Uni-Tankers Code of Conduct

CODE OF CONDUCT

Title Date 30-APR-2025

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.

3.1

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

3.2.

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

Business Ethics ............................................................................................................................. 4 4.1

Company values and ethics .............................................................................................. 4

4.2

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

4.3

Anti-Corruption and Ethical Business Practices ................................................................ 6

4.4

Confidentiality and Data Protection ................................................................................... 7

5.

Use of company resources ........................................................................................................... 7

6.

Reporting violations and whistleblower protection ........................................................................ 7

7.

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

8.

Signatures ..................................................................................................................................... 8

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Title Date 30-APR-2025

1.

CODE OF CONDUCT Review date -

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INTRODUCTION

We believe our success is built on integrity, compliance, and a shared commitment to the highest standards. Our Code of Conduct guides our operations and ensures that we uphold these values as a team. By following our Code of Conduct, we create a positive and lasting impact, not only within our organization but also in the communities we serve. This Code of Conduct outlines the principles and expectations that guide our daily activities and interactions.

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

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

2.

SCOPE

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

These standards apply to all employees, both off- and onshore.

We expect all employees 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.

3.1

ENVIRONMENTAL PROTECTION

At Uni-Tankers, we are dedicated to reducing our carbon footprint and minimizing emissions across all operations. We adhere to relevant local, national, and international environmental laws to ensure compliance and promote best practices.

3.1.1 Sustainable operations and resource management Sustainable operations are at the core of our strategy. We expect you to actively engage in decarbonization efforts by implementing measures to reduce greenhouse gas emissions, utilizing renewable energy sources, and continuously improving energy efficiency. Additionally, we encourage you to minimize waste, promote recycling, and ensure the responsible disposal of hazardous substances.

Our objective is to ensure transparency in reporting and all operational activities. We strive to cultivate a culture of environmental awareness among all employees. .

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3.2.

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HEALTH, SAFETY, AND HUMAN RIGHTS

At Uni-Tankers, we prioritize the health and safety of all employees, and we are committed to upholding fundamental human rights. By adhering to these principles, we create a safe, respectful, and inclusive work environment.

3.2.1. Safety Management We are dedicated to ensuring a safe working environment for all employees. This includes implementing and maintaining robust safety management systems that prioritize the welfare of our employees, providing appropriate safety training, ensuring the availability of necessary protective equipment, and having emergency response procedures in place.

Our goals include achieving 100% participation in safety training.

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 are committed to ensuring that these practices do not take place. All employees must be treated with respect and dignity.

We enforce a zero-tolerance regarding human rights violations. Our Human Rights policy is publicly available, and we hold ourselves to these standards.

Uni-Tankers is committed to upholding Human Rights in accordance with the principles of the UN Global Compact and the International Labor Organization (ILO).

3.2.3. Right to collective bargaining Uni-Tankers recognizes and respects the rights of its employees join trade unions and representation bodies. We acknowledge that all employees can freely engage in collective bargaining and union activities, including the right to negotiate working conditions, wages, and other employment terms collectively.

4.

BUSINESS ETHICS

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

4.1

COMPANY VALUES AND ETHICS

At Uni-Tankers, our company values and ethics are the foundation of our organizational culture and guide our daily actions and decisions. By embodying these values, we cultivate a positive and respectful work environment that promotes trust and collaboration.

We expect our employees to follow the guidelines of TØN’s Law:

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1. Business Acumen— profitability, persistency, simplicity. Good business acumen is the key to our success. We run our business in a reasonable, prudent, and profitable way, ensuring that our operations are sustainable and efficient.

2. Leadership— proactiveness, quality, responsibility. We show leadership in everything we do, striving to realize the true potential inherent in our companies and in each of us. We set high standards for ourselves and our businesses.

3. Decency— management & organization, communication, humanity. Our actions are characterized by decency, meaning we are respectful, fair, and open in all our dealings. This helps build strong relationships and trust with our stakeholders.

TØN's Law promotes transparency, builds trust with stakeholders, and holds us accountable, demonstrating our commitment to ethical behavior and responsible decision-making.

Following TØN's Law is essential. It minimizes risks and enhances credibility.

4.2

WORKPLACE CONDUCT

4.2.1 Anti-discrimination and equal opportunity We are committed to a discrimination-free workplace with equal opportunities. 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, along with equal access to training and development, must be fair and based on objective criteria.

We believe in fostering continuous staff development, ensuring all employees have equal access to professional growth through training, education, and skill enhancement opportunities. We support initiatives that promote both personal and professional development when relevant and mutually beneficial.

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

We expect you to prevent and address harassment and bullying effectively.

4.2.3 Equity, and inclusion We value equity and inclusion and encourage 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.

4.2.4 Targets To ensure we continuously improve and uphold our values, we have established the following targets: ▪

We aim to maintain a LEAP-score above 8 for onshore employees.

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We aim to maintain a Re:Fresh-score above 7.5 for offshore employees.

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We aim to promote the well-being of all employees and ensure a comfortable work environment.

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We foster open communication through regular meetings and development conversations.

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By 2032, we strive for equal gender distribution (40/60%) at first and second management levels in offices in Denmark, as required by the Danish Business Authority.

4.3

ANTI-CORRUPTION AND ETHICAL BUSINESS PRACTICES

4.3.1 Zero tolerance for bribery and corruption We are dedicated to maintaining ethical business conduct, which includes rejecting corruption, bribery, and money laundering, while ensuring fair practices.

We adhere to our procedures for reporting any corrupt activities. Recognizing the potential for unethical practices in our industry, we have joined the MACN (Maritime Anti-Corruption Network) network. This commitment involves upholding principles of fair competition, where all employees are expected to maintain these standards to effectively counter unethical practices.

4.3.2 Procedure for reporting corrupt practices Uni-Tankers have established and continues to refine policies and procedures to manage sanction risks effectively. Employees receive regular compliance training, and we utilize various sanction systems to ensure adherence to current regulations. This approach creates a sophisticated and robust framework that safeguards our company and business partners.

4.3.3 Conflicts of interest Employees are permitted to take up employment outside Uni-Tankers, provided it aligns with our company manual – meaning that it does not create conflicts of interest. Employees must seek permission before engaging in any outside employment to ensure there are no conflicts of interest.

We encourage our employees to be aware of personal relationships that may cause bias in third party dealings. If you are unsure whether bias is affecting your dealings, we encourage you to seek guidance.

4.3.4 Targets To ensure that we continuously improve and uphold our values, we have established the following targets: ▪

We aim for a 100% completion of awareness training for operations- and chartering employees towards sanctions, anti-competition-law, anti-bribery and corruption.

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We aim to conduct risk assessments for 100% of all docking sites by 2030.

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We aim to educate 100% of all employees on money laundering topics by 2030.

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We aim to educate 100% of all employees on anti-competition topics by 2030.

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We aim to train 100% of all employees in conflicts-of-interest topics by 2030.

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4.4

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CONFIDENTIALITY AND DATA PROTECTION

Uni-Tankers is dedicated to maintaining data protection, which includes ensuring confidentiality, integrity, and availability. To achieve this, employees are expected to follow our IT policy and report any security threats they encounter.

4.4.1 Information Security Information security encompasses a wide range of topics, and we encourage you to reach out with any questions about how to adhere to our policies for safeguarding information, whether working in the office or remotely. We follow information security standards, tailored to meet our specific business needs, as we believe that robust business practices and information security can coexist harmoniously.

4.4.2 Targets To ensure we continuously improve and uphold our values, we have established the following targets: ▪

Conduct an IT Security Risk assessment for 100% of all sites by 2030.

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Phishing-prone score below 10%.

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Maintain and improve a Microsoft security baseline score of 90%.

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100% of all employees complete ongoing information security awareness training with a 90% pass rate.

5.

USE OF COMPANY RESOURCES

At Uni-Tankers, we prioritize our employees' well-being and provide various resources to support them. The use of these resources is outlined in our company manual. We commend our employees for their commitment to sustainable and responsible practices when utilizing company resources.

6.

REPORTING VIOLATIONS AND WHISTLEBLOWER PROTECTION

We encourage all employees to report any irregularities or unethical behavior without fear of retaliation. We have clear and accessible procedures for reporting misconduct and ensure that those who report in good faith are protected against any form of retaliation. Confidentiality is upheld, and appropriate measures are taken to safeguard whistleblowers from any adverse consequences.

Employees have access to clear procedures for reporting misconduct or unethical behavior. We emphasize that those who report in good faith are protected, ensuring confidentiality and safeguarding against any adverse consequences.

All reports of suspected violations are thoroughly investigated. These investigations are conducted independently, fairly, and without bias, respecting the rights of all parties involved. Findings are meticulously documented and, if necessary, reported to the relevant authorities.

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Title Date 30-APR-2025

CODE OF CONDUCT Review date -

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We foster an environment of open dialogue about responsible conduct and provide our employees with secure channels to raise legal or ethical concerns. We encourage everyone to report any concerns or potential violations of this Code of Conduct through our Whistleblower Policy – UniTankers. All reports are treated confidentially, and investigations are conducted fairly and independently, in accordance with relevant laws and principles, including the right to a fair hearing.

7.

CONCLUSION AND ACKNOWLEDGEMENT

At Uni-Tankers, we are committed to maintaining the highest standards of ethical conduct and integrity.

This Code of Conduct serves as a guide for all employees to understand and uphold our values in our daily work. We acknowledge the importance of each employee's role in fostering a culture of transparency and accountability.

All employees must read, understand, and follow this Code of Conduct. By doing so, you contribute to the success and reputation of Uni-Tankers. Thank you for your dedication and cooperation.

8.

SIGNATURES

Date: 30 April 2025 Signature

Date: 30 April 2025 Signature

______________________

_____________________

Per Ekmann, CEO

Thomas Thomsen, CFO

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