Economou – International Shipping Agencies Ltd (“the Company”, “EISA” or “we”) has always been committed to conduct its business in an ethical, legal and socially responsible manner. Therefore, we are trying hard each day to grow and nourish our reputation not only for quality service but also for honesty and integrity.

And since we understand and trust that behind this important asset – our reputation – stand the minds, souls and the hard work of the people working with us – whether it is our employees or business partners, we believe that it is our responsibility to create a strong ethical framework for our joint activity together.

This Code of Ethics and Conduct (“the Code”) sets forth the most important values of the Company implemented in uniform principles, standards and practices that we require from our employees, representatives, managers, shareholders, contractors, subcontractors, clients, suppliers, business partners and all other persons engaged in working for and/or with EISA.

This Code is a part of the terms and conditions of employment and is an inseparable part of all business relations in which the Company enters and therefore should be carefully read and comprehended.

LEGALITY

General Compliance

All personnel and business partners of EISA should aim to duly comply with the legislation of Bulgaria and the European Union and to refrain in their activities from breaching any commercial, tax, customs, criminal or administrative obligations which may arise in respect to their relations with the Company or may affect the Company.

Anti-corruption and bribery rules

EISA maintains a zero tolerance policy towards corruption and bribery, which in the sense of the Bulgarian laws occurs when a person holding a senior public office abuses its power, violates or fails to perform official duties in order to directly or indirectly gain a material or intangible benefits for themselves or for other persons, to which they would otherwise not be entitled.

Therefore, the Company advises its employees and business partners to always be alert when conducting business with persons holding senior public office as described in Art. 6, para 1 of the Bulgarian Law against Corruption and Forfeiture of Illegally Acquired Property.

The anti-corruption and bribery principles must be interpreted in a broad sense. No kind of benefits of value, including money, should ever be offered or given on request, neither as incentive nor as a reward, to any public servant or employee or other representative in a private company, in order to obtain a favorable decision for the Company or a third party.

It is also prohibited for Company’s personnel, managers and other kind of representatives to receive any gifts or benefits from third parties, such as suppliers, clients or associates, as well as Company’s competitors, unless it is a gift of low value and in consistent with customary business practices.

Full compliance with the relevant anti-bribery laws is mandatory and any attempts or doubts for involvement in corruption schemes by EISA’s personnel and/ or business partners shall be followed by the most severe sanction possible.

Prohibition of money laundering and tax evasion

EISA conducts business only with reputable and honest partners involved in legitimate business activities and shall have no relations with individuals or entities linked in any way to money laundering or terrorism financing, nor shall it allow its funds to be used for illegitimate purposes. The Company also will always reject doing business in a way that assists or facilitates tax evasion by its suppliers, clients or other third parties.

For the benefit of both parties EISA encourages its partners to undertake similar commitments: to always act in compliance with the tax legislation, the anti-money laundering and anti-terrorism financing legislation.

Prohibition of theft and fraud

EISA requires from its employees duly protection of the Company’s property against theft, damage, misuse, and improper disposal. Acts of theft of employee’s and/or Company’s property and any act of fraud is prohibited, and will be duly prosecuted.

PROTECTION OF HUMAN RIGHTS

Equality, Respect and No Discrimination

The Company does not and will not tolerate any act of discrimination, harassment or victimization. All employees and business partners shall be treated with respect and shall be given equal opportunities and conditions. Any direct or indirect discrimination based on sex, race, nationality, ethnicity, citizenship, religion or belief, education, political affiliation, personal or social status, disability, age, sexual orientation, family or property status is prohibited. Any behavior, gestures, language or physical contact that is compulsive, threatening, abusive or may be perceived as sexual, mental or physical harassment is prohibited.

Health and Safety Measures

EISA is committed to pursuing the highest standards of health and safety for its employees. The Company has adopted and duly applies Internal Rules on the Health and Safety on the Workplace and closely follows and complies with all health and safety Bulgarian laws and by-laws.

Personal Data Protection

EISA is committed to protecting the privacy of individuals and to comply with applicable personal data protection laws and in particular with the European Union’s General Data Protection Regulation (GDPR) and all internal data protection laws and regulations. The Company has duly adopted and fully applies its Internal Rules on Lawful Personal Data Processing and Protection in compliance with the law.

In its contractual relations, the Company insists its business partners to keep any personal data as confidential when it is applicable, use it only for authorized purposes, applying high level of standards that are never below the legal, contractual, or other binding obligations that may be relevant.

ACTING PROFESSIONAL AND IN GOOD FAITH

Antitrust and Fair Competition

EISA believes that the fair competition in the marketplace is the key to economic growth and prosperity and complies with all applicable laws concerning antitrust and fair competition. The Company requires from its employees to always be alert when interacting with competitors of the Company and to not discuss prices and other conditions of the contracts concluded by the Company, as well as to not request or to receive unwanted information from competitors on these matters.

EISA also requires from business partners to avoid collecting or sharing competitively sensitive information such as customer lists or pricing and discount information.

Drugs and alcohol

Possession or use of any substance prohibited by law is not tolerated in the workplace as well. Consumption of alcohol or drugs in the workplace is not allowed. Outside of the workplace and in the framework of business meetings, alcohol consumption is allowable only when it is objectively acceptable, and in such cases it must be consumed in moderate amounts and in accordance with local customs, the applicable laws and the ethical manners.

Loyalty and Conflict of interest

EISA conducts its business in a fair and ethical manner and expects the same behavior form its employees and partners.

Employees of the Company are expected always to be loyal to the Company and avoid potential conflicts of interests, including any kind of competing activities. A conflict happens when the employees have or may have personal interests interfering with their objective work performance or affecting their business decisions. In order to prevent any conflict of interest the employee should always address the managing body of the Company in case there is doubt about a conflict situation. It is also forbidden for the employees and managers of the Company to offer or accept any monetary benefits or gifts to achieve business advantages which they would not otherwise be entitled to. Permitted are only non-monetary gifts that are of minimal value (e.g. flowers, pens, notebooks, cups, etc.) or gifts that are provided for a local holiday or business event and only if they are adequate in nature and in value and are in compliance with the ordinary good commercial customs.

EISA will never extend preferential treatment to partners because of their offer of gifts, entertainment or other items of value. Therefore, EISA’s contractors should refrain from offering gifts to the Company’s employees and managers in an attempt to influence our business decisions, or to gain advantage over other partners.

Intellectual property and confidentiality

The Company values its intellectual property and its confidential corporate information. Employees and partners of the Company are not allowed to disclose confidential information that they have received in the course of their work, except in cases where this is necessary for legitimate business purposes and the recipient of the information has agreed to keep its confidentiality, or when disclosure is required by law. Confidential information includes but is not limited to any non-public information about the Company, including its activities, financial status, operational results, business documentation, client list and information about clients and suppliers, as well as any other commercial information produced by or related to the Company’s business activities, labeled or not as “confidential” etc.

The employees and the partners are also not allowed without the prior consent of the Company to use, distribute or reproduce intellectual property of the Company.

PROTECTION OF THE ENVIRONMENT

EISA cares about our planet and the global environmental issues and aims at contributing towards achieving continual environmental protection improvement. It complies with all Bulgarian legislation regarding environment protection and makes every effort to promote eco-friendly practices. The Company has a zero tolerance policy to any violation of the environmental rules, regulations or laws whatsoever in relation to environmental protection.

The values described above are the foundations of EISA business and are of great importance for our success and development. That is why all employees and partners of the Company are encouraged to take it as a personal liability to observe and apply the standards and practices set above and to always report violations of this Code to the Company’s representatives. On its side, EISA will make every effort to conduct an objective and comprehensive inspection of the facts and to take the necessary measures.

As a matter of principle we believe that complying with a specific Code of Ethics and Conduct is a fundamental asset which builds Company’s relationships with our personnel and all the parties EISA collaborates with. No violation of the rules and standards stipulated in the Code is tolerated and disciplinary action is foreseen for those in breach.