COMPANY POLICIES

MISSION STATEMENT

Marflet Marine strives to maintain and further develop a fleet of ships fulfilling market standards as
stipulated by the world’s leading Oil Majors and meeting national and international rules and
regulations.

The Safety of crew and vessels as well as the protection of the environment has top priority within the
Marflet Marine fleet. We are committed to safe and secure transportation of liquid cargoes at sea and
our goal is to reach zero incidents, zero spills or releases to the environment, reduction in permitted
emissions and zero detentions by continuously improving our procedures, practices and controls.

We carefully select and train our staff in order to constantly meet the requirements of our customers as
well as those of national and foreign maritime authorities. The majority of our staff has worked in the
Company for many years, thereby ensuring continuity and compliance with the high standards
determined by Marflet Marine.

14th June 2022

Juan J. Ferrer

CEO

SAFETY COMPANY POLICY

The safety objectives of the Company Policy are to ensure safety at sea, prevention of human injury or
loss of life, and avoidance of damage to the environment and property.

Safety management objectives of the Company are, inter alia:

Provide for safe practices in ship operation and safe working environment.

Establish safeguards against all identified risks.

Continuously improve safety management skills of personnel ashore and aboard ships, including
preparing for emergencies related both to safety and environmental protection.

Continuous improvement in the reduction of pollution; and

Continuous striving to reach Zero goals:

Zero Incidents – Zero Pollution – Zero Detentions

For this purpose the Company has developed and implement a Safety Management System (SMS) which
is maintained at shore office and in all Company’s operated vessels.

The Company’s Safety Management System ensures:

Compliance with ISM code and mandatory rules and regulations.

That applicable codes, guidelines and standards recommended by the Organization, Administrations,
Classification Societies and Maritime Industry Organizations, are taken into account.

Quick application of possible improvements in the safety and environmental management.

14th June 2022

Juan J. Ferrer

CEO

THE HEALTH, SAFETY AND ENVIRONMENTAL POLICY

The day-to-day operational conduct of Marflet Marine S.A. is governed by the Company Health, Safety
and Environmental Policy. This Policy Endeavour’s to ensure that all operations are carried out in a
manner which:

Ensures the safety and health of employees and other persons affected by Company activities.

Gives due regard to the protection and conservation of the environment

Complies with, or exceeds, all relevant international, national and local laws and regulations which
relate to health, safety and protection of the environment.

Ensures that commercial factors shall not take precedence over matters relating to health, safety and
environmental protection.

In order to implement this policy, Marflet Marine S.A. endeavours to ensure that vessels under its
management are manned by qualified, medically fit and suitably trained seafarers and insists on a
commitment from all employees to maintain the highest standards of health, safety and environmental
protection.

Seafarers employed on Marflet Marine S.A. managed vessels are invited to identify potentially unsafe or
unsound procedures, equipment or practices and to bring them to the attention of a responsible person
and/ or Safety Committee on board the vessel.

Safety and environmental protection is the responsibility of all personnel onboard and any person who
feels after bringing the matter to the attention of a responsible person onboard and/ or the Safety
Committee, that the safety or environmental protection are still compromised, must inform to Marflet
Marine S.A. Designated Person Ashore (DPA).

It is the responsibility of the Master to ensure that all personnel on his vessel adhere to this policy.

This policy shall be reviewed at regular intervals and amended and updated when necessary to ensure
that it remains effective.

14th June 2022

Juan J. Ferrer

CEO

ENVIRONMENTAL POLICY

As an essential part of its Environmental Management System, whose scope covers the “PROVISION OF
MARITIME TRANSPORTATION SERVICES WITH SPECIALIZED OIL AND CHEMICAL TANKERS IN
WORLDWIDE TRADE”, Marflet Marine S.A. has set up this Environmental Policy, by which it commits to:

Manage the significant environmental aspects in a responsible manner and in any case in accordance
with ISO 14001 standard.

Learn, communicate, and comply with all applicable legal requirements concerning environmental
protection, promulgated by the various Authorities with responsibilities in this area, and with any other
commitments voluntarily subscribed to, and that might influence and constrain the development of our
activities.

Establish a corporate culture that discourages criminal or other aberrant conduct by establishing a
system to encourage and oversee compliance with regulations and standards, and to discover and
appropriately deal with non-compliances.

Voluntary disclose any wrongdoing on a timely basis and cooperate with Government’s investigations.

Carry out actions for continuous improvement of significant environmental aspects, where this is
techno-economically viable.

Strive to reduce, prevent or control the various existing types of pollution and to prevent future ones,
where techno-economically viable.
Strive to deliver its contribution by reducing its Greenhouse Gas (GHG) emissions, particularly CO2
emissions, supporting IMO to develop real and sustainable GHG emission reduction regulations from
ships that will not hinder international commerce energy efficiency.

Effectively manage the wastes generated in our activities, when they are harmful to the environment.

Consider environmental factors in relevant purchasing decisions and giving preference to those products
and services that have a lesser or reduced effect on human health and the environment when compared
with competing products or services that serve the same purpose.

Establish environmental objectives and targets consistent with this Policy and review them periodically.

Communicate this Policy to our employees, subcontractors and suppliers and maintain it publicly
available.

14th June 2022

Juan J. Ferrer

CEO

COMPANY SECURITY POLICY

It is the policy of the Company to provide a secure working environment by establishing and maintaining
the required security measures to prevent unlawful acts against the ship, which endanger the safety and
security of persons and property onboard the Company ships.

Company objectives are to:

Provide security procedures and practices for ship operations to protect the security of the ships, ports
and the wider community.

Establish safeguards to reduce the risk to visitors, crew and shore personnel onboard the Company
ships.

Improve the security skills and awareness of the Company personnel ashore and onboard, and

Prepare contingency measures for emergencies relating to possible security incidents.

Preserve the cyber security with the required software and hardware equipment.

The Company intends to achieve these objectives by:

A ship Security Assessment and Security Plan specific to each ship.

Comprehensive training for Company personnel.

Actively promoting security awareness amongst Company personnel.

Regular document reviews and internal audits, and

Providing the necessary support to the Company Security Officer (CSO) and Ship Security Officer (SSO) to
fulfill their duties in accordance with chapter XI-2 and part A and B of the ISPS code

14th June 2022

Juan J. Ferrer

CEO

DRUG AND ALCOHOL POLICY

It is the policy of the Company that any Master, Officer, Petty Officer, Rating or contractor when on
board our vessels is prohibited from performing any duties whatsoever whilst under or seemingly under
the influence of alcohol or drugs or an illegal substance or possess any such substances.

14th June 2022

Juan J. Ferrer

CEO

QUALITY MANAGEMENT SYSTEM’S POLICY

Shipmanagement services of Marflet Marine S.A. are used by world-wide Customers that demand the
highest standards of performance and reliability. The quality of our services plays a key role in achieving
Customers’ satisfaction and in turn business success.

It is our Policy to:

Provide services that meet current and predictable future requirements of our customers in the most
efficient and competitive way, as well as applicable laws and regulations, in turn satisfying the interests
and expectations of other stakeholders (shareholders, employees, suppliers and Society in general).

Ensure safety at sea, prevention of human injury or loss of life, and avoidance of damage to the
environment, striving to reach zero incidents and zero spills.

Maintain an effective coordination with our suppliers, in order to ensure availability for our customers of
the most appropriate and efficient vessels, equipped with the best and more up-to-date technology
advances.
Act in an attitude of leadership, to properly guide the efforts of all staff, for which we ensure a proper
selection, training and promotion, recognizing their essential role and creating an internal environment
in which everyone can participate and get involved in the achievement of the Organization’s objectives.
In particular, vessels will be operated with senior officers with appropriate experience and training on
their specific type and trade.

Identify the continuous improvement in performance as a permanent Objective of the Organization,

facilitating and encouraging the active participation of all personnel in this task.

Implement and communicate this Policy to all our employees, and review it regularly for updates.

Our overall Quality Objective is to continually improve customer’s satisfaction by operating an efficient
and effective Quality Management System, striving to anticipate and exceed customer needs and
expectations at every opportunity. This is achieved through understanding current and future customer
needs and expectations and through structured planning for the future organization and managing
change.

14th June 2022

Juan J. Ferrer

CEO

ENERGY EFFICIENCY MANAGEMENT POLICY

The Company, having established and implementing an Environmental Management System certified in
accordance with ISO 14001, believes that although shipping is by far the most fuel-efficient mode of
transport, nevertheless additional action has to be taken to further improve the energy efficiency of ship
related operations. The increased energy efficiency eventually results in increased environmental
protection by reducing air emissions.

Energy efficiency is controlled primarily through well-planned and properly managed ship operations
and needs the personal commitment of everyone involved in the above tasks. To be successful, energy
efficiency and conservation must become part of the day to day operation and living onboard.

In our efforts to enhance the energy efficiency on the shipboard operations, the Company is committed
to:

Establishing and maintaining a Ship Energy Efficiency Management Plan (SEEMP) which is regularly
reviewed by all concerned departments and approved by the management of the Company. This Plan,
which applies to all fleet vessels, provides standard procedures and practices on best energy
management under the various operational modes of the vessel

Implementing an Environmental Management System supported with several environmental programs

with the objective of continually increasing energy efficiency and minimizing energy waste. A set of
time-specific, measurable – whenever practicable – and achievable targets shall be established and
maintained, which shall relate to a combination of design optimization, in-service performance
monitoring and best-practice operational management processes

Promoting energy efficiency awareness through training to the shore and sea-going personnel and
implementing energy related Campaigns and other personnel incentive/motivating programs

Monitoring and complying with all applicable legal requirements related to ship energy efficiency
management

This Policy shall be periodically reviewed with the aim of being kept always updated so as to function as
the “leading light” towards a continual energy efficiency improved performance.

14th June 2022

Juan J. Ferrer

CEO

CODE OF ETHICS AND CODE OF CONDUCT

The Company’s shore staff and seagoing personnel shall not be involved in any kind of harassment,
abuse, discrimination or child pornography.

The Company’s personnel shall not conceal any identified unsafe act or event which affects or could
affect human health and safety, the environment and the property.

The Company’s personnel shall carry out their duties in a professional and impartial manner. All
Company’s employees shall act in honesty and good faith.

All information regarding Company operations, projects, reports or any work carried out shall be treated
as business confidential to the extent that such information does not conflict with Company’s policy for
HSSQEEn excellence and is not already disseminated or made generally available to third parties.

Any kind of offer, gift or bribe in any form direct or indirect, including kickbacks is strongly prohibited in
all Company’s operations. Furthermore, the Company prohibits the use of other routes or channels for
provision of improper benefits to, or receipt of improper benefits from agents, contractors, suppliers or
employees of any such party or government officials.

Procurements are conducted in a fair and transparent manner.

14th June 2022

Juan J. Ferrer

CEO
SOCIAL MEDIA POLICY

This policy outlines the necessary principles that users of social media shall observe, the conditions in
which Internet activity will be monitored and actions to be taken upon violation of the established
policy. The Company, expects all individuals to comply with this policy at all times and to protect the
Company’s reputation.

This policy deals with the use and misuse of social media platforms and other websites including but not
limited to:

Social networking websites such as Facebook, CrewToo, MySpace, LinkedIn, Yahoo! Groups, QQ.com,
VK.com.

Micromedia / Microblogging websites such as Twitter.

Multimedia websites such as YouTube and Instagram.

Wikis such as Wikipedia.

Blogs and News sites where content and comments can be posted.

Any other website where user-generated content can be posted for wider sharing.

This policy applies to all individuals working at all levels in the Company, either in the office or on board
the vessels and covers the use of social media (as outlined above) during work and non-work hours, on
personal and Company supplied equipment such as laptop computers and cellular / smart phones.

The General Manager, Lines Managers and ships’ Masters are responsible for ensuring that the
standards set forth by this policy are communicated to their teams and that their own conduct sets a
good example in this respect.

The Company recognizes the value of social media and expects all staff to use these tools responsibly.

The following basic principles should be observed:

Be responsible. As an employee, any user-generated content could have an impact on the Company’s
reputation, so give careful thought before sharing photographs or video of the Company assets,
particularly our ships, facilities or people in uniform. For example, images taken during an incident could
potentially be detrimental to an investigation.

Be accurate and honest. In any circumstance in which you are in doubt, or you are uncertain about how
to respond to a post, contact the Company for guidance.

Do not make posts or comments that may be considered defamatory, obscene, libellous, threatening,
harassing or embarrassing to others.
Before you post photographs of other people, get their permission first.

Never use someone else’s copyrights, copyrighted material, trademarks, service marks or other
intellectual property.

If you see comments relating to the Company that you think should be addressed, contact the Company
for guidance.

Do not use the Company’s logo (in any form) on any personal social media platform. Use of any
Company logo must be approved by the Company.

Respect others in any online social interaction. Do not use social media or any similar form of
communication to attack or insult the Company, fellow employees, customers, vendors, contractors,
suppliers, competitors or others.

Do not disclose any confidential, proprietary or sensitive information about the Company as well as
names of our employees, customers, vendors, contractors, suppliers, competitors or others. Employees
are reminded of Company’s policy on public statements / media response.

Do not comment on Company related legal matters, financial performance, competitors, strategy or
rumours, unless you are specifically authorized to do so by the Company.

If any member of the media (social or traditional) contacts you about your user-generated content (i.e.,
blog post, comment, video), a colleague’s or another party’s, do not engage in a dialogue, but refer
them to contact the Company.

Please be aware that violation of this policy may be grounds for disciplinary action up to and including
termination of employment.

14th June 2022

Juan J. Ferrer

CEO

HARASSMENT AND BULLYING POLICY

Marflet Marine recognises that all employees have a right to work in an environment in which the
dignity of individuals is respected and which is free from harassment and bullying. It is committed to
eliminating intimidation in any form.

The Policy applies to harassment and bullying on the grounds of disability, gender, marital status, sexual
orientation, age, creed, colour, race, nationality or ethnic origin.

Harassment and bullying breaches Marflet Marine Policy as outlined, and it is classified as a serious
offence which may result in disciplinary action including summary dismissal under the Disciplinary
Procedure.
The Policy applies to all staff employed by Marflet Marine

14th June 2022

Juan J. Ferrer

CEO

SOCIAL RESPONSABILITY POLICY

Company operates in a socially responsible manner, ensuring the safety of people and the environment,
through transparent and ethical behavior, respecting the following principles:

Accountability for the organization’s impacts on society and the environment;

Transparency in the organization’s decisions and activities that have impact on society and the
environment;

Ethical behavior at all times;

Respect, consider and respond to the interests of the Company’s stakeholders and employees;

Accept that respect for the rule of law is mandatory;

Respect international norms of behavior, while adhering to the principle of respect for the rule of law;
and

Respect human rights and recognize both their importance and their universality.

The Company addresses the following core subjects in order to identify the issues and priorities that are
relevant for the organization: Organizational governance; Human rights; Labor practices; Environment.

Our commitment to this objective is underscored by the daily actions of our employees and their
dedication to the numerous programs and practices we have implemented.

We aim to integrate sustainable thinking and corporate social responsibility into all our business
processes and business relationships. Employee skills and competencies are developed by continually
raising awareness and impartment of training.
We recognize that our operations have a global influence. With this in mind, we work diligently with our
employees, local communities and internationally recognized bodies to ensure that social factors are
integral to our business principles.

We promote continual improvement as a principal driver by knowledge-sharing practices and the timely
review of our management systems while always meeting or exceeding all applicable legislative and
regulatory requirements.

14th June 2022

Juan J. Ferrer

CEO

WHISTLEBLOWING POLICY

Company is committed to conducting all aspects of her business with honesty and integrity, and to
providing a working environment where high standards of ethical, moral and legal business conduct are
encouraged and safeguarded.

The Company is confident in the comprehensiveness and effectiveness of its Management System and
its role in ensuring the safety of people and the environment, as well as in the effectiveness of its
existing reporting channels.

Furthermore, the Company is committed to a workplace characterized by open communication

regarding its business practices. As such, this Whistleblowing Policy has been developed to provide a
means for employees and seafarers to raise concerns that cannot be, or have not been, adequately
addressed via usual reporting channels without fear of retaliation or discrimination over such reports
made in good faith.

The Whistleblowing Policy addresses concerns related to issues of public interest, including, but not
limited to, the following:

A criminal offence;

Non-compliance with legislation and/or Company procedures, particularly in relation to health and
safety at work or environmental protection;
Dishonesty, either verbal or written (including intentionally maintaining official log books or records
inaccurately);

Malpractice or unethical conduct;

Financial or non-financial misadministration or malpractice or impropriety or fraud;

A safety and/or security risk or hazardous condition that may impact the life or health of individuals on
board the vessel;

Miscarriages of justice; and

The deliberate concealment of any of the above.

If an employee has a legitimate concern in (and holds reasonable belief that the information he has
relates to) one of the above areas and wishes to raise the concern in good faith, it should be raised with
the Master, DPA or other Company’s representative who may be able to agree a way of resolving the
concern quickly and effectively.

Although the Company’s Top Management maintains an open-door policy endeavoring to address
individuals’ concerns internally, a concern can also be raised through the following channels:

E-mail: ceo@marfletmarine.com

Tel.: +34 91 532 83 01

Reports can be made without fear of retaliation and be even anonymous. Upon receipt of a report, same
will be assessed by the Company’s Top Management and an investigation may commence, if deemed
necessary. Any victimization of a member of staff who “whistle-blows”, or any attempt to deter him
from reporting, will be regarded as a serious disciplinary offense and will result in action under the
Disciplinary Procedures.

14th June 2022

Juan J. Ferrer

CEO

CYBER SECURITY POLICY

The purpose and objective of this Policy is to protect Marflet Marine information assets (note 1) from all
threats, whether internal or external, deliberate or accidental, to ensure operations continuity, minimize
damage and maximize return on investments and relevant industry opportunities.

To fulfil these objectives, the management is committed to the following approach:

It is the Policy of Marflet Marine to ensure that:

Information and Systems identified as vulnerable to Cyber-attacks will be protected from a loss of
confidentiality (note 2), integrity (note 3) and availability (note 4).

Regulatory and legislative requirements are to be met.

Cyber Security Contingency Plans have been produced for support.

Cyber Security training will be available to all staff.

All breaches of information security, actual or suspected, will be reported and investigated.

Guidance and procedures have been produced to support this policy. These include incident handling,
information backup, system access, virus controls, passwords and encryption.

The role and responsibility of the Information Technology Manager is to manage information security
and to provide advice and guidance on implementation of the Cyber Security Policy.

All managers are directly responsible for implementing this Policy within their departments.

It is the responsibility of each employee/crew member to adhere to the Cyber Security Policy.

NOTES

Information takes many forms and includes data printed or written on paper, stored electronically,
transmitted by post or using electronic means, stored on tape or video.

Confidentiality: ensuring that information is accessible only to authorized individuals.

Integrity: safeguarding the accuracy and completeness of information and processing methods.

Availability: ensuring that authorized users have access to relevant information when required.