Business Ethics

Aegean Shipping Management S.A. is committed to promote a honest and trustworthy working environment, both on board and ashore and to implement strictly and without deviations, Company’s Business Conduct and Ethics Policy.

Senior management of Aegean Shipping Management S.A. shall lead by example

Employees on-board and ashore must act honestly, ethically and fairly towards the Company’s customers, suppliers, competitors and employees. No kind of harassment, manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice should take place. The Company has a zero-tolerance approach towards bribery and corruption, fraud and deception.

Whistleblower Policy

The Company has adopted a whistleblower policy by means of which, employees on-board and ashore are encouraged to report any known or suspected environmental, legal or other violation to the Office. Employees may choose to remain anonymous, but even if they identify themselves, their identity and information provided will remain strictly confidential.

Compliance with Laws, Rules and Regulations

It is the Company’s policy to strictly comply with all laws, rules and regulations that apply to its business. It is the personal responsibility of each Individual to adhere to the standards and restrictions imposed by these laws, rules and regulations and to prevent, detect and report instances of non-compliance.
There are no circumstances where the Company will allow that any law or regulatory requirement be disregarded in the conduct of its business.

Conflicts of Interest

A conflict of interest occurs when an Individual’s private interests interfere, or appear to interfere, with the interests of the Company as a whole. While it is not possible to describe every situation in which a conflict of interest may arise, employees on-board and ashore must never use or attempt to use their position with the Company or their rank on a vessel to obtain personal benefits. Any Individual who is aware of a conflict of interest, or is concerned that such a conflict might arise, should address the matter with his/her manager immediately.

Enforcement and Duty to Report

Employees on-board and ashore shall report any actual or suspected violation of the Code to their manager/superior. All should organize their area of responsibility in such way that violations of the Code can be observed and relevant reports are received and looked into. Violations may result in reprimand, claim for damages and/or termination of employment or loss of office. The above principles form part of the Company’s general policy. In cases where employees are witnessing a violation and are failing to report, this will be considered as ground for disciplinary action and/or contract termination.

Aegean Shipping Management S.A., 10 Akti Kondili, Piraeus, Greece, 185 45 Tel: (+30) 210 4586000 Fax: (+30) 210 4586242

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