Health, Safety and Environment Protection

The Company is dedicated to fulfilling all due management responsibilities and obligations in the course of developing ship management and shipping businesses, and thus formulates the following target, policy and commitment in respect of occupational health, safety and environmental conservation.

Target: zero injury, zero accident, zero pollution, high energy efficiency and low emission.

Policy: safety is the top priority and requires an emphasis on preventive measures and a holistic management approach; business operations are conducted based on people-oriented philosophy, energy conservation and emission reduction, as well as high efficiency from modest resource consumption; life and health, ship safety and marine environment protection must always be ensured.

Anti-Corruption and Anti-Commercial Bribery

Any employee of COSCO SHIPPING Energy shall not directly or indirectly ask, give, request or accept bribery, facilitating spending, kickback or any other improper payment in any way, irrespective of its being paid or received directly or through the third party (e.g. agent, representative, contractor, partner or retailer).

The Company must refrain from any special connected transaction, which is economic transactions with any special affiliated enterprise (business entities that a key person or a person related to such person of China COSCO SHIPPING Corporation Limited established, controlled or invested in).

Business Gifts

The Company prohibits employees from requesting gifts or entertainment. As an act of good faith for building business relationships, receipt or provision of gifts shall not influence any business decision-making process or cause impression of such influence. When accepting gifts, employees must be aware of potential conflict of interest.

All employees are not allowed to accept gifts exceeding the equivalent value of RMB 100 (individually or in aggregate, including business gifts with company logos and holiday gifts), business meals exceeding the value of RMB 100 per person, or occasional business events of more than RMB 200 per person in value (for events that last less than one day and occur no more than three times a year for a single business partner), unless they have obtained prior approval from their immediate supervisors regarding gifts or events exceeding the above value or frequency limits.

Conflicts of Interest

Any employee of COSCO SHIPPING Energy shall avoid conflicts of interest in privacy and business. Employees must report potential conflict of interest to the Company. The Company relies on its employees in exercising good judgment when performing their duties and complying with the best interests and reputation of the Company.

The Company respects the privacy of employees in private matters and activities. However, employees shall avoid activities that actually impair their duty of loyalty to the Company, while reporting, recording and resolving potential conflicts of interest. Any individual interest that might affect the employeesfairness in their job responsibilities must be reported to their supervisors promptly.

Prohibition of Insider Trading

All insiders knowledgeable of certain non-public information that can potentially influence a rational investors investment decision of trading the Company’s securities must comply with the duty of confidentiality until such non-public information is properly disclosed to the public. The Company’s directors, supervisors and senior management, as well as all departments and subsidiaries or branches of COSCO SHIPPING Energy are required to keep such non-public information confidential and refrain from unauthorized disclosure, insider trading and any act of assisting others in manipulating securities prices. Employees shall follow the guidelines given in the Company’s Administrative Measures for Recording and Managing Insiders published on 31 October, 2019.

Fair Opportunity and Prohibition of Harassment

The Company respects legitimate rights of all onshore and offshore staff, and provides competitive remuneration and safe working conditions. The Company shall maintain an inclusive working environment that allows all employees to share level playing ground to develop and utilize their skills. The Company strictly complies with laws and regulations, as well as labor policies, to avoid any form of gender discrimination and provide female employees with equal opportunities and resources to ensure their competitiveness at workplace.

All employees shall be treated with respect at work. The Company does not tolerate any workplace harassment, which includes any unwelcomed, humiliating, intimidating or hostile action or behavior. Employees must also avoid behaviors deemed or might be deemed as harassment. Any person with harassing conduct shall face severe consequences, including disciplinary actions, dismissal and even legal liabilities.

Protection of Company Assets

All employees shall protect and properly use the Companys assets, including vessels, buildings, equipment, tools, provisions, communication facilities, funds, accounts, computer programs, information, technology, documents, techniques, data, patents, trademarks, copyrights and any other resource or property. Onshore and offshore employees are responsible for protecting such assets, so as to prevent waste, damage, abuse, loss, theft, embezzlement or infringement of rights, and ensuring responsible use of the assets.

All employees shall be liable for the ownership and confidentiality of the intellectual property rights that are acquired during the period of employment or arise from employment. Employees shall be careful of cyber attacks or frauds, such as phishing, and immediately report such incident, including those cause or might cause loss to the Companys information or property.

Respect for OthersAssets

The Company highly respects othersphysical assets and intellectual property, and requires that all onshore and offshore staff refrain from knowingly damaging or embezzling othersphysical assets, infringing othersvalid patents, trademarks and copyrights, misappropriating confidential information, or using or disclosing othersconfidential information without proper authorization.

Record-Keeping Accuracy and Completeness

All employees shall make sure that business records and files are prepared and maintained accurately, reliably and timely, including expenditures incurred by individual staff on behalf of the Company. Forgery of asset filing or misrepresentation of facts may constitute frauds, which may potentially bring in civil and criminal liabilities to both individuals and the Company. The Companys business partners, government authorities and the public rely on the accuracy and completeness of the information and records we disclose, so that the Company shall maintain sound decision making based on such documentation, requiring that:

(1)   all transactions be authorized, recorded and reported;

(2)   creation, retention, recording or destruction of the files (including electronic files) be performed in compliance with applicable laws and the Companys rules;

(3)   any response to a request of information from the government or supervising departments should be provided only if necessary prior approvals are obtained.

The Company reviews the management system documents containing the above policies at least once a year, and releases policies immediately after revision to all employees.