Rewarding a customer, public official or other decision-maker; or
• Indirectly providing a prohibited personal benefit.

Appropriate approval shall be obtained before significant charitable contributions or sponsorship commitments are made on behalf of DYNAMARINe.

Company funds, resources or assets shall not be used to make political contributions for the purpose of obtaining or retaining business or securing an improper advantage.

Any political activity undertaken by personnel in their private capacity must be clearly separate from DYNAMARINe and must not involve unauthorised use of Company funds, resources, name or representation.

Personnel shall avoid situations where personal interests could improperly influence, or reasonably appear to influence, decisions taken on behalf of DYNAMARINe.

Potential conflicts may arise through personal, family, financial or other relationships with customers, suppliers, consultants or other business partners.

Any actual or potential conflict of interest that could affect a business decision shall be disclosed to Management.

Personnel shall not use their position within DYNAMARINe to obtain an improper personal benefit for themselves, family members, friends or associates.

All Company transactions shall be accurately and transparently recorded.

DYNAMARINe shall not:

• Create false or misleading records;
• Issue fictitious invoices;
• Deliberately misdescribe payments;
• Maintain undisclosed accounts for improper purposes;
• Conceal improper payments within legitimate expense categories; or
• Falsify supporting documentation.

Expenses, commissions, consultancy fees, hospitality, travel and other payments must accurately reflect their actual purpose.

Personnel responsible for approving expenditure shall take reasonable measures to ensure that payments are legitimate, appropriately documented and consistent with this Policy.

Personnel should remain alert to circumstances that may indicate an increased risk of bribery or corruption.

Examples include:

• Requests for unexplained commissions or fees;
• Requests for cash payments;
• Requests for payments to unrelated third parties;
• Requests for payments to personal accounts;
• Unusually generous gifts or hospitality;
• Pressure to provide gifts or benefits before a decision is made;
• Requests for unofficial payments to accelerate routine administrative procedures;
• Invoices that do not clearly describe the services provided;
• Consultants or intermediaries whose role or services cannot be adequately explained;
• Excessive commissions compared with the apparent value of the services;
• Requests to conceal the identity of the recipient of a payment;
• A person claiming that a payment is necessary because "this is how business is done" locally;
• Requests to provide benefits to relatives, friends or associates of a decision-maker; or
• Attempts to circumvent normal Company approval or documentation procedures.

The presence of a red flag does not necessarily establish that bribery or corruption has occurred. It requires appropriate review before proceeding.

All personnel have a responsibility to raise concerns regarding suspected bribery, corruption or violations of this Policy.

Any person who:

• Is requested to make an improper payment;
• Is offered an improper advantage;
• Becomes aware of suspicious conduct;
• Believes that an agent or other party may be acting improperly on behalf of DYNAMARINe; or
• Otherwise has reasonable grounds for concern,

shall promptly report the matter to Management or the person designated by Management for compliance matters.

Personnel should not independently investigate suspected criminal conduct beyond obtaining information reasonably required in the normal course of their responsibilities.

Management shall assess the matter and determine the appropriate response, which may include seeking additional information, suspending the relevant transaction or relationship, conducting an internal review, obtaining specialist legal advice, terminating a business relationship or referring the matter to competent authorities where appropriate or required by law.

DYNAMARINe shall not tolerate retaliation against any person who:

• Refuses to participate in bribery or corruption;
• Refuses to make an improper payment;
• Raises a genuine concern in good faith; or
• Cooperates with an investigation concerning suspected misconduct.

This protection applies even where a refusal to make an improper payment results in DYNAMARINe losing business or experiencing a commercial disadvantage.

Knowingly making false or malicious allegations is not protected under this provision.

All DYNAMARINe personnel are responsible for understanding and complying with this Policy.

Personnel are expected to:

• Conduct business honestly and transparently;
• Avoid conduct that could compromise their independence or impartiality;
• Remain alert to bribery and corruption risks;
• Obtain Management guidance where the appropriate course of action is unclear;
• Maintain accurate records;
• Report suspected violations; and
• Cooperate with any internal review.

DYNAMARINe shall provide appropriate awareness and guidance to personnel according to their responsibilities and exposure to bribery and corruption risks.

DYNAMARINe considers violations of this Policy to be serious misconduct.

Failure to comply may result in disciplinary action, up to and including termination of employment or cooperation, subject to applicable law.

DYNAMARINe may also suspend or terminate relationships with consultants, agents, suppliers or other business partners that violate the principles of this Policy.

Where required by law or considered appropriate following legal advice, matters may be referred to competent authorities.

Management shall periodically review this Policy and the associated controls, taking into consideration:

• Changes in applicable legislation;
• Developments in the Company's activities;
• Geographical and business exposure;
• Identified bribery and corruption risks;
• Incidents or concerns identified during implementation; and
• Opportunities to improve the effectiveness of the Company's controls.

The Policy shall be updated where necessary to maintain its continuing suitability and effectiveness.

Top Management of DYNAMARINe is committed to maintaining a business environment in which integrity, transparency, independence and impartiality take precedence over improper commercial advantage.

DYNAMARINe would rather decline or lose business than obtain or retain it through bribery, corruption or improper influence.

All personnel are expected to support this commitment and to seek guidance whenever there is uncertainty regarding the appropriate course of conduct.