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QL Ship Management Trading LTD has adopted this Code of Conduct and Ethics which applies to all Company’s employees, managers, agents and ship personnel serving on board vessels managed by the Company.

This Code provides basic guidelines regarding the minimum requirements expected by the Individuals and reflects the Company’s core values and commitment to managing its business with integrity, without being constrained, as it does not describe all of the Company’s policies in detail. All Individuals must take time to review the Code and commit to upholding its requirements.
1. 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, Individuals 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/superior immediately.
2. Corporate Opportunities
Individuals owe a duty to promote the Company’s legitimate interests and not to use corporate property/information, their position in the Company or their rank on a vessel to advance personal interests.
3. Confidentiality and Personal Data Privacy
Confidential information includes any internal information obtained in the course of employment, including but not limited to non-public information concerning the Company’s business, the Company’s customers and suppliers, the Company’s contracts, agreements and transactions and any legal proceedings commenced by or against the Company as well as any non-public information that might, if disclosed, be harmful to the Company or its customers.
Any Individual in possession of such information must maintain the highest degree of confidentiality and must not disclose the same unless lawful authorization is obtained. This obligation remains in effect during the employment of each as well as thereafter.
Further, the privacy of personal data should be protected and treated with confidentiality. Any personal data processing should be made by the applicable laws and regulations.
The consequences to the Company and the Individual/s concerned can be severe if unauthorized disclosure of any non-public, privileged or proprietary information takes place and/or if any unlawful processing of personal data takes place.
4. Environmental Compliance
All individuals are aware, understand and agree to the Company’s Policy for environmental compliance and in this respect, they accept responsibility for working towards achieving environmental protection and continual improvement. No environmental violation whatsoever is to the benefit of the Company and therefore there is zero Company’s tolerance against any such kind of act/omission.
5. Anti-Money Laundering and Combatting Terrorist Financing
It is the Company’s policy to comply with all applicable laws, regulations and recommendations about anti-money laundering and combatting terrorist financing.
The identifying information of the Company’s existing and potential business partners and customers, and the purpose and nature of its business with them are reviewed by the Company regularly. In case the purpose and intended nature of the business relationship are or become suspicious, the Company will refuse the commencement of the business relationship or its continuation, as the case may be.
The Company implements procedures ensuring that sanctioned entities and individuals listed in the OFAC (USA), UN and EU sanctions lists, as updated from time to time, are identified and no business is conducted with such entities and individuals.
6. Anti-corruption, Gifts and Hospitality
It is the Company’s policy to comply with all applicable anti-corruption laws, deny any form of bribery and conduct its worldwide business in an ethical, fair and transparent manner.
It is strictly prohibited for Individuals to offer to pay, pay, authorize payment or promise to pay money or anything of value, directly or indirectly, to a Government Official, an existing or potential business partner or any other party, when such payment is intended to influence the latter’s act or decision, to award or retain business, or to induce or reward unethical or illegal behaviour or a breach of duty.
The Individuals shall not request, receive, solicit, and agree to receive, directly or indirectly, money or anything of value that may reasonably be regarded as a bribe or as an improper incentive for the Company’s business activities.
Gifts and hospitality must never be offered or provided to try to improperly influence business conduct.
7. Market Abuse and Market Conduct
While in the course of dealing with charterers, brokers, vendors, suppliers or any other party, an Individual becomes aware of material non-public information (“inside information”), accidentally or otherwise, he/she must report this to his/her manager/supervisor immediately and must not misuse such information.
8. Ethics Policy
Individuals must act honestly, ethically and fairly towards the Company's customers, suppliers, competitors and employees. No kind of harassment and/ or bullying including cyberbullying, 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 fraud and deception.
9. Protection and Proper Use of Company Assets
The Company's assets are only to be used for legitimate business purposes and only by authorized individuals. This applies both to tangible assets (such as office equipment, telephone, copy machines, etc.) and intangible assets (such as trade secrets, software, confidential information, etc.). Individuals have a responsibility to protect the Company's assets from theft and loss and to ensure their efficient use. If an individual becomes aware of theft, waste or misuse of the Company's assets, such Individual should report this to his/her manager/superior or to the Company’s internal legal department immediately.
10. 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 any law or regulatory requirement to be disregarded in the conduct of its business.
11. Harassment and Bullying
The Company promotes a working environment in which harassment & bullying, including cyberbullying, are not tolerated, supports the right of everyone to be treated with dignity & respect at work and ensures that all individuals are aware of their responsibilities. Incidents of harassment and/or bullying must be reported to the Company, to be treated confidentially and effectively. For further details, please refer to Harassment & Bullying Policy.
12. Enforcement and Duty to Report
Individuals shall report any actual or suspected violation of the Code to their manager/superior.
All should organize their area of responsibility in such a 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.
Failure to comply with the Code of Conduct and Ethics and/or failure to notify the Company of any violation of the Company’s Code of Conduct and Ethics is grounds for disciplinary action and/or dismissal.
13. Prohibition of forced labour, child labour and human trafficking
The Company is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour. The Company will not tolerate or condone such activities in any part of its organisation. Company employees, contractors, subcontractors, vendors, suppliers and others through whom the Company conducts business must avoid complicity in any practice that constitutes trafficking in persons, forced or child labour and must comply with all applicable laws, regulations and recommendations about the above.
The Company ensures that its employees are of legal working age for their position and complies with ILO and MLC standards, as well as with the laws of IMO member countries for youth employment or student work, such as internships or apprenticeships.
The Company takes measures to verify, evaluate, promote awareness about, and address risks associated with forced labour, child labour and human trafficking in its direct business dealings. Examples of actions undertaken include the following:
Evaluating and addressing business risk in the area of forced labour and human trafficking.
Supplier verification of compliance with applicable anti-slavery and human trafficking.
Awareness of Company employees