SANCTIONS COMPLIANCE POLICY for DYNAMARINe SA

DYNAMARINe SA ("DYNAMARINe" or the "Company") is committed to conducting its business in compliance with applicable international and national sanctions and restrictive measures.

DYNAMARINe shall not knowingly provide services, make funds or economic resources available, or otherwise participate in transactions or business relationships that are prohibited by sanctions applicable to the Company.

The purpose of this Policy is to establish a proportionate and risk-based framework for identifying, assessing and managing sanctions-related risks arising from DYNAMARINe's international maritime activities.

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

Anti-money laundering and anti-bribery and corruption matters 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.

It applies to all Company activities and business relationships where sanctions may be relevant, including relationships involving:

• Clients;
• Vessels;
• Shipowners;
• Vessel managers and operators;
• Charterers, where relevant;
• Suppliers;
• Service providers;
• Consultants;
• Agents and intermediaries; and
• Other relevant counterparties.

DYNAMARINe shall comply with sanctions and restrictive measures applicable to the Company under the laws and regulations of the jurisdictions in which it operates.

As a company established within the European Union, particular consideration shall be given to sanctions and restrictive measures adopted by the European Union and implemented under applicable Greek and EU law.

Where relevant to a particular transaction, service, contractual relationship, payment or jurisdiction, DYNAMARINe may also consider other applicable sanctions regimes and restrictions.

Where different sanctions regimes may apply or potentially conflict, the matter shall be referred to Management and, where necessary, specialist legal advice shall be obtained before proceeding.

DYNAMARINe shall not knowingly:

• Provide services where doing so is prohibited by applicable sanctions;
• Conduct prohibited business with a sanctioned person or entity;
• Make funds or economic resources available to a sanctioned person or entity where prohibited;
• Participate in a transaction prohibited by applicable sanctions;
• Assist another party in circumventing applicable sanctions;
• Structure or modify a transaction for the purpose of avoiding sanctions restrictions;
• Conceal the identity, ownership or control of a party in order to avoid sanctions requirements;
• Knowingly provide false or misleading information concerning a sanctions-related matter; or
• Use an agent, intermediary, affiliate or other third party to undertake an activity that DYNAMARINe itself would be prohibited from undertaking.

Compliance with applicable sanctions takes precedence over commercial considerations.

No client relationship, commercial opportunity or financial benefit justifies knowingly violating or circumventing applicable sanctions.

DYNAMARINe applies a proportionate and risk-based approach to sanctions compliance.

The extent of sanctions due diligence shall depend on the nature of the service, parties involved, vessel, jurisdictions, transaction and other relevant circumstances.

Factors that may indicate increased sanctions risk include:

• Involvement of a country or territory subject to significant sanctions or restrictive measures;
• Involvement of a sanctioned or potentially sanctioned person or entity;
• Unclear or unusually complex ownership structures;
• Difficulty identifying the beneficial owner or controlling interests of a company;
• Recent or unexplained changes in ownership or management;
• Unusual involvement of intermediaries;
• Payments involving unrelated parties or jurisdictions;
• Vessels with unusual changes of ownership, management, name, flag or registration;
• Unusual vessel trading patterns or activities;
• Unexplained inconsistencies between the stated purpose of the service and the circumstances of the vessel or transaction;
• Attempts to conceal parties involved in the transaction or operation; or
• Other circumstances indicating possible sanctions circumvention.

The presence of a risk factor does not automatically mean that an activity is prohibited. It requires appropriate review before the Company proceeds.

DYNAMARINe shall undertake reasonable sanctions due diligence appropriate to the identified risk.

Depending on the nature of the engagement, this may include identifying and, where appropriate, verifying:

• The contractual client;
• Registered company details;
• Country of incorporation;
• Beneficial ownership and controlling interests;
• Relevant directors or controlling persons;
• Vessel identity and IMO number;
• Registered vessel owner;
• Vessel manager or operator;
• Charterer or other commercially relevant party, where appropriate;
• Vessel flag;
• Relevant banks or payment parties;
• Geographical areas connected with the engagement; and
• Other parties relevant to determining whether the proposed activity is permitted.

The level of due diligence shall be proportionate to the sanctions risk associated with the engagement.

Additional or enhanced due diligence shall be undertaken where circumstances indicate increased risk.

Where appropriate to the nature and risk of the engagement, DYNAMARINe shall screen relevant persons, entities and vessels against applicable sanctions information.

Screening may include:

• Clients;
• Beneficial owners or controlling persons;
• Vessel registered owners;
• Vessel managers and operators;
• Vessels;
• Relevant intermediaries; and
• Other parties where their involvement may affect sanctions compliance.

A potential match shall not automatically be treated as a confirmed sanctions designation.

Where a potential match is identified, appropriate information shall be reviewed to determine whether the person, entity or vessel concerned is the party appearing on the relevant sanctions list.

No engagement presenting an unresolved material sanctions concern shall proceed without Management review.

DYNAMARINe recognises that sanctions restrictions may apply not only to persons or entities explicitly named on sanctions lists but, depending on the applicable sanctions regime, also to entities owned or controlled by sanctioned persons or entities.

Accordingly, screening a company name alone may not always be sufficient.

Where appropriate to the identified risk, reasonable measures shall be taken to understand the ownership and control of relevant counterparties.

Particular attention shall be given where:

• Ownership is obscured through multiple corporate layers;
• Shareholders or controlling interests cannot reasonably be identified;
• Ownership has changed shortly before or after sanctions were imposed;
• Ownership has been divided among multiple parties under unusual circumstances;
• There are indications that a sanctioned person may continue to exercise control despite a formal change in ownership; or
• The available information concerning ownership or control is inconsistent.

Where ownership or control cannot reasonably be established and the sanctions risk is material, the matter shall be escalated to Management.

Because DYNAMARINe operates within the maritime industry, vessel-related sanctions risks shall receive particular attention.

Where relevant to the service being provided, DYNAMARINe may consider:

• Vessel name and IMO number;
• Flag;
• Registered owner;
• Beneficial ownership or control;
• Technical or commercial manager;
• Operator;
• Relevant chartering interests;
• Recent changes of vessel name;
• Recent changes of ownership or management;
• Recent changes of flag;
• Relevant trading history or geographical activity; and
• Other information that may reasonably indicate increased sanctions or circumvention risk.

The IMO number should be used where available as the primary vessel identifier because vessel names and flags may change.

A change of vessel name, ownership, manager or flag is not in itself evidence of sanctions evasion. However, unexplained or repeated changes combined with other risk factors may require additional review.

Sanctions compliance shall be considered not only in relation to payments received by DYNAMARINe but also in relation to the nature and ultimate beneficiary of the Company's services.

This may include, as applicable:

• Maritime consultancy;
• Ship-to-ship related services;
• Marine technical assessments;
• Risk assessments;
• Mooring studies;
• Training;
• Software and digital services;
• Technical documentation;
• Engineering or advisory services; and
• Other maritime support services.

Before providing a service presenting increased sanctions risk, consideration shall be given to whether:

• The service itself is restricted;
• The recipient of the service is restricted;
• The vessel involved is subject to applicable restrictions;
• The service would directly or indirectly benefit a sanctioned person or entity where prohibited; or
• The circumstances indicate that the service may facilitate circumvention of applicable sanctions.

Payments connected with Company services shall be consistent with the underlying contractual relationship.

Particular attention shall be given where:

• Payment is proposed by an unrelated third party;
• Payment originates from an unexpected country or jurisdiction;
• A different company is introduced as payer without reasonable explanation;
• Payment routes are changed following a sanctions-related query;
• A counterparty requests payment through an intermediary without reasonable commercial justification; or
• Banking arrangements appear designed to conceal the origin, destination or parties to a transaction.

Where a payment creates a sanctions concern, it shall be reviewed before being accepted, processed or refunded as appropriate.

The Anti-Money Laundering Policy shall apply separately to money-laundering risks associated with payments.

DYNAMARINe shall not knowingly or intentionally participate in activities designed to circumvent applicable sanctions.

Personnel shall remain alert to arrangements where the form of a transaction differs from its apparent commercial substance.

Potential circumvention indicators may include:

• Unexplained use of intermediary companies;
• Newly established companies with no clear commercial history;
• Sudden changes in ownership or control;
• Unexplained changes in vessel ownership, management or flag;
• Unnecessary complexity in contractual or payment arrangements;
• Involvement of third countries without a clear commercial reason;
• Reluctance to identify the ultimate customer or beneficiary;
• Inconsistent information concerning the purpose of the service;
• Requests to remove or modify information identifying relevant parties;
• Requests to issue documentation to a party different from the actual recipient of the service;
• Requests to structure services or payments in a way apparently intended to avoid sanctions restrictions; or
• Refusal to provide information reasonably required for sanctions due diligence.

No single indicator necessarily establishes sanctions circumvention. The overall circumstances shall be considered.

Personnel should remain alert to circumstances including:

• A sanctions screening match;
• Refusal to provide reasonable company or ownership information;
• Inability to identify relevant ownership or controlling interests;
• Involvement of companies with no apparent connection to the underlying maritime activity;
• Unusual secrecy concerning vessel ownership or operation;
• Frequent or unexplained changes of vessel name, ownership, manager or flag;
• Unexplained changes to contractual parties after sanctions concerns are raised;
• Unusual payment routes;
• Payment by unrelated third parties;
• Requests to omit relevant vessel, company or ownership information from documentation;
• Discrepancies between information supplied by the customer and information available from reliable independent sources;
• Unexplained involvement of high-risk jurisdictions;
• Attempts to pressure personnel to proceed before sanctions checks have been completed; or
• Statements suggesting that an arrangement has been deliberately structured to avoid restrictions.

A sanctions red flag does not automatically mean that the proposed activity is prohibited. It requires further review.

Personnel shall promptly refer a matter to Management where:

• A sanctions screening result cannot be satisfactorily resolved;
• There is uncertainty regarding ownership or control;
• The legality of providing a service is unclear;
• Circumstances indicate possible sanctions circumvention;
• Relevant information has been withheld or appears misleading;
• An existing client or vessel becomes subject to sanctions; or
• Any other material sanctions concern arises.

The relevant activity shall not proceed until the concern has been appropriately assessed where proceeding could result in a sanctions violation.

Management may determine that additional information, enhanced due diligence or specialist legal advice is required.

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

• The activity is prohibited by applicable sanctions;
• A relevant party is subject to restrictions that prohibit the proposed activity;
• The Company cannot reasonably establish relevant ownership or control;
• Requested due diligence information is deliberately withheld;
• There are reasonable grounds to believe that the proposed activity is intended to circumvent sanctions;
• A material sanctions concern cannot be satisfactorily resolved; or
• Continuing the relationship would expose DYNAMARINe to unacceptable legal or regulatory risk.

Where an existing relationship becomes affected by new or amended sanctions, Management shall determine the appropriate action in accordance with applicable legal requirements.

Termination or suspension shall be undertaken in a lawful and controlled manner.

Personnel shall not advise a customer or other party on how to restructure a transaction for the purpose of avoiding applicable sanctions.

Where DYNAMARINe declines or suspends an engagement because of sanctions concerns, personnel shall exercise appropriate care regarding the information communicated to the counterparty.

Where necessary, guidance shall be obtained from Management or legal advisers concerning what information may appropriately be disclosed.

Appropriate records of sanctions-related due diligence shall be retained in accordance with the Company's document-control and record-retention requirements.

Depending on the circumstances, records may include:

• Information obtained concerning counterparties;
• Sanctions screening results;
• Ownership information;
• Vessel information;
• Enhanced due diligence undertaken;
• Explanations or supporting documentation obtained from clients;
• Management decisions; and
• Specialist or legal advice obtained.

Records shall be sufficient to demonstrate, where appropriate, the reasonable steps taken by DYNAMARINe to assess sanctions compliance.

Information shall be treated as confidential and processed in accordance with applicable data-protection requirements.

All DYNAMARINe personnel are expected to:

• Comply with this Policy;
• Remain alert to sanctions-related risks;
• Provide accurate information;
• Conduct required checks within their area of responsibility;
• Not knowingly circumvent Company sanctions controls;
• Not assist another party in circumventing sanctions;
• Escalate potential sanctions concerns promptly;
• Maintain appropriate records; and
• Cooperate with internal reviews.

Where personnel are uncertain whether an activity is permitted, they shall seek guidance before proceeding.

Management is responsible for overseeing implementation of this Policy.

Management shall, as appropriate:

• Ensure that sanctions risks relevant to the Company's activities are considered;
• Establish appropriate sanctions screening and due diligence arrangements;
• Review escalated sanctions concerns;
• Determine when enhanced due diligence is necessary;
• Obtain external specialist or legal advice where required;
• Ensure appropriate records are maintained; and
• Periodically review the effectiveness of the Company's sanctions controls.

DYNAMARINe shall provide appropriate sanctions awareness and guidance to personnel based on their responsibilities and exposure to sanctions risks.

Personnel involved in:

• Client acceptance;
• Vessel-related services;
• Commercial activities;
• Contracting;
• Invoicing and payments; or
• Other activities presenting increased sanctions exposure

shall receive appropriate information regarding the Company's sanctions procedures and relevant red flags.

Any person who becomes aware of a potential violation of this Policy shall promptly report the matter to Management.

DYNAMARINe shall not tolerate retaliation against personnel who raise genuine sanctions concerns in good faith.

Management shall determine whether the matter requires further investigation, specialist legal advice, notification to a competent authority or other action required by applicable law.

Failure to comply with this Policy may expose DYNAMARINe and the persons involved to serious legal, regulatory, 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.

DYNAMARINe may also suspend or terminate relationships with clients, agents, consultants, suppliers or other business partners that engage in conduct contrary to this Policy.

Sanctions regimes change frequently.

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

• Changes in applicable sanctions;
• Developments in sanctions guidance;
• Changes in the Company's services;
• Geographical exposure;
• Developments within the maritime industry;
• Identified sanctions risks and incidents; and
• Experience gained from implementation.

The Policy and related procedures shall be updated where necessary to maintain their continuing suitability and effectiveness.

Top Management of DYNAMARINe is committed to ensuring that the Company does not knowingly conduct prohibited business or permit its services to be used to circumvent applicable sanctions.

DYNAMARINe shall decline business where necessary to comply with applicable sanctions, irrespective of the commercial value of the opportunity.

All personnel are expected to support this commitment and to seek guidance whenever the sanctions implications of an activity are uncertain.