Dear Agent,

Our Port Agents around the world are on the front line with respect to Stolt Tankers’ dealings with local officials
and counterparties (port authorities, customs/immigration/environmental/health officials, pilots, inspectors,
surveyors, terminal staff, loading masters). Stolt-Nielsen has updated its Global Anti-Bribery and Corruption
(AB&C) Policy, and we thought this was a good time to advise you all of the highlights of this update, reinforcing
the principles of Stolt-Nielsen’s Code of Business Conduct, which is already part of our agency agreements.

I provide below the highlights from the Policy for your guidance. Should you have any questions with respect to
this update, please contact Norman O’Shaughnessy (NOO@stolt.com), or the Stolt person you are working with,
who will coordinate a response.

Please note we revised the shipboard policy, accompanied by training materials and other materials for use
aboard ship. The information below is for your use as agents only.

Definitions:
Bribe: Anything given to someone to induce, reward or influence the improper performance of a duty.

Corruption: Includes Bribery, Facilitation Payments and any other form of improper business practice.

Facilitation Payment: A payment or offering of any kind of value to a Public Official designed to secure or speed
up a routine government action.

Highlights of main interest to our Port Agents:

 Stolt-Nielsen expressly prohibits Bribery and Corruption in all business dealing in every country around the
world. (Section 3.2)
 All Facilitation Payments are prohibited under this Policy. (Section 3.3.1)
 When demands for payment are accompanied by actual or implied threats to personal safety, then safety
should be the first priority. In these exceptional emergencies, the Extortion Payment should be made, and the
incident reported immediately to your Stolt Tankers contact. (Section 3.3.2)
 Gifts and hospitality are only permitted if they are infrequent, modest, appropriate and consistent with Stolt-
Nielsen’s Anti-Bribery values. It is prohibited to provide gifts, hospitality or travel to Public Officials unless
this has been approved in advance. (Section 3.7)
 It is prohibited to make a payment to a Third Party if you know or suspect that the person may use or offer all
or a portion of the payment directly or indirectly as a Bribe. Third parties who play a role in the Company’s
business must not engage in Bribery or Corruption on the Company’s behalf or in connection with its
business. It is the responsibility of each Stolt Employee to ensure that Third Parties engaged on behalf of the
Company are legitimate service providers. (Section 3.8)
 “Red flags” may include, amongst many other items, lack of transparency in expenses or accounting records.

Our Port Agents make payment to local entities on our behalf, including government entities and local providers
of goods and services. As the Port Agent acts as an intermediary, Stolt Tankers requires our Port Agents to always
provide supporting documentation with port disbursements, i.e. an invoice from the local entity/provider, as
proof that a legitimate service was provided.

We trust our requirement for full compliance with all laws and regulations is already second nature to you, but
this topic is so important that we felt a reminder was appropriate. Should you need clarification on any of the
above points, do not hesitate to contact us immediately.

Regards
Norman O’Shaughnessy

Stolt Tankers USA, Inc

As agents for Stolt Tankers B.V.
15 February 2019