Supplier Code of Conduct

SUPPLIER

CODE OF CONDUCT

Title Date 30-APR-2025

SUPPLIER CODE OF CONDUCT Review date -

Version 1.0

Language English

TABLE OF CONTENTS 1.

Introduction ................................................................................................................................... 3

2.

Scope ............................................................................................................................................ 3

3.

Corporate Social Responsibility (CSR) ......................................................................................... 3

4.

5.

3.1

Environmental Protection .................................................................................................. 3

3.2.

Health, safety, and human rights....................................................................................... 4

Business Ethics ............................................................................................................................. 5 4.1

Workplace conduct ............................................................................................................ 5

4.2

Anti-Corruption and Ethical Business Practices ................................................................ 5

4.3

Confidentiality and Data Protection ................................................................................... 6

Compliance and monitoring .......................................................................................................... 7 5.1

Sanctions compliance ....................................................................................................... 7

5.2

Financial integrity and reporting ........................................................................................ 7

5.3

Whistleblower protection ................................................................................................... 8

6.

Conclusion and acknowledgement ............................................................................................... 8

7.

Responsibility ................................................................................................................................ 9

8.

Revision history ............................................................................................................................. 9

9.

Signatures ..................................................................................................................................... 9

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Title Date 30-APR-2025

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INTRODUCTION

Welcome to Uni-Tankers. We believe that our valued partnership is “A Matter of Chemistry” and grounded in a shared commitment to excellence and compliance with this Supplier Code of Conduct.

This Code of Conduct reflects both Uni-Tankers’ and our partners’ commitment to upholding the highest standards in all our business activities.

By adhering to this Code of Conduct, we can create a lasting impact and not only meet but exceed the complex requirements we face together.

Uni-Tankers’ Supplier Code of Conduct outlines the principles and expectations that guide our business activities. We believe that by working together and adhering to these standards, we can create a positive and lasting impact and the communities we serve and uphold a common level of responsibility.

Your commitment to these principles is vital for maintaining the integrity of our supply chain and achieving our shared goals of compliance, sustainability, and ethical business practices. Together, we can navigate the complexities of our industry and work towards a better and more sustainable future.

Thank you for your cooperation and commitment to these values. Let's make a difference, together!

2.

SCOPE

At Uni-Tankers, we value our suppliers and partners. This Code of Conduct establishes the minimum standards of conduct expected from our suppliers. By adhering to this Code of Conduct, you help maintain integrity and foster sustainable collaboration.

These standards apply to all suppliers, contractors, port agents, and other third parties who provide goods or services to Uni-Tankers.

We expect all suppliers to comply with applicable local and international laws and regulations. In cases of discrepancies between local laws and our guidelines, the higher standard should prevail.

Please keep us informed of any conflicts, so we can work together to find a solution.

3.

CORPORATE SOCIAL RESPONSIBILITY (CSR)

At Uni-Tankers, we are committed to ethical, sustainable, and socially responsible business practices.

We expect our suppliers to uphold these values in areas such as environmental protection, health, safety, and human rights.

3.1

ENVIRONMENTAL PROTECTION

3.1.1 Commitment to decarbonization and emission reduction At Uni-Tankers, we are dedicated to reducing our carbon footprint and minimizing emissions across all operations. We expect our suppliers to actively engage in decarbonization efforts by implementing measures to reduce greenhouse gas emissions, utilizing renewable energy sources, and continuously

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improving energy efficiency. While it is not mandatory, we strongly encourage and appreciate your feedback on the measures you have implemented and their impact.

3.1.2 Sustainable operations and resource management Sustainable operations are at the core of our strategy. We expect you to adopt resource management practices that prioritize efficiency in energy, water, and raw materials. This includes minimizing waste, promoting recycling, and ensuring responsible disposal of hazardous substances. We encourage our suppliers to innovate and implement sustainability best practices.

3.1.3 Compliance with environmental regulations Compliance with environmental regulations is non-negotiable. Suppliers must adhere to all relevant local, national, and international environmental laws and standards, including obtaining necessary permits, conducting regular environmental impact assessments, and implementing corrective actions.

3.2.

HEALTH, SAFETY, AND HUMAN RIGHTS

3.2.1. Safety Management At Uni-Tankers, we prioritize the health and safety of all employees and expect suppliers to implement robust safety management systems that ensure a safe working environment and prioritize the welfare of its employees. This includes providing appropriate safety training, ensuring the availability of necessary protective equipment, and emergency response procedures in place.

Suppliers are expected to comply with relevant health and safety regulations and strive to minimize workplace hazards. By maintaining high safety standards, we can protect the workforce and promote a culture of safety and well-being.

3.2.2. Human Rights Uni-Tankers views any form of slavery, servitude, human trafficking, forced labour, or child labour as serious violations of fundamental human rights. Through our own recruitment process and within our business, we commit to ensure that these practices do not take place. All employees must be treated with respect and dignity.

Our suppliers and business partners must respect human rights and enforce a zero-tolerance regarding human rights violations. Suppliers and business partners are strictly prohibited from using child labour.

Our Human Rights policy is publicly available, and we hold our business partners to the same high standards as outlined in this Supplier Code of Conduct.

Uni-Tankers is committed to upholding Human Rights in accordance with the principles of the UN Global Compact and the International Labor Organization (ILO). We expect our business partners to do the same.

3.2.3. Right to collective bargaining Uni-Tankers recognizes and respects the rights of its employees join trade unions and representation bodies, and we urge our suppliers to do the same, ensuring that employees can freely engage in collective bargaining and union activities. This includes the right to negotiate working conditions, wages, and other employment terms collectively.

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If local laws restrict these rights, suppliers should seek lawful alternatives for employee representation. We encourage our suppliers to foster dialogue based on collective bargaining whenever possible.

4.

BUSINESS ETHICS

At Uni-Tankers, we understand the importance of maintaining high ethical standards. To sustain our compliance, we expect our suppliers to commit to continuous improvement in all operations as part of our cooperation.

At Uni-Tankers, we rely on partnerships across the world. For our common business to thrive, it is essential that we take responsibility for our decisions.

4.1

WORKPLACE CONDUCT

4.1.1 Anti-discrimination and equal opportunity We are committed to a discrimination-free workplace with equal opportunities and expect our suppliers to share this commitment. Employment decisions should be based on qualifications, experience, and performance without regard to gender, race, religion, age, disability, sexual orientation, or any other protected characteristic.

Compensation and benefits must be fair and based on objective criteria. All employees should have equal access to training and development opportunities, ensuring that all employees have the opportunity to thrive and contribute fully to their collective success.

4.1.2 Harassment and bullying prevention We strive to maintain a work environment free from harassment and bullying and expect suppliers to uphold the same standards. All employees must be treated with respect and dignity, and any form of harassment – whether verbal, physical, or psychological – must be avoided.

Suppliers are expected to prevent and address harassment and bullying effectively.

4.1.3 Equity and inclusion We value equity and inclusion and encourage our suppliers to promote these principles. Suppliers should foster an inclusive environment where all employees feel valued and respected. Efforts should be made to sustain diverse representation throughout the organization and to provide equal opportunities for advancement and development.

4.2

ANTI-CORRUPTION AND ETHICAL BUSINESS PRACTICES

4.2.1 Zero tolerance for bribery and corruption Uni-Tankers maintains a zero-tolerance policy towards bribery and corruption. We expect our suppliers to uphold this commitment by being transparent and honest in all business dealings.

Uni-Tankers disassociates from any form of bribery or corruption. Gift-giving and hospitality should be fully transparent and should not be allowed to create suspicions of conflicts of interest or improprieties.

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4.2.2 Procedure for reporting corrupt practices All suppliers are expected to have concrete and robust procedures in place for handling and reporting corruption or bribery cases. These procedures must ensure that suspected or corrupt behavior is investigated, addressed, and handled decisively.

4.2.3 Anti-money laundering Combating money laundering is crucial for Uni-Tankers. As such, we require our suppliers to engage in strict anti-money laundering practices. This includes documenting all suspected cases of money laundering, conducting thorough due diligence on business partners and transactions, and promptly reporting any suspicious activities to the relevant authorities.

4.2.4 Fair competition and anti-trust laws Suppliers must comply with applicable antitrust laws and conduct fair competition, avoiding practices that restrict competition, such as price-fixing or bid-rigging.

4.2.5 Personal Relationships and Nepotism Suppliers must base their decisions on objective criteria and not be influenced by personal relationships or familial connections. Nepotism must be avoided to ensure fairness and integrity.

4.3

CONFIDENTIALITY AND DATA PROTECTION

4.3.1 Handling company information Uni-Tankers prioritizes confidentiality, privacy, and information protection. We encourage our suppliers to uphold all data protection standards when handling company and business-relevant information. This includes ensuring that proprietary information, business plans, financial data, and other sensitive materials are only accessed by authorized personnel and protected against unauthorized disclosure. When relevant, data processing agreements must also be established.

4.3.2 Protecting customer and employee data As part of our critical infrastructure, Uni-Tankers must ensure that our suppliers comply with stringent requirements to secure their roles within our supply chain.

Suppliers are expected to implement robust technical, organizational, and physical measures for data protection. This includes ensuring and documenting secure processing of personal data, promptly reporting any breaches, and addressing vulnerabilities.

4.3.3 Cybersecurity and use of technology Suppliers must maintain strong cybersecurity practices and implement appropriate security measures.

Suppliers must comply with policies for responsible technology use, avoid illegal and unauthorized activities, and ensure a secure environment for all stakeholders.

By maintaining high standards of confidentiality and data protection, we can safeguard the integrity and security of our operations.

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5.

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COMPLIANCE AND MONITORING

At Uni-Tankers, we are committed to upholding high standards of compliance and monitoring. This section outlines our expectations for suppliers in areas such as sanctions compliance, financial integrity, and whistleblower protection.

By adhering to these compliance measures, we can ensure robust oversight and accountability in our business relationships.

5.1

SANCTIONS COMPLIANCE

5.1.1 Applicable Sanction Regimes At Uni-Tankers, we are dedicated to ensuring that our suppliers and their business partners comply with all applicable sanction regimes.

We expect our suppliers to stay informed and comply with all sanctions imposed by the United Nations, the European Union, the United States, and other relevant jurisdictions, including but not limited to restrictions or sanctions on conducting business with sanctioned individuals, entities, and countries and not supporting or facilitating any prohibited or sanctioned activities.

Suppliers must implement internal controls and due-diligence processes to identify and mitigate risks.

Suppliers are expected to report any potential or actual violations of sanction schemes or prohibited activities immediately. Suppliers must cooperate fully with any investigations related to sanctions compliance.

We expect our suppliers to commit to these standards and ensure that their business partners and subcontractors also comply with these requirements.

5.2

FINANCIAL INTEGRITY AND REPORTING

5.2.1 Transparency & Accurate Record Keeping Uni-Tankers is dedicated to upholding high standards of financial integrity and transparency, and we expect our suppliers to do the same. Financial records must be complete, accurate, and reflect all transactions truthfully.

All financial activities should be documented according to applicable accounting standards and regulations to ensure transparency, integrity, and accountability.

5.2.2 Fraud Prevention Uni-Takers expects suppliers to have procedures in place for reporting financial irregularities and ensuring employees can report concerns without fear of retaliation. By fostering integrity and vigilance, suppliers help prevent financial misconduct and protect stakeholders' interests.

Uni-Tankers expects suppliers and their business partners to commit to these standards, contributing to a transparent and trustworthy business environment.

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5.3

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WHISTLEBLOWER PROTECTION

We encourage our suppliers to implement their own whistleblowing procedures. Suppliers should ensure that employees can report irregularities or unethical behavior without the fear of retaliation.

5.3.1 Procedures for Reporting Misconduct and Protection against Retaliation Suppliers should provide clear and easily accessible procedures for employees to report any misconduct or unethical behavior. Additionally, suppliers should emphasize that employees who report misconduct in good faith are protected against any form of retaliation, including ensuring whistleblower confidentiality and taking appropriate measures to protect them from adverse consequences.

5.3.2 Investigation Process Suppliers must ensure that all reports of suspected violations are investigated. Investigations should be independent, fair, and unbiased, respecting the rights of all parties involved. The findings should be documented, and if necessary, reported to the relevant authorities.

We promote open dialogue about responsible conduct and encourage our suppliers to provide their employees with safe channels to raise legal or ethical concerns without the fear of retaliation. Any individual is encouraged to report concerns, as well as potential violations or breaches of this Supplier Code of Conduct, through our Whistleblower Policy – Uni-Tankers.

We assure that no retaliation will be taken against any supplier or their employees for raising concerns, questions, or complaints in good faith. All reports will be handled confidentially, and investigations will be conducted fairly, independently, and in accordance with relevant laws and principles, including the right to a fair hearing.

6.

CONCLUSION AND ACKNOWLEDGEMENT

We value our partnerships with our suppliers and their business partners. We aim to cultivate a collaborative relationship where trust and compliance are paramount.

As part of our commitment to the Uni-Tankers Code of Conduct, we conduct audits designed to support continuous improvement and mutual success.

6.1 Audit Process We strive to create a comprehensive and transparent overview regarding our audit process. We will notify our suppliers in advance regarding the scope of the audit When conducting the audit, we will: ▪

Send a notification: We will inform you in advance, ensuring time for preparation.

▪

Documentation Review: We may request relevant documents and records that document your compliance. The level of documentation may vary.

▪

On-Site Audit if needed: Based upon your documentation, we may determine the need to conduct further audits, which might include physical onsite visits.

▪

Audit Report: After the audit, we will provide you with a report outlining our findings.

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Title Date 30-APR-2025

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Suppliers Not Subject to Regular Audits: For suppliers engaged on a one-time or infrequent basis, regular audits may not be conducted. However, compliance with our Supplier Code of Conduct is still expected, and we reserve the right to audit if necessary.

We believe that by working together we can uphold the highest standards and achieve our shared goals. We encourage our suppliers to actively engage in continuous improvement to consistently meet and exceed compliance standards.

7.

RESPONSIBILITY

It is the responsibility of the management in the appropriate departments of Uni-Tankers to ensure that this Code of Conduct is implemented and communicated to all relevant stakeholders. UniTankers’ GDPR specialist must continuously update this Code of Conduct to ensure its continued relevance and effectiveness, and management must review it regularly.

8.

REVISION HISTORY

DATE OF CHANGE

9.

RESPONSIBLE

SUMMARY OF CHANGE

SIGNATURES

Date: 30 April 2025 Signature

Date: 30 April 2025 Signature

______________________

_____________________

Per Ekmann, CEO

Thomas Thomsen, CFO

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