ETHICS POLICY for Code of Business Conduct for DYNAMARINe SA

DYNAMARINe SA ("DYNAMARINe" or the "Company") is committed to conducting its business according to high standards of integrity, professionalism, transparency, independence and ethical conduct.

Our reputation depends not only on the technical quality of the services we provide, but also on the way in which we conduct our business and interact with our clients, personnel, suppliers, business partners and the wider maritime community.

DYNAMARINe conducts its activities in compliance with applicable laws and regulations and expects all personnel to act honestly, responsibly and professionally.

This Corporate Business Ethics Policy and Code of Business Conduct ("the Code") establishes the fundamental ethical principles applicable throughout DYNAMARINe and forms an integral part of the Company's Management System.

The purpose of this Code is to:

• Establish clear standards of ethical and professional conduct;
• Provide guidance for personnel when making business decisions;
• Protect the integrity, independence and reputation of DYNAMARINe;
• Promote responsible and lawful business practices;
• Support a professional and respectful working environment; and
• Provide a framework for identifying, reporting and addressing improper conduct.

The Code cannot anticipate every situation.

Where the appropriate course of action is uncertain, personnel are expected to apply the principles of integrity, legality, fairness, transparency and professional judgement and seek guidance from Management where necessary.

This Code applies to:

• Directors and Top Management;
• Managers;
• All employees;
• Consultants and contractors acting for DYNAMARINe;
• Agents and representatives; and
• Other persons acting on behalf of the Company.

DYNAMARINe also expects its suppliers, service providers and other business partners to conduct their activities according to equivalent principles of lawful and ethical business conduct.

All DYNAMARINe personnel are expected to conduct themselves according to the following principles:

Integrity

We act honestly and ethically and do not compromise our professional judgement for personal or commercial advantage.

Professionalism

We perform our responsibilities with due care, competence, diligence and respect.

Independence and Impartiality

We maintain objectivity and ensure that commercial, personal or other interests do not improperly influence our professional judgement.

Compliance

We comply with applicable laws, regulations, professional requirements and Company policies.

Transparency

Our business activities, transactions and decisions shall have legitimate purposes and be appropriately documented.

Confidentiality

We protect confidential and proprietary information entrusted to us.

Fairness and Respect

We treat colleagues, clients and other stakeholders fairly, professionally and respectfully.

Accountability

Each person is responsible for their actions and for raising concerns when conduct appears inconsistent with this Code.

All personnel are responsible for maintaining high standards of professional behaviour when acting for or representing DYNAMARINe.

Personnel are expected to:

• Act honestly and with integrity;
• Exercise appropriate professional judgement;
• Perform their duties diligently and competently;
• Follow lawful and reasonable Company instructions;
• Treat colleagues, clients and other persons with respect and courtesy;
• Protect the interests and reputation of DYNAMARINe;
• Maintain appropriate professional conduct in both physical and digital communications;
• Avoid conduct that could reasonably undermine confidence in DYNAMARINe or its services; and
• Raise concerns where they become aware of conduct inconsistent with this Code.

Professional responsibilities apply whenever personnel are acting for, representing or may reasonably be associated with DYNAMARINe.

DYNAMARINe's professional reputation depends upon the independence and reliability of its technical judgement.

Personnel shall not allow:

• Commercial pressure;
• Customer pressure;
• Personal relationships;
• Financial interests;
• Gifts or benefits; or
• Other inappropriate influence

to compromise the objectivity, accuracy or integrity of their professional work.

Technical conclusions, assessments, reports, recommendations and other professional deliverables shall reflect the Company's professional judgement and the information reasonably available.

Where circumstances may compromise, or reasonably appear to compromise, independence or impartiality, they shall be disclosed to Management.

All personnel shall conduct Company business in accordance with applicable laws and regulations.

DYNAMARINe maintains specific policies and procedures addressing areas requiring additional controls, including:

• Anti-Money Laundering Policy;
• Anti-Bribery and Corruption Policy;
• Sanctions Compliance Policy;
• Quality Policy;
• Data protection and information-security requirements; and
• Other policies established within the Company's Management Systems.

Personnel whose responsibilities are affected by these requirements shall understand and comply with the applicable policies and procedures.

Where there is uncertainty regarding a legal or compliance requirement, guidance shall be sought before proceeding.

DYNAMARINe has zero tolerance for bribery and corruption.

Personnel shall not offer, promise, give, request or accept any improper payment, benefit or advantage intended to influence a business or official decision.

No person may use an agent, consultant, intermediary or other third party to undertake conduct that DYNAMARINe itself would be prohibited from undertaking.

Detailed requirements concerning gifts, hospitality, facilitation payments, public officials, agents, consultants and other corruption risks are established in the Company's Anti-Bribery and Corruption Policy.

DYNAMARINe shall not knowingly participate in, facilitate or permit its services or transactions to be used for money laundering, terrorist financing or the concealment or transfer of proceeds of crime.

Personnel shall remain alert to unusual or suspicious transactions and shall report concerns in accordance with the Company's Anti-Money Laundering Policy.

DYNAMARINe shall not knowingly conduct prohibited business with sanctioned persons or entities or provide services in violation of sanctions applicable to the Company.

Personnel shall not assist any party in circumventing applicable sanctions.

Sanctions due diligence, screening, vessel-related considerations and escalation requirements are established in the Company's Sanctions Compliance Policy.

Personnel shall avoid situations in which personal, financial, family or other interests improperly influence, or reasonably appear to influence, their professional judgement or decisions on behalf of DYNAMARINe.

Potential conflicts of interest may include:

• Involvement in purchasing or contracting decisions concerning family members, friends or businesses in which personnel have an interest;
• Outside employment or commercial activities that interfere with responsibilities to DYNAMARINe;
• Personal financial interests connected with a client, supplier or transaction;
• Using Company position, information or resources for personal benefit; or
• Relationships that may compromise professional independence or impartiality.

Actual or potential conflicts shall be disclosed to Management.

Disclosure of a conflict does not necessarily mean that the activity is prohibited. Management shall determine whether the conflict can be appropriately managed or whether the relevant person should withdraw from the activity or decision.

Gifts, hospitality and entertainment must never compromise, or appear to compromise, the independence or impartiality of DYNAMARINe or its personnel.

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

Personnel shall not offer or accept gifts or benefits intended to:

• Influence a decision;
• Obtain preferential treatment;
• Create an obligation;
• Reward improper conduct; or
• Obtain or retain business through improper influence.

Reasonable and proportionate business hospitality may be offered or accepted where it has a legitimate business purpose and is not intended to improperly influence the recipient.

Detailed requirements are established in the Company's Anti-Bribery and Corruption Policy.

Company funds, equipment, systems, intellectual property and other assets shall be used responsibly and primarily for legitimate Company purposes.

Company assets include, among other things:

• Financial resources;
• Equipment and facilities;
• Software and information systems;
• Intellectual property;
• Technical methodologies;
• Designs and documentation;
• Business strategies and plans;
• Customer and supplier information;
• Databases and data; and
• Confidential or proprietary information.

Personnel shall not misuse Company assets for personal gain or unauthorised commercial purposes.

Reasonable personal use of Company resources may be permitted where authorised and where it does not interfere with work responsibilities, create material cost or risk, or violate Company policies.

During their responsibilities, personnel may have access to confidential information concerning DYNAMARINe, its clients, suppliers, business partners and other stakeholders.

Such information shall:

• Be used only for legitimate and authorised purposes;
• Be disclosed internally only where there is a legitimate business need;
• Not be disclosed externally without appropriate authority;
• Be protected from unauthorised access, use, alteration or disclosure; and
• Be handled in accordance with applicable data-protection, confidentiality and information-security requirements.

Confidential information includes, as applicable:

• Technical information and reports;
• Customer information;
• Vessel and operational information;
• Commercial information;
• Financial information;
• Business strategies;
• Methodologies and processes;
• Software and systems;
• Intellectual property; and
• Personal data.

Personnel shall not use confidential information obtained through their responsibilities for personal financial or commercial benefit.

The obligation to protect confidential information continues after employment or cooperation with DYNAMARINe ends.

DYNAMARINe respects the privacy of personnel, clients and other persons whose personal data is processed through its activities.

Personal data shall be processed lawfully, fairly and only for legitimate purposes in accordance with applicable data-protection requirements, including the EU General Data Protection Regulation (GDPR).

Personnel shall access and process personal data only where required for their responsibilities and shall apply appropriate confidentiality and security measures.

DYNAMARINe seeks to establish professional business relationships based on quality, competence, reliability, fairness and mutual respect.

Personnel shall:

• Communicate honestly and professionally;
• Accurately represent DYNAMARINe's capabilities and services;
• Avoid misleading statements or commitments;
• Treat suppliers fairly and objectively;
• Base purchasing and commercial decisions on legitimate business considerations;
• Protect confidential information received from customers and suppliers; and
• Comply with the Company's AML, anti-bribery and sanctions requirements.

Commercial success shall not be pursued through unlawful or unethical practices.

Agents, consultants, representatives and other persons acting on behalf of DYNAMARINe shall be engaged for legitimate and identifiable business purposes.

Their arrangements shall be transparent and appropriately documented.

Agreements shall clearly establish, as applicable:

• The services to be performed;
• Responsibilities of the parties;
• The basis for remuneration;
• Applicable commissions or fees; and
• Relevant compliance requirements.

Payments shall be reasonable and proportionate to legitimate services actually provided.

No third party may be used to circumvent this Code or any other DYNAMARINe policy.

DYNAMARINe competes on the basis of the quality, competence, innovation and value of its services.

Personnel shall comply with applicable competition laws and shall not participate in improper arrangements with competitors concerning matters such as:

• Pricing;
• Allocation of customers or markets;
• Manipulation of tenders;
• Commercially sensitive non-public information; or
• Other activities that unlawfully restrict competition.

Normal professional interaction with competitors at industry events, conferences, associations and other legitimate forums is permitted, provided that confidential or competitively sensitive information is not improperly exchanged.

DYNAMARINe may legitimately obtain and analyse publicly available information concerning competitors and the maritime market.

The Company shall not obtain competitive information through unlawful, deceptive or improper means.

Personnel shall not:

• Steal or improperly obtain trade secrets;
• Encourage disclosure of confidential information belonging to competitors;
• Request newly hired personnel to disclose confidential information belonging to former employers; or
• Misrepresent their identity or purpose in order to obtain proprietary information.

DYNAMARINe is committed to maintaining a professional, positive and constructive working environment.

All personnel shall be treated with dignity, fairness and respect.

The Company does not tolerate unlawful discrimination, harassment, bullying, intimidation or other inappropriate workplace conduct.

Employment and professional decisions shall be based on legitimate business considerations, including competence, performance, qualifications and Company requirements.

Personnel are expected to be fit to perform their responsibilities safely and effectively.

No person shall knowingly undertake work where their ability to perform their responsibilities competently or safely is materially impaired.

Where circumstances may affect an individual's ability to perform safety-critical or professionally significant responsibilities, appropriate guidance shall be sought from Management.

DYNAMARINe's records, reports, invoices, financial information and other business documentation shall accurately reflect the underlying activities and transactions.

Personnel shall not knowingly:

• Falsify records;
• Create misleading documentation;
• Conceal material information where disclosure is required;
• Knowingly provide false information to clients, authorities, auditors or other legitimate stakeholders; or
• Deliberately misrepresent Company activities or transactions.

Errors identified in Company records or professional deliverables shall be appropriately reported and corrected.

Company information systems, software, digital services, communication tools and data shall be used responsibly, securely and for legitimate purposes.

Personnel shall:

• Protect Company credentials and access rights;
• Respect confidentiality and intellectual property;
• Comply with applicable information-security requirements;
• Avoid unauthorised software or system access;
• Not deliberately introduce malicious or harmful material into Company systems; and
• Exercise appropriate professional judgement when using digital technologies, including artificial intelligence and automated tools.

Technology shall support professional judgement and shall not be used in a manner that compromises the confidentiality, integrity, accuracy or quality of DYNAMARINe's services.

As a maritime organisation, DYNAMARINe recognises its responsibility to contribute to the safety of life and property at sea and the protection and preservation of the marine environment.

The Company seeks to conduct its activities responsibly and supports initiatives and services that contribute to safer and more sustainable maritime operations.

DYNAMARINe does not tolerate:

• Child labour;
• Forced or compulsory labour;
• Unlawful employment practices; or
• Other serious abuses of fundamental employment rights

within its own activities.

Where serious unethical or unlawful practices are identified within a relevant business relationship, Management shall evaluate the appropriate response.

All personnel are encouraged and expected to raise concerns where they reasonably believe that:

• This Code has been violated;
• Another Company policy has been violated;
• Unlawful activity may have occurred;
• Company or client interests may be materially compromised; or
• Conduct may expose DYNAMARINe to significant ethical, legal or reputational risk.

Concerns may be reported to Management or through any reporting mechanism established by the Company.

Personnel should raise concerns in good faith and provide information they reasonably believe to be accurate.

DYNAMARINe does not tolerate retaliation against any person who, in good faith:

• Reports suspected misconduct;
• Raises an ethical or compliance concern;
• Refuses to participate in unlawful or unethical activity; or
• Cooperates with an investigation.

Retaliation itself constitutes a violation of this Code.

Knowingly submitting false or malicious allegations is not protected by this provision.

Management shall appropriately review credible allegations of misconduct.

All personnel are expected to cooperate honestly with authorised internal or external investigations.

Personnel shall not:

• Deliberately conceal relevant information;
• Knowingly provide false or misleading information;
• Interfere with an investigation; or
• Retaliate against persons involved in an investigation.

Investigations shall be conducted with appropriate confidentiality, fairness and respect for the persons involved.

Violations of this Code are taken seriously.

Depending on the nature and severity of the violation, appropriate action may include:

• Guidance or additional training;
• Corrective action;
• Disciplinary action;
• Termination of employment or cooperation;
• Suspension or termination of a business relationship; or
• Referral to competent authorities where required or appropriate.

Any action shall be taken in accordance with applicable law and Company procedures.

Management is responsible for promoting an ethical culture and ensuring that the principles of this Code are reflected in Company activities.

Managers are expected to:

• Lead by example;
• Promote integrity and professional conduct;
• Ensure personnel understand relevant policies;
• Provide guidance when ethical questions arise;
• Take concerns seriously;
• Ensure concerns are appropriately reviewed;
• Protect persons raising concerns in good faith; and
• Take appropriate action where violations are identified.

Every person covered by this Code is responsible for:

• Reading and understanding it;
• Complying with its principles;
• Completing relevant training;
• Seeking guidance when uncertain;
• Reporting suspected violations; and
• Supporting DYNAMARINe's commitment to ethical and professional business conduct.

When faced with a difficult decision, personnel should consider:

Is it lawful?

Is it consistent with DYNAMARINe's policies and values?

Is it professionally and ethically appropriate?

Would I be comfortable if the decision were reviewed by Management, a client, an auditor or made public?

If the answer is unclear, guidance should be sought before proceeding.

DYNAMARINe shall provide appropriate ethics and compliance awareness to personnel according to their responsibilities.

Relevant policies shall be made available to personnel, and additional guidance or training shall be provided where activities present increased legal, ethical or compliance risks.

Top Management shall periodically review this Code to ensure its continuing suitability and effectiveness.

The review shall consider, as appropriate:

• Changes in applicable legislation;
• Changes in DYNAMARINe's activities and services;
• Developments within the maritime industry;
• Identified ethical and compliance risks;
• Incidents and lessons learned;
• Audit and Management Review findings; and
• Opportunities for improvement.

This Code and its supporting policies and procedures shall be updated where necessary.

Top Management of DYNAMARINe is committed to maintaining a culture in which integrity, professionalism, independence, impartiality, quality and lawful conduct take precedence over improper commercial advantage.

DYNAMARINe expects the same fundamental standards from persons and organisations acting on its behalf.

All personnel are encouraged to seek guidance whenever the appropriate course of conduct is uncertain.