Signal for Corruption or Irregularity

Odessos Shipyard conducts its business with loyalty, fairness and transparency and in full compliance with international laws and regulations. With this in mind, corruption is an intolerable obstacle to business efficiency and fair competition.

In accordance with the principle of “zero tolerance” towards corruption expressed in the Code of Ethics, Odessos decided to face head-on other risks, which may be encountered by the Company in its business activities, by implementing a detailed system of rules and controls to prevent corruption-related crimes, which is characterised by its dynamism and constant attention to evolving national and international legislation and best practices.

Odessos takes all misconduct seriously and everyone should feel free to report any wrongdoing or irregularity as described herein. Odessos shall not dismiss, discharge, demote, suspend or in any way harass the employee or business partner who has reported a concern in good faith.

To send a signal for corruption and/or conflict of interests as well as for any signals of general nature you may use one of the following means:

• You don’t have to identify yourself as the system has been designed to allow anonymity.
• Only authorised Odessos’s staff will be able to access your signal.
• Violations committed more 3 (three) years ago shall be considered inadmissible and shall not be processed.

Conflict of interest

The relationship of personnel involved in the process regulated in this Standard Procedure with their counterparts shall aspire to the highest standards of ethical behaviour in compliance with the Odessos Shipyard Code of Ethics.

Every effort must, therefore, be made to avoid all situations and activities which could give rise to a conflict with the company’s interests or which could interfere with a person’s ability to take decisions impartially in the best interests of the company and in full observance of the principles and contents of the Code of Ethics and of the company’s Model, the Anti-corruption MSG and, in general, with the correct performance of their duties and responsibilities.

Any situation that could constitute or give rise to a conflict of interest shall be managed in accordance with the provisions of the Code of Ethics and the AntiCorruption
MSG.

Anti-corruption policy

Odessos Shipyard prohibits all forms of corruption, without exception. In particular, Odessos Shipyard prohibits:

• offering, promising, giving, paying, authorising anyone to give or pay, directly or indirectly, financial or other benefits to a Public Official or private party (Active Bribe);
• accepting, or authorising someone to accept, directly or indirectly, financial or other benefits or the requests or entreaties for financial or other benefits from a Public Official or private party (Passive Bribery).

When the intention is:

• to induce a Public Official or private party to perform improperly any function of a public nature or any activity connected with a business or to reward them for the improper performance of such a function or activity;
• to influence any official act (or failure to act) by a Public Official or any decision in violation of any his/her official duty;
• to obtain or secure any improper advantage in the conduct of business;
• in any case, to violate the applicable laws. Prohibited conduct includes financial or other benefits offered to or received by Odessos Shipyard Personnel (Direct Bribery) or by anyone acting on behalf of Odessos Shipyard (Indirect Bribery) in connection with Odessos Shipyard’s business.