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Castor Marine Code of Conduct 2023

Introduction

1. Castor Marine takes its responsibilities in ensuring the supply chain is auditable and compliant with legislation seriously. This is not only applicable to Castor Marine, but also to its Suppliers. This means not only Castor Marine is required to this Code of Conduct but also we require every (new) Supplier to confirm they are compliant with the Castor Marine Supplier Code of Conduct confirming compliance with this Code of Conduct.

Anti-bribery/Corruption

2. Bribery and Corruption is not tolerated in the Castor Marine Supply Chain. Castor Marine and its Suppliers must comply with all Laws relating to anti-corruption and anti-money laundering in all of the countries in which Castor Marine, its Supplier or any affiliated business provides products or services.

3. Castor Marine, nor its Suppliers shall give to or receive any gift or entertainment of material value which could cause either party to be brought into disrepute.

4. Castor Marine confirms its compliance with the Anti-Bribery Act 2010 and that neither it, nor any of its Directors or Employees is, or has engaged in any activity, practice or conduct or has taken any action or inaction directly or indirectly, which constitute an offence under any applicable laws, statutes and regulations relating to anti-bribery and anti-corruption.

Unfair Business Practices

5. Castor Marine will not and its Suppliers must not engage in any illegal anti-competitive conduct or deceptive trade practice for any reason whatsoever, whether on behalf of Castor Marine, Supplier, or others.

Sanctions and Export Controls

6. Castor Marine and its Suppliers must comply with all applicable sanctions, trade restrictions and export control Laws. Castor Marine and its Suppliers shall not engage in business activities that would breach such Laws, including onward transfers or facilitation. Where required by Law, appropriate screening or due diligence measures shall be applied.

Health and Safety

7. Castor Marine and its Suppliers must comply with all health, safety, and security Laws where it works to reduce risks and hazards to workers through appropriate risk management and risk mitigation. All accidents and near-misses will be reported to Castor Marine HSE@castormarine.com.

8. Health and safety breaches and accidents shall be recorded and reported in line with applicable Laws. Castor Marine is committed to a safety-first culture: protecting our people and those we work with is a priority. We expect our Suppliers to follow suit and to provide a safe environment, meaning you shall take appropriate action, such as policies, standards, procedures, and management systems in order to prevent occupational illnesses and work-related accidents and to provide a safe and healthy workplace. Relevant training, personal protective equipment and monitoring will also be provided by its Suppliers.

Environment and Sustainability

9. Castor Marine and its Suppliers must comply with all applicable environmental Laws when setting up, running or ceasing a service or providing a product. This includes complying with reporting standards and achieving permits when required.

10. Castor Marine and its Suppliers must minimize any packaging required, dispose waste products in an environmentally responsible way and use green energy wherever possible.

Conflict of Interest

12. Castor Marine shall avoid all conflicts of interest or situations giving the appearance of a conflict of interest when doing business with the Customer. In case of a conflict of interest, Castor Marine must inform the Customer contact person immediately.

Labor

13. Castor Marine and its Suppliers must follow all applicable Laws in the countries in which it operates, and be committed to the value of, and respect for, all people.

14. Castor Marine and its Suppliers are responsible for respecting human rights in its operations and comply with the standards set forth in the United Nations Universal Declaration of Human Rights.

15. Castor Marine confirms its compliance with the Modern Slavery Act 2015 and in particular that we are not in any way connected with, slave labor, human trafficking or exploitation, or any other activity which would constitute an abuse of human rights.

16. The standards set forth in this Code apply to all workers, including, without limitation, temporary, migrant, student, contract, direct employees, and any other type of worker of Castor Marine and its Suppliers.

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