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Code of Business Conduct and Ethics

Because Fednav is dedicated to operating in the best interests of its clients, partners, and employees, it bases its decisions on doing the right thing at all times to ensure that we have a sustainable business in the long run. Transparency and good governance are the main focal points of its operations and policies. Fednav's commitment to responsible business practices ensures that the company adheres to all relevant laws and regulations while upholding ethical and compliance standards. These integral practices are crucial to the business's success and are deeply rooted in day-to-day operations. Members of Fednav's leadership team serve on worldwide governing bodies and work with international organizations to set regulations and best practices for the industry as a whole. The objectives of emphasizing ethics and compliance involve fostering a culture where ethical considerations are integral to decision-making processes. This necessitates establishing clear codes of conduct, providing comprehensive training, and implementing robust monitoring and reporting mechanisms.

FEDNAV CODE OF BUSINESS CONDUCT AND ETHICS

Fednav complies with all applicable regulatory requirements and tax regulations in the jurisdictions where it operates. Where possible, the company adopts best practices that go beyond what is legally required. Fednav's policies and procedures ensure that the company conducts its business responsibly.

Compliance with Laws

Fednav will, at a minimum, conducts its business and affairs in compliance with all laws, rules, and regulations, and in accordance with the Company's high ethical standards.

Bribery, Corruption and Facilitation Payments

Fednav does not allow taking, offering, providing, or promising any bribe or unlawful facilitation payment, regardless of the value.

Trade Influence and Competition

Fednav deals fairly with its customers, suppliers, competitors, officers, and employees; and does not take unfair advantage of any other party through fraud, manipulation, concealment, abuse of privileged information, misrepresentation, or omission of material facts or any other unfair practices. Fednav conducts its business and affairs in compliance with all applicable competition legislation.

Money Laundering

Fednav conducts its business and affairs in compliance with all applicable anti-money laundering legislation.

Conflict of Interest

Employees, officers, and directors avoid situations in which their personal interests or actions conflict with, or appear to conflict with, the interests of Fednav.

Business Gifts and Hospitality

Fednav prohibits the giving or receiving of gifts or hospitality with the intention of influencing business decisions, judgements, or outcomes. Reasonable gifts and hospitality are provided and accepted only in the interest of maintaining genuine business relationships.

Discrimination and Harassment

Fednav respects the right to be treated with dignity, courtesy, and respect in an environment free from harassment or discrimination. Fednav has zero tolerance for harassment or discrimination in any form.

Reporting Illegal or Unethical Behaviour

Fednav encourages its directors, officers, and employees to speak up and report concerns about any illegal, fraudulent, corrupt, or unethical behaviour or any other breach of its Code of Business Conduct and Ethics. Third parties are also encouraged to report any such concerns by contacting [email protected]. Alternatively, such reports may be submitted anonymously by using the Whistleblower system.

Fednav will treat all concerns seriously and will follow up conscientiously, discreetly, and without bias, which may include carrying out an investigation.

Fednav does not tolerate any form of retaliation against those who report concerns in good faith.