ETHEL MARITIME LTD is committed to providing a quality recruitment and placement service that consistently meets Principal requirements, protects seafarers from exploitation and supports safe and compliant ship operations.

The Company shall:

• comply with MLC, 2006 as amended, including applicable 2022 amendments, and monitor future amendments including 2025 amendments before their expected entry into force;

• comply with Marshall Islands requirements for demonstrating compliance of recruitment and placement services, including Marine Notices;

• recruit and place only seafarers who are trained, certified, medically fit and otherwise qualified for their intended duties;

• verify documents and employment references as far as practicable;

• ensure that no recruitment or placement fee is charged to seafarers directly or indirectly, except only permitted personal document costs under applicable requirements;

• supply seafarers only to Principals that offer terms and conditions compliant with applicable laws, regulations and collective agreements;

• protect personal data and confidential information;

• maintain an efficient complaint and appeal system without retaliation;

• maintain financial security arrangements for monetary loss compensation through shipowner P&I/financial security or ETHEL cover where required;

• continually improve recruitment quality, operational responsiveness and compliance performance.

All employees are responsible for implementing this policy. Management shall review the policy at least annually during management review and after any material legal, operational or audit change.

Ethical Compliance

ETHEL MARITIME LTD shall conduct business lawfully, transparently and with respect for seafarers, Principals, authorities, employees and suppliers. Bribery, gifts, informal payments, improper commissions, coercion, deception, discrimination, retaliation and conflicts of interest are prohibited.

All personnel shall immediately report suspected ethical violations, attempted fee collection, illegal commissions, data misuse, document fraud, discrimination, harassment or blacklisting to the Director or appointed compliance person. Confirmed violations may result in disciplinary action including termination and, where appropriate, notification to competent authorities.

Anti-Blacklist and Fair Recruitment Policy

The Company shall not use any means, mechanisms, lists, informal databases or practices intended to prevent or deter seafarers from gaining employment for which they are qualified. Negative information shall never be kept indefinitely or used as a hidden blacklist. Any rejection shall be objective, verifiable and related to legal, medical, safety, operational, qualification or documented Principal requirements.

The following controls apply:

• no secret blacklist, informal blacklist, arbitrary exclusion list or financial rejection list shall be created, used, shared or accepted;

• rejection reasons shall be documented when requested by the seafarer or when risk indicators exist;

• rejection shall not be based on complaints, union activity, lawful rights-seeking activity, personal dislike, political opinion, financial expectation or refusal to pay improper money;seafarers may appeal through the complaint mechanism and shall be protected from retaliation.

Company and Crewing Policy

Ethical Compliance, Anti-Blacklist and Fair Recruitment