ANTI-MONEY LAUNDERING POLICY for DYNAMARINe SA

DYNAMARINe SA ("DYNAMARINe" or the "Company") is committed to conducting its business with honesty, integrity and transparency and in compliance with applicable laws and regulations.

The Company does not tolerate money laundering or terrorist financing and shall not knowingly allow its services, business relationships or financial transactions to be used for the concealment, transfer or legitimisation of proceeds derived from criminal activities.

The purpose of this Policy is to establish a proportionate and risk-based framework for identifying, assessing and mitigating money-laundering and terrorist-financing risks arising from the Company's activities.

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

Anti-bribery and corruption matters and compliance with international sanctions are addressed under separate Company policies.

This Policy applies to:

• Directors and management;
• All employees;
• Consultants and persons acting on behalf of DYNAMARINe; and
• Relevant business relationships with clients, suppliers, service providers and other counterparties.

The level of due diligence applied shall be proportionate to the nature of the business relationship and the identified level of risk.

DYNAMARINe shall not knowingly:

• Participate in or facilitate money laundering or terrorist financing;
• Accept funds known or reasonably suspected to originate from criminal activities;
• Assist any person or organisation in concealing the origin, ownership, destination or movement of unlawful funds;
• Participate in transactions intended to disguise the true payer, beneficiary or beneficial owner;
• Accept or make payments having no reasonable connection with the underlying business relationship;
• Participate in arrangements involving fictitious transactions, false invoices or deliberate misrepresentation of services for the purpose of concealing or transferring funds.

No commercial objective or customer relationship shall justify knowingly participating in a transaction involving proceeds of crime or other activity prohibited under this Policy.

DYNAMARINe applies a proportionate, risk-based approach to the prevention of money laundering and terrorist financing.

The Company recognises that its international maritime activities may involve companies, vessels, shipowners, managers, operators, agents, consultants, suppliers and other parties located in different jurisdictions.

Circumstances that may indicate increased AML risk include:

• Unnecessarily complex or opaque corporate structures;
• Difficulty identifying the person or organisation ultimately controlling a counterparty;
• Unexplained involvement of intermediaries or third parties;
• Unexplained payments by or to parties unrelated to the underlying business relationship;
• Significant differences between the contracting party, invoiced party and paying party;
• Unusual payment arrangements without reasonable commercial justification;
• Requests for refunds to accounts different from those from which the original payment was received;
• Transactions that appear inconsistent with the nature of the services being provided;
• Adverse information indicating possible involvement in money laundering, terrorist financing, fraud or other serious financial crime.

The presence of a risk factor does not automatically establish unlawful activity. It requires appropriate review and, where necessary, additional due diligence.

Before establishing a significant new business relationship, DYNAMARINe shall take reasonable measures to understand the identity and nature of the party with whom it is conducting business.

Depending on the nature and assessed risk of the relationship, this may include obtaining or verifying:

• Legal/company name;
• Registered address and country of incorporation;
• Company registration information;
• VAT or tax identification details, where applicable;
• Nature of business;
• Relevant contact persons;
• Ownership or controlling interests where appropriate;
• Invoicing and payment information; and
• Relationship with the relevant vessel or maritime operation, where applicable.

The extent of verification shall be proportionate to the identified risk.

Additional information or verification may be requested where the circumstances of a business relationship or transaction give rise to an increased AML risk.

As a general principle, payments to DYNAMARINe should originate from the client or contractual counterparty receiving the Company's services.

Payments from unrelated third parties should only be accepted where there is a reasonable and documented commercial explanation.

Similarly, DYNAMARINe should normally make payments directly to the supplier, consultant or contractual counterparty providing the relevant services.

Particular attention shall be given to:

• Unexplained third-party payments;
• Overpayments followed by requests for refunds;
• Requests to refund money to a different bank account;
• Requests to split payments without reasonable commercial justification;
• Payments through unrelated companies or individuals;
• Payment arrangements inconsistent with the contractual relationship;
• Unusual cash transactions;
• Requests to incorrectly describe the nature or value of services on invoices.

DYNAMARINe shall not knowingly issue or accept false, misleading or fictitious documentation intended to disguise the true nature of a transaction.

Personnel should remain alert to circumstances that may indicate increased money-laundering or terrorist-financing risk.

Examples include:

• Refusal to provide reasonable company or identification information;
• Inability to reasonably determine who owns or controls a counterparty;
• Unexplained use of shell companies or multiple intermediaries;
• Payment from an apparently unrelated company or individual;
• Unusual or unnecessarily complicated payment arrangements;
• Significant overpayments without reasonable explanation;
• Requests for refunds to third parties or different bank accounts;
• Requests to alter invoices so that they do not accurately reflect the services provided;
• Unusual secrecy concerning ownership, payments or the purpose of an engagement;
• Transactions having no apparent legitimate commercial purpose;
• Pressure to complete a transaction before reasonable checks can be performed.

A red flag does not necessarily mean that money laundering is taking place. It requires the circumstances to be appropriately reviewed.

Any member of personnel who becomes aware of, or reasonably suspects, activity that may involve money laundering or terrorist financing shall promptly report the matter to Management or the person designated by Management for AML matters.

Personnel shall not independently investigate suspected criminal activity beyond obtaining information reasonably required in the ordinary course of business.

Management shall assess the matter and determine the appropriate action, which may include:

• Requesting additional information or documentation;
• Carrying out additional due diligence;
• Suspending acceptance or processing of a payment where appropriate;
• Declining or terminating the business relationship;
• Obtaining specialist legal or compliance advice; or
• Reporting the matter to the competent authorities where required by applicable law.

Personnel must maintain confidentiality regarding such reviews and must not disclose information where such disclosure could prejudice an investigation or would otherwise be prohibited by law.

No member of personnel shall suffer retaliation for reporting a genuine concern in good faith.

DYNAMARINe reserves the right, subject to applicable contractual and legal requirements, to refuse, suspend or terminate a business relationship where:

• Satisfactory information concerning the counterparty cannot reasonably be obtained;
• Ownership or control is deliberately concealed;
• Suspicious payment arrangements cannot reasonably be explained;
• The Company has reasonable grounds to believe that its services or transactions may be connected with money laundering, terrorist financing or proceeds of crime; or
• Continuing the relationship would expose DYNAMARINe to unacceptable legal, financial or reputational risk.

Such decisions shall be taken by appropriate Management personnel.

Relevant records concerning due diligence, AML reviews and associated Management decisions shall be maintained in accordance with the Company's document-control, confidentiality, data-protection and record-retention requirements.

Information obtained for AML purposes shall be treated as confidential and used only for legitimate business, compliance or legal purposes.

Personal data shall be processed in accordance with applicable data-protection requirements, including the EU General Data Protection Regulation (GDPR).

All DYNAMARINe personnel are expected to:

• Comply with this Policy;
• Act honestly and with integrity;
• Remain alert to unusual or suspicious transactions;
• Provide accurate information and documentation;
• Not knowingly circumvent Company controls;
• Promptly report concerns to Management; and
• Cooperate with any internal review relating to potential money-laundering or terrorist-financing concerns.

Appropriate AML awareness and guidance shall be provided to personnel according to their responsibilities and exposure to AML risks.

Failure to comply with this Policy may expose DYNAMARINe and the individuals involved to legal, financial and reputational consequences.

Deliberate violation of this Policy may result in disciplinary action, up to and including termination of employment or cooperation, subject to applicable law.

Where required by law, matters may also be referred to the competent authorities.

Management shall periodically review this Policy and the associated controls, taking into consideration changes in applicable legislation, the Company's activities, geographical exposure, identified risks and experience gained from implementation.

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