1. Respect in every work setting

This policy applies to LT Marine Offshore Services, Inc. directors, staff and people acting for the company in dealings with applicants, seafarers, colleagues and business partners. It covers interviews, office work, training arranged by the company, business travel and work-related online activity. Concerns connected with a vessel must be coordinated with the responsible employer and shipboard arrangements without removing LT Marine's own duties.

Respect lawful differences and assess people fairly. A person may experience abuse from a superior, a peer, a subordinate, a customer or another participant in the recruitment process.

2. Conduct that is prohibited

Prohibited conduct includes unwanted sexual approaches, requests for sexual favours, sexual comments or images, discriminatory abuse, threats, intimidation and repeated humiliating or hostile treatment. Online conduct and a supposedly private message can cause the same harm as conduct in person. Serious single incidents also require action.

Do not link an interview, deployment, assessment, promotion or continued work to a personal or sexual favour. Do not ridicule a person's identity, disclose intimate information to embarrass them, or encourage others to isolate or target them. Reasonable, respectful feedback and fair performance management must not be used as a cover for abuse.

3. Reporting and immediate protection

You may approach a manager you trust or email Diane Tapia, Data Protection Officer, at dpo@lt-marine.com to request safe routing of a concern. You do not have to confront the person involved or report through your line manager first. The DPO contact does not replace the legally required investigating mechanism.

Describe the conduct, relevant dates, any continuing risk and a safe contact method. Preserve messages or other evidence you lawfully hold. Avoid sending unnecessary medical or identity documents. Email may identify you; the company cannot promise absolute confidentiality.

Immediate danger requires vessel emergency procedures or relevant emergency services. You may seek a representative, independent advice or assistance from an appropriate authority at any time.

4. Impartial and fair handling

Management must establish and maintain the independent mechanism or Committee on Decorum and Investigation required by applicable Philippine law. It must have the required workforce representation, a woman as chair and at least half of its members women. Members must be impartial; conflicted members must be replaced. Management must publish the current reporting arrangements to personnel.

The recipient must refer a complaint promptly to the proper mechanism, assess immediate protection needs, limit access to necessary persons and preserve relevant records. An implicated person must not control the case. The respondent must receive a fair opportunity to answer; decisions must consider relevant evidence and be communicated appropriately. Provide information about any applicable review or appeal route.

Applicable statutory investigation and decision deadlines take priority. Referral between company contacts must not be used to delay a complaint or require informal settlement as a condition of access.

5. Protection and consequences

Retaliation against a complainant, witness or person assisting a review is prohibited. Protective arrangements must avoid unfairly disadvantaging the person raising the concern. An unproven concern or an honest mistake is not a deliberately false report.

Following fair procedure, substantiated breaches may result in a warning, suspension or dismissal where lawful and proportionate; contractual remedies may apply to representatives or suppliers. Deliberate retaliation, serious abuse and interference with an investigation must be assessed as serious misconduct. Criminal or regulatory matters may be referred to the appropriate authority. No sanction is automatic.

6. Prevention and accountability

Management must consult personnel or their representatives on workplace rules, explain this policy, arrange preventive education and ensure managers know how to respond. Maintain controlled case records under applicable privacy and retention requirements. Review recurring risks and corrective actions.

Our Speak Up & Whistleblower Policy provides a further route for suspected misconduct or a concern about the person handling a report. Company processes do not waive rights to report to authorities, pursue lawful remedies or use applicable onboard procedures.

1. Honest opportunities and official channels

This policy applies to LT Marine Offshore Services, Inc. staff and representatives involved in sourcing, assessment, documentation and deployment. Managers must explain these requirements to any recruitment intermediary and address conduct carried out in the company's name.

Advertisements must describe genuine opportunities and relevant requirements accurately. Direct applications to registration.lt-marine.com. Do not promise a job, visa, joining date or promotion before the relevant selection and approvals. Applicants may verify a message through crewing@lt-marine.com; an unexpected social-media message is not proof of authority.

2. Fair assessment and eligibility

Assess candidates against relevant qualifications, competence, experience and lawful assignment requirements. Verify age, certificates, medical eligibility and documents through appropriate authorised processes. Do not fabricate an assessment or overlook a deficiency to fill a vacancy.

Explain the main stages and any further information needed. Do not demand a gift, personal connection or favour to progress an application. Do not blacklist a person for honestly raising a concern, refusing an unlawful charge or exercising lawful employment rights. A declined application must not become an informal exclusion list.

3. Recruitment fees and permitted document costs

LT Marine must not levy recruitment or placement fees, visa costs or related prohibited charges on a seafarer or their family, directly or through another person. Do not disguise a job payment as a reservation, processing deposit, compulsory donation, loan or deduction.

Philippine law permits limited personal-document costs for obtaining a medical certificate, seafarer's record book, passport or similar travel documents. Any cost the applicant is asked to bear must be lawful for the assignment, explained beforehand and supported by a proper receipt. Apply any rule or employment term providing greater protection. Shipowner responsibility for visa costs must be respected.

Do not collect a personal commission or require payment to a staff member's private account. Report an unexplained request before paying it so the company can assess the charge and any required correction or refund.

4. Understand the employment agreement

Before signing, the responsible team must identify the employer or shipowner and explain the proposed role, vessel or assignment, duration, pay, deductions, joining arrangements and relevant welfare and complaint contacts. Give the seafarer a real opportunity to read the agreement, ask questions and seek advice.

Provide the required signed employment documents and explain applicable standard terms or collective agreements. Do not substitute less favourable terms through pressure, conceal a material change or require a blank signature. Further approvals and official processing must follow the current rules applicable to the assignment. Principal and agency obligations under law continue to apply.

5. Documents, personal information and choice

Request only information needed for an explained recruitment purpose and handle it under the Privacy Notice and applicable portal notice. Do not ask applicants to publish passports or medical records in social-media comments.

Never retain original documents as security for a debt or continued employment. Where originals are needed for lawful processing or authorised safekeeping, record the purpose, provide a receipt and keep them accessible for prompt return. Explain the proper process for withdrawing an application or raising a proposed contract change without intimidation.

6. Support, concerns and oversight

The responsible crewing team must communicate joining arrangements and the appropriate contacts for employment or welfare concerns. Our 24/7 Hotline: +63 919 003 3093 provides operational and welfare support; immediate danger requires vessel emergency procedures or relevant emergency services.

Use Seafarer Grievance & Welfare for a service or employment concern, and Speak Up & Whistleblower for suspected wrongdoing. External reporting and legal remedies remain available. Management must keep appropriate recruitment records, review complaints and intermediary risks, and arrange corrective action and guidance. This policy complements our Modern Slavery Policy.

1. Choose a contact route

This procedure covers LT Marine Offshore Services, Inc. recruitment and crew-management concerns, including joining arrangements, treatment, wages, allotments, medical support and repatriation. Principals, seafarers, applicants, families and business partners may also give service feedback.

• Routine crew support: crewing@lt-marine.com.
• Service complaints and unresolved welfare concerns: crewing@lt-marine.com. Use “LT Marine complaint” or “LT Marine service feedback” as the subject.
• Misconduct, retaliation or a concern involving the ordinary recipient: use the Speak Up & Whistleblower Policy and dpo@lt-marine.com, or approach a manager you trust.

Email links open your email application; send the message there. LT Marine charges no fee for raising or reviewing a complaint through this procedure. You may ask for assistance and involve a lawful representative.

2. Urgent welfare and safety

For operational or welfare support, call our 24/7 Hotline: +63 919 003 3093. Explain the vessel, location where relevant, urgency and safe contact route. A caller reporting another person's concern should explain their relationship and authority to assist.

Immediate danger, urgent medical needs or a shipboard emergency require the vessel's emergency procedure and appropriate emergency services. Alert the responsible onboard officer where safe. Do not wait for an email reply or use an ordinary website complaint as a substitute for an emergency report. Relevant crew, principal and shipowner contacts must be involved according to their responsibilities.

3. What to include and how we protect information

Explain what happened, relevant dates, any vessel or contract reference, the outcome you seek and a safe way to reply. Tell us about immediate risks, earlier correspondence or any difficulty using the usual reporting route. You do not need to complete a special website form to contact us.

Keep passport numbers, full medical or bank records and unnecessary information about other people out of an initial message. Ask the recipient to arrange a suitable exchange if supporting documents are needed. Access to complaint information must be limited to authorised people who need it for assessment, response or legal duties, as explained in our Privacy Notice. Email can identify its sender; absolute confidentiality cannot be promised.

4. Assessment, response and further review

The receiving team must assess urgency and conflicts, preserve relevant information and assign a responsible reviewer. A person implicated in the concern must not decide its outcome. The reviewer must acknowledge receipt where a safe contact is available, explain any further information required and tell the person when to expect the next update.

The responsible team must seek relevant facts, give affected people a fair opportunity to respond, coordinate action within LT Marine's responsibilities and communicate the response and next steps where lawful. Record the concern, decisions, responsible people and follow-up; recurring or significant issues require corrective-action review.

For further review, reply to the correspondence or email the crewing team with the earlier reference and why you disagree. Request a manager who was not involved in the original decision. If there is a conflict or alleged retaliation, use Speak Up or an appropriate external route.

5. Formal procedures, deadlines and protection

Onboard and onshore grievance arrangements, employment agreements, collective bargaining agreements and applicable law continue to apply. Seafarers must have access to the ship's complaint procedure and relevant contacts, assistance or representation where provided, and protection from victimisation. LT Marine prohibits retaliation, threats or blacklisting for an honestly raised concern.

You do not need to complete LT Marine's website/email process before contacting an authority, seeking advice or obtaining emergency help. Statutory, contractual and collective-agreement grievance, conciliation or arbitration procedures and filing deadlines still apply. This page does not replace those mechanisms or pause a deadline.

Where section 58 of the Philippine Magna Carta of Filipino Seafarers applies, specified salary, statutory-benefit, disability or death claims must be validated and the findings communicated within 15 days of submission of the claim, proof or complete documents, as applicable. Established obligations must be settled within 15 days after communicating the findings. Other case-specific legal periods also govern.

You may seek guidance from the Department of Migrant Workers, an appropriate labour or maritime authority, your union or an independent adviser. Management must assign handlers, brief the relevant teams, monitor applicable deadlines and review the effectiveness of this procedure.

1. Who can report & what to report

This policy is open to current and former employees, seafarers, applicants, principals, suppliers, contractors and other people with concerns connected with LT Marine’s activities.

• Fraud, theft, bribery, corruption or falsification of records.
• Recruitment misconduct, unlawful fees, exploitation or abuse.
• Harassment, discrimination, threats or other serious misconduct.
• Unsafe practices, environmental harm or suspected breaches of law.
• Misuse of personal information, concealment of wrongdoing or retaliation.

You do not need to prove the concern before reporting. Explain what you reasonably believe happened and distinguish facts from assumptions.

This Speak Up policy also covers suspected breaches of our company policies, including anti-corruption, anti-money laundering, competition, sanctions, data security, modern slavery, social media, social responsibility, fair recruitment, dignity at work, safety and business-partner standards. Concerns may be raised before harm occurs.

2. How to make a report

Email dpo@lt-marine.com with as much relevant information as you can safely provide:

• What happened, when and where, including any relevant vessel or service.
• The people involved and any witnesses, where known.
• Any continuing risk or concern about retaliation.
• A safe way to contact you, if you wish to receive a response.

Describe relevant evidence you already lawfully hold. Do not put yourself at risk, access records without authorization or send unnecessary passport, bank or medical information. Ask the recipient how to provide sensitive supporting documents appropriately.

Reports received without a name will be considered on the information available, although investigation and feedback may be limited. This website does not provide an anonymous reporting system.

You may speak to a manager you trust or use the reporting email directly. You do not have to approach your manager first. Managers receiving a concern must escalate it promptly, protect relevant records and avoid investigating a matter in which they are involved. If you believe the response is inadequate, write again with that concern or approach an appropriate authority.

3. Protection against retaliation

LT Marine prohibits retaliation against anyone who raises a concern honestly or assists a review. This includes threats, intimidation, harassment, dismissal, unfair treatment or adverse recruitment or deployment decisions because of the report.

This protection applies even when a concern is not substantiated. Report suspected retaliation through this channel or an appropriate external authority. Retaliation will be reviewed and may lead to disciplinary or other appropriate action, subject to fair procedures.

Deliberately providing information known to be false may lead to appropriate action. An honest mistake or an unproven concern is not a deliberately false report.

4. Confidentiality & personal information

LT Marine will limit access to reports and identifying information to authorized people who need it to assess the concern, investigate, take appropriate action or meet legal obligations. Information will not be shared more widely than necessary for those purposes.

Absolute confidentiality cannot be guaranteed. Limited disclosure may be necessary for a fair investigation, professional advice or a lawful request from an authority. Where lawful and practicable, we will discuss with you any necessary disclosure of your identity.

Records will be protected against unauthorized access and retained only as necessary to handle the matter and meet applicable legal requirements, including any required preservation for proceedings. They will then be securely disposed of or anonymized.

For privacy questions or requests concerning your information, contact dpo@lt-marine.com. Requests will be considered subject to applicable law and the rights of others.

5. How reports will be handled

1. Assess: review the concern, any immediate risk and any conflict of interest; acknowledge receipt where a safe contact method is available.
2. Review fairly: assign an authorized person who is not involved in the concern, obtain relevant information and give affected people an appropriate opportunity to respond.
3. Act: determine appropriate corrective, disciplinary or referral action based on the findings and applicable requirements.
4. Follow up: provide updates and, where appropriate, a summary of the outcome, subject to confidentiality and the rights of others.

The time needed depends on the nature and complexity of the concern. Receiving a report does not predetermine its outcome. The person receiving a report is not automatically the person who investigates it.

6. Independent reporting & your rights

If a concern involves the person receiving reports, or you are uncomfortable using the company channel, you may approach an appropriate external authority. Company permission is not required to contact an authority.

Depending on the concern, these may include the Department of Migrant Workers for recruitment or manning matters, the National Privacy Commission for privacy matters, or relevant maritime authorities or law enforcement. Use the authority’s official guidance for its reporting procedure.

This policy supplements existing onboard and onshore complaint procedures, employment grievance procedures and applicable collective agreements. It does not remove rights to approach the master or appropriate authorities, seek advice or obtain representation. Any applicable legal procedures and filing deadlines still apply.

7. Responsibility & review

Company management is responsible for implementing this policy, authorizing access to the reporting mailbox and arranging impartial handling of concerns. Anyone involved in a concern must not investigate or decide the outcome of that concern.

The policy will be reviewed periodically and when changes to the business, reporting arrangements or applicable requirements make an update necessary.

Managers must explain these reporting routes to their teams, arrange guidance appropriate to their work and check that corrective actions are followed through. A person involved in a reported issue should preserve relevant information and cooperate honestly; cooperation does not guarantee immunity.

Legal whistleblower protection depends on the applicable law and circumstances. This company policy does not limit any broader statutory protection or require confidentiality to be used to conceal wrongdoing.

1. Scope and responsibilities

This policy sets expectations for LT Marine Offshore Services, Inc. employees, representatives and contractors in activities the company manages or coordinates. Management must identify applicable Philippine occupational safety requirements, including Republic Act No. 11058 and current implementing rules, and arrange the personnel, resources and instruction required for the workplace.

For shipboard work, follow applicable flag-state requirements, the vessel’s safety management system and the master’s instructions. LT Marine’s shore coordination must support safe assignments within its role; this policy does not replace the master’s authority or the shipowner’s statutory responsibilities.

2. Plan work and raise hazards

Before starting an unfamiliar task, understand the hazards, controls and your authority to perform it. Ask for instruction if you are unsure. Managers must assess relevant risks, explain controls and provide required protective equipment and safe working arrangements. Do not bypass a guard, permit, qualification or safety check to meet a deadline.

Keep exits and access routes clear, use equipment appropriately and report defective equipment, unsafe conditions, near misses and injuries promptly. Where an activity appears unsafe, pause it where safe to do so, move away from immediate danger and alert the responsible supervisor or vessel officer. Respect applicable rights to refuse unsafe work and report hazards without retaliation; do not pressure someone to resume while an imminent danger remains unresolved.

3. Fitness, rest and welfare

The crewing team must check the qualifications and required fitness documentation relevant to the assignment and escalate concerns about travel, joining arrangements or working conditions. Do not falsify certificates or rest records, conceal fatigue or direct another person to conceal it.

Report fatigue, illness, injury or other concerns that could affect safe work through the appropriate workplace or onboard route. Managers must consider a safe response and necessary assistance. Share medical details only with authorised people who need them; apply our Privacy Notice. Respect dignity and use the Dignity at Work & Anti-Harassment Policy for related concerns.

4. Protect the environment

Office teams must segregate waste using the available lawful arrangements, avoid unnecessary printing and use energy, water and supplies responsibly. Batteries, electronic equipment, chemicals and other special waste must go through suitable collection or disposal routes. Do not mix hazardous material with ordinary waste or arrange unlawful dumping.

Personnel aboard must follow the vessel’s pollution-prevention procedures, including relevant waste, spill and reporting instructions. Never falsify an environmental record or make an unauthorised discharge. Crew briefings must identify the applicable onboard instruction and training routes. Purchasing and travel decisions should consider practical waste and resource reductions alongside safety, service needs and worker rights.

5. Emergencies and concerns

In an emergency, use the workplace or vessel emergency procedure and relevant emergency services. Do not attempt a rescue or contain a hazardous release beyond your training and available protection. Notify the responsible person and preserve relevant information when safe.

Our 24/7 Hotline: +63 919 003 3093 provides operational and welfare support; it is not an emergency-services number. Routine questions may be sent to crewing@lt-marine.com. Suspected concealment, retaliation or misconduct can be raised through dpo@lt-marine.com under our Speak Up & Whistleblower Policy.

6. Learning and accountability

Management must arrange appropriate review of incidents and recurring hazards, assign corrective actions and check their completion. Keep records required by applicable law and the activity, protect personal information and cooperate with competent authorities. Review this policy when operations or requirements change and communicate relevant lessons.

1. Purpose and application

LT Marine Offshore Services, Inc. expects suppliers, recruitment intermediaries, agents, contractors and other business partners to conduct work connected with us lawfully and responsibly. Staff choosing or managing a partner must consider these standards and the risks of the proposed service.

This public code explains expectations. It does not itself create a new contract or amend an existing agreement merely because someone visits the website. Management must identify relevant requirements and include specific obligations, remedies and any permitted subcontracting in an authorised agreement where appropriate.

2. Workers and fair recruitment

Partners must not use forced labour, trafficking, unlawful child labour, threats, recruitment debt or identity-document withholding to control a worker. Apply lawful age, employment, pay, rest and safety requirements relevant to the work. Workers must have access to their documents and safe routes to raise concerns.

Recruitment partners are expected to follow our Fair Recruitment & Seafarer Employment Policy and Modern Slavery Policy, including the prohibition on seafarer recruitment or placement fees and the treatment of any lawful personal-document costs. Do not misrepresent a vacancy, substitute contract terms through pressure or blacklist a worker for making an honest complaint. Respect lawful representation and prevent harassment and discriminatory treatment.

3. Honest business and payments

Never offer or request an improper benefit to win business, obtain an approval or influence recruitment. Disclose a relevant personal or financial conflict before it affects a decision. Keep invoices, expenses and supporting records accurate; do not disguise a payment as a donation, commission or reimbursement.

Provide information reasonably needed to verify the business, the service and authorised payment details. Unusual payment changes require verification through a trusted contact. Do not participate in collusion, laundering criminal proceeds or sanctions evasion. Follow applicable law and the relevant Anti-Corruption, Anti-Money Laundering, Competition and Sanctions policies when working with LT Marine.

4. Safety, environment and information

Use competent personnel, necessary permissions and appropriate controls for the work. Coordinate hazards with other parties at the workplace and follow applicable vessel procedures. Report serious safety or environmental risks promptly. Handle waste and materials through lawful arrangements; do not conceal pollution or falsify safety records.

Use company, client and seafarer information only for an authorised purpose. Limit access, protect records and report suspected loss or misuse promptly. Processing personal data requires clear instructions, appropriate safeguards and the necessary agreement; our Privacy Notice and Data Security Policy remain relevant. Subcontracting must not be used to bypass agreed protections.

5. Checks and resolving concerns

The responsible LT Marine manager must obtain proportionate evidence for higher-risk relationships, record concerns and seek advice before proceeding when material issues remain unresolved. Partners are expected to answer reasonable questions honestly and cooperate with review under applicable law and agreed terms. This code does not grant unrestricted access to a partner’s systems or confidential records.

Management must consider the facts, seriousness, worker safety and available remedy when deciding on corrective action, suspension or termination under the agreement and law. Identify an action owner and follow up. Ending a relationship alone may not protect affected workers; consider safe remediation and required referrals.

6. Raising issues and keeping standards current

Send routine business questions to crewing@lt-marine.com. Suspected wrongdoing or pressure to bypass this code can be reported to dpo@lt-marine.com under our Speak Up & Whistleblower Policy. Honest reports must not lead to retaliation; reporting to an appropriate authority remains available.

Management must communicate relevant expectations, arrange guidance for purchasing and relationship owners, and review the code, partner risks and outstanding corrective actions periodically.

1. Who must follow this policy

This policy sets requirements for LT Marine Offshore Services, Inc. directors, employees and anyone acting for the company. Managers must communicate relevant requirements to agents, recruitment intermediaries, suppliers and other business partners. Business targets, local custom or instructions from a customer do not justify an improper payment.

People representing LT Marine must follow applicable anti-corruption law, including Philippine requirements and any other law applicable to their activity. Obtain management guidance and appropriate legal advice where an overseas transaction creates uncertainty.

2. Decisions must not be bought

Do not promise, give, request or receive money, gifts, favours or another benefit to influence a decision improperly. This applies to dealings with private businesses and public officials, whether the advantage is provided directly or through another person.

• Do not ask an applicant for a personal payment, gift or favour to secure an interview, deployment or preferred assignment.
• Do not pay an unofficial fee to obtain a document, overlook a deficiency or accelerate a port or government procedure.
• Do not arrange hidden commissions, false expense claims, inflated invoices or sham services.
• Disclose a personal or financial relationship that could influence recruitment, purchasing or a contract decision, and step back from the decision pending management review.

3. Gifts, hospitality and support

A business courtesy must have a legitimate purpose, be modest, transparent and lawful, and create no expectation of favourable treatment. Decline cash, cash equivalents and any benefit connected with an active selection, tender or approval. Where the circumstances are uncertain, obtain documented management approval before offering or accepting it; approval cannot make an unlawful benefit acceptable.

Record the recipient, purpose, value and approval of company hospitality or gifts. Charitable support, sponsorship and political activity must never disguise a reward for business. Company funds or the company name may be used for such support only after management checks the recipient, purpose and applicable restrictions.

4. Agents, expenses and immediate threats

Before appointing an intermediary, the responsible manager must establish who will perform the work, why the service is needed and whether the proposed fee is reasonable. Require an accurate written description and supporting payment records. An agent must not do something LT Marine could not lawfully do itself.

Request official invoices and receipts for legitimate charges. Record the real purpose of every expense; never conceal a questionable payment under a different description. If a demand involves an immediate threat to life or physical safety, prioritise safety, follow vessel or local emergency arrangements and report what happened as soon as it is safe. Preserve the facts for management assessment and any required referral.

5. Reporting and responsibility

Report suspected misconduct through the Speak Up & Whistleblower Policy. Do not investigate covertly or destroy records. LT Marine prohibits retaliation for an honestly raised concern or refusal to participate in corruption.

Management is responsible for implementing these requirements, addressing conflicts, providing guidance to relevant roles and reviewing the policy when risks change. Confirmed breaches may lead to corrective or disciplinary action, contractual remedies or referral to authorities, with applicable law and fair procedure observed.

1. Purpose and legal context

This policy applies to company directors, employees and representatives handling business relationships, invoices, payroll, refunds or other funds for LT Marine Offshore Services, Inc. It prohibits knowingly dealing with criminal proceeds or helping another person disguise their origin, ownership or destination. Terrorist financing concerns must also be escalated.

The Philippine Anti-Money Laundering Act, as amended, distinguishes the general money-laundering prohibition from particular duties of legally defined covered persons. A maritime business is not automatically a covered person merely because it makes or receives payments. Management must obtain advice on duties applicable to the actual activity; this policy does not claim a registration, reporting system or regulatory status.

2. Understand the business relationship

Before approving a new commercial relationship, the responsible manager must obtain enough reliable information to understand the other party's identity, business, authority to act and reason for using LT Marine's services. Where ownership or control is unclear or the arrangement is unusually complex, seek further information and management review.

The checks must match the transaction's risk. A small routine supply and a large unfamiliar cross-border arrangement need different attention. Collect only information that is necessary, protect it under our Privacy Notice and do not treat nationality, name or place of birth alone as proof of wrongdoing.

3. Follow traceable payment instructions

• Match the invoice or employment obligation to the approved service, amount, payee and account.
• Independently confirm a new bank account or changed payment instruction through an established contact route; do not rely solely on a reply to the message requesting the change.
• Escalate requests to use an employee's personal account, an unexplained third-party account or a payment route unrelated to the service.
• Do not split payments, falsify invoices or describe funds inaccurately to avoid scrutiny.
• Verify the reason and destination of any refund rather than automatically sending an overpayment to a different account.

4. Warning signs and escalation

Warning signs include unexplained cash, repeated overpayments, inconsistent documents, pressure to act before normal checks, a payer refusing reasonable identity questions, or transactions with no credible commercial purpose. One sign is not a finding of crime. Consider the facts and record the reason for concern.

Refer an unresolved concern promptly to management before approving the affected transaction. Seek advice about any lawful restriction or external reporting duty; an internal concern alone does not give an employee authority to confiscate funds or disclose private information. Assess legitimate crew welfare and wage obligations when deciding how to manage an interruption. Do not alert others to a confidential report where doing so would breach law or prejudice an investigation.

5. Records, reporting and oversight

Keep accurate supporting records of the checks, payment instructions, approvals and resolution. Apply the retention requirements relevant to the record and preserve material required for a lawful investigation; this policy does not set a universal financial-record retention period.

Use our Speak Up & Whistleblower Policy if management involvement is a concern or another reporting route is needed. Honest reports are protected against retaliation. Management must assign responsibility for applying this policy, give relevant staff guidance and review concerns, changes in activity and corrective measures. Breaches are subject to fair review and appropriate action under applicable law.

1. Independent decisions

This policy applies to LT Marine Offshore Services, Inc. directors, employees and representatives involved in sales, purchasing, recruitment, partnerships or commercial discussions. Philippine competition law and any other applicable competition rules must be considered in the markets affected by our activities.

Set our own service proposals, fees, capacity and business strategy using lawful information. An informal understanding, social-media exchange or discussion at an industry event can create a competition concern even without a signed agreement. Management must arrange appropriate advice where a proposed transaction or collaboration raises uncertainty.

2. Prohibited coordination

Do not agree with a competitor to:

• Set or coordinate service charges, discounts or other commercial terms.
• Submit a deliberately uncompetitive quotation, rotate successful bidders or withdraw a bid so another provider wins.
• Divide principals, fleets, territories or service opportunities between businesses.
• Restrict available services or organise a joint refusal to deal with a customer or supplier.
• Use an intermediary to exchange information or achieve coordination that would be improper directly.

Do not use industry discussions to agree hiring restrictions or coordinate pay with competing employers. This requirement does not restrict lawful trade-union activity or collective bargaining; seek advice on the arrangements and laws that apply.

3. Information and industry meetings

Keep current or future pricing, margins, unpublished bid terms, customer plans and business capacity confidential. Do not request a rival agency's confidential quotation from a shared supplier or a newly hired employee. Publicly available market material may be used lawfully; record its source when the origin could otherwise be unclear.

For a trade-association meeting, review the agenda, keep discussion within its legitimate purpose and avoid sharing sensitive business plans. If an inappropriate subject is raised, object clearly, end your participation in that discussion and make a factual record. Promptly ask management for advice. Do not assume that everyone else's attendance makes the discussion acceptable.

4. Contracts and collaborations

Some arrangements need a competition assessment before a commitment is made, including exclusivity, joint bidding, joint purchasing, information-sharing projects, acquisitions and terms that limit a customer's or supplier's ability to trade with others. Ask management to arrange that assessment. A commercial benefit does not automatically justify a restriction.

Do not exploit market power to exclude competitors unlawfully. The legality of a particular restriction depends on its facts, market effects and applicable rules. This policy does not assume that LT Marine holds a dominant position or that every exclusive agreement is unlawful.

5. Concerns, records and review

If confidential competitor material arrives unexpectedly, stop circulating or using it and obtain management advice on controlled preservation and handling. Never delete, alter or conceal records to avoid scrutiny. Record business decisions accurately and cooperate with lawful enquiries through authorised company representatives.

Raise suspected collusion or pressure to participate through our Speak Up & Whistleblower Policy. Retaliation for an honest concern is prohibited. Management is responsible for explaining these rules to relevant roles, reviewing higher-risk arrangements and taking corrective action. Any disciplinary or contractual response must follow applicable law and fair procedure.

1. Purpose and responsibility

This policy applies to LT Marine Offshore Services, Inc. employees, directors, contractors and service providers entrusted with company information, whether working ashore, remotely or in connection with a vessel. It covers paper files, messages, photographs, portable media, devices and hosted systems, including information received from seafarers, principals and suppliers.

Management must assign responsibility for each business system, assess information risks and arrange appropriate resources and instruction. Managers must report control gaps and track corrective work. Requirements must reflect applicable Philippine privacy law and any other law that applies to the activity.

2. Access and everyday handling

• Use information only for an authorised work purpose and access only the records necessary for your assigned duties. Do not browse a colleague's or applicant's file out of curiosity.
• Use individual accounts; protect passwords and verification codes. Never approve an unexpected sign-in request. System owners must require appropriate authentication, including multi-factor authentication for privileged and remote access.
• Obtain approval before granting access. Review permissions when duties change and remove access promptly when it is no longer required.
• Lock unattended screens, secure paper files and collect printouts promptly. Keep crew documents away from public view when travelling or working aboard.

3. Sharing and working securely

Before sharing a crew list, contract, identity document or medical record, verify the recipient, purpose, authority and minimum information needed. Check attachments and access settings before sending. An urgent request or familiar display name does not prove identity; independently verify requests to change payment details or release sensitive records.

Use approved business systems and protected transfer methods appropriate to the information. Do not copy company records to personal email, public links, unapproved cloud storage or external AI tools. Personal devices require prior approval and suitable protection. Do not disable security controls or install unapproved software.

System owners must arrange risk-appropriate encryption, maintenance, security updates, protected backups and recovery checks. Changes affecting personal information require a privacy and security assessment before release. Suppliers must receive defined instructions and contractual security obligations before access is provided.

4. Retention and proportionate oversight

Keep working copies to a minimum. Follow the retention requirements for the record concerned, including any lawful preservation instruction; dispose of records securely when retention ends. Do not keep downloaded crew documents indefinitely or delete evidence after a problem is reported.

Any security logging or monitoring must have a defined, lawful purpose, appropriate notice, restricted access and a justified retention period. Monitoring must be proportionate and respect individual rights. This policy does not authorise unrestricted surveillance or removal of statutory privacy rights.

5. Report suspected incidents promptly

Report a lost device, misdirected email, suspicious link, exposed file, unexpected access or loss of important records immediately to your manager and Diane Tapia, Data Protection Officer, at dpo@lt-marine.com. Do not wait for proof or attempt an unauthorised investigation. If email may be compromised, use another verified company contact.

Describe what happened, when it was noticed and how you can be contacted. Avoid attaching passwords, full identity documents or unnecessary personal records. Preserve relevant evidence and follow authorised containment instructions. Management and the DPO must arrange assessment, recovery and any legally required notifications within the applicable deadlines.

6. Accountability and related notices

Management must review these requirements and unresolved risks periodically and after material changes or incidents. Breaches may lead to corrective or disciplinary action, subject to fair procedures and applicable law. Honest incident reports and protected disclosures must not result in retaliation.

Read the Privacy Notice for data handling and individual requests, and the Speak Up & Whistleblower Policy for reporting misconduct.

1. Our standard

LT Marine Offshore Services, Inc. prohibits slavery, human trafficking, forced or bonded labour and unlawful child labour. This applies to staff, persons acting for LT Marine and the recruitment and services we arrange. We expect principals, suppliers and recruitment partners to meet the same standard in work connected with us.

A worker must be free to make an informed employment choice. Consent obtained through threats, deception, withheld wages or abuse of vulnerability does not justify exploitation.

2. Fair recruitment and documents

Staff must explain the role, employer, vessel assignment and material contract terms accurately, give the seafarer time to review them and provide the employment agreement required for the assignment. Do not substitute terms through pressure after acceptance or conceal deductions.

LT Marine must not charge seafarer recruitment or placement fees, directly or through a third party. Under the Maritime Labour Convention, limited personal-document costs may be borne by the seafarer: a national statutory medical certificate, national seafarer’s book, and passport or similar personal travel document. Visa costs belong to the shipowner. Apply any Philippine, contractual or other applicable rule that gives the seafarer greater protection.

Never hold identity documents as security for a debt or continued service. Where originals are needed for lawful processing or requested safekeeping, record the purpose, obtain appropriate authority, provide a receipt and keep them accessible for prompt return. Do not demand a recruitment deposit or a loan tied to accepting work.

3. Age and freedom at work

Verify age and eligibility before deployment. Follow the applicable Philippine, flag-state and assignment requirements, including any higher minimum age. The MLC minimum is 16, with additional protection for those under 18, including restrictions on night work and work likely to harm health or safety. A lawful training arrangement must satisfy its specific conditions.

Workers must be able to raise welfare concerns, communicate with their representatives and leave employment through lawful contract procedures. Threats against families, confinement, punitive document retention and blacklisting for reporting abuse are prohibited.

4. Recognising risk and checking partners

Before using a recruitment intermediary or a higher-risk supplier, the responsible manager must consider licensing where required, ownership, recruitment methods and credible reports of abuse. Record concerns and obtain management direction before proceeding.

Warning signs include unexplained cash demands, someone controlling another person’s answers or documents, wages diverted without a clear lawful reason, and workers afraid to discuss their conditions. Do not dismiss a concern because a contract or supplier assurance appears satisfactory.

5. Reporting and protecting people

Report suspected exploitation promptly through dpo@lt-marine.com under our Speak Up & Whistleblower Policy. Explain any immediate safety risk and a safe way to contact you. Email can identify its sender; this is not an anonymous reporting system.

For immediate danger, follow vessel emergency procedures or contact the relevant emergency services. Do not confront a suspected trafficker or put a worker at greater risk. Management must arrange a proportionate review, protect affected people, preserve relevant records and consider specialist assistance, remedy and referral to authorities. No one must suffer retaliation for honestly raising a concern.

6. Accountability and review

Management is responsible for communicating these requirements, assigning relevant guidance and recording corrective action. A supplier problem requires a response based on worker safety and the facts; ending a relationship alone may leave the affected person exposed. Breaches may lead to appropriate employment or contractual action, subject to fair procedures and applicable law. Management must review this policy periodically and when material risks change.

1. Scope and applicable rules

This policy applies to LT Marine Offshore Services, Inc. directors, employees and people acting on its behalf. Business partners are expected to provide information reasonably needed to assess a proposed service and to cooperate with lawful restrictions.

Sanctions can restrict particular persons, entities, vessels, destinations, goods, services or payments. The assessment must identify the rules that actually apply, considering the Philippines, relevant United Nations measures as implemented, and any other applicable jurisdiction. EU, UK or US rules may be relevant because of the parties, location, banking arrangements or other legal connections; they do not all apply identically to every transaction.

2. Understand the proposed relationship

Before accepting a new principal, vessel assignment or material business relationship, the responsible manager must arrange proportionate checks and document their basis. Obtain reliable information about:

• The contracting party, representatives, beneficial ownership and relevant control arrangements.
• The vessel's identity, including its IMO number where applicable, ownership, management and flag.
• The services requested, relevant ports, trading area and any known cargo or activity restrictions.
• The payer, payee, bank details and any third party involved in settlement.

Use current official sources for the relevant regime and check the specific restriction, not just a name search. Ownership and control rules differ between regimes. Resolve possible matches using reliable identifiers; a similar name alone does not establish that someone is restricted.

3. Warning signs and changing circumstances

Escalate missing ownership information, contradictory documents, unexplained payment intermediaries or instructions to conceal the real principal or vessel. In a maritime assignment, unexplained changes of vessel identity, trading arrangements or ownership warrant further enquiries. A legitimate explanation may exist, but uncertainty must be resolved before approval.

Repeat checks when the parties or service change, when new relevant restrictions are announced and before a significant new commitment or payment where the risk warrants it. Retain the date, sources, findings and decision. Do not rely on an old clearance for a different vessel, voyage or counterparty.

4. No evasion or unsupported clearance

Do not misdescribe a service, alter documents, divide payments, route work through another company or remove identifying details to avoid a restriction. A customer's assurance, bank acceptance or contractual clause does not replace our own assessment.

If an applicable prohibition or unresolved risk is identified, pause the proposed activity and refer it to management. Management must obtain qualified advice where needed and document a lawful basis before work resumes. Required authorisations must be obtained from the relevant authority and their conditions followed; an application or business urgency does not itself permit the activity. Suspected frozen funds must not be returned or redirected without appropriate legal direction.

5. Safety, fair treatment and information

Protect life and follow the vessel's emergency procedures. Where sanctions affect emergency assistance, medical care, wages or repatriation, management must urgently seek advice and coordinate with the relevant authorities and responsible parties. Use an exception or licence only where it lawfully applies; this policy creates no automatic exemption.

Decisions must be based on applicable restrictions and relevant facts. Nationality alone must not be treated as proof that a person is prohibited. Collect only information reasonably needed for checks and protect it under our Privacy Notice.

6. Raise concerns and maintain accountability

Send routine business questions to crewing@lt-marine.com. Suspected evasion or pressure to bypass a restriction can be reported to dpo@lt-marine.com under the Speak Up & Whistleblower Policy. Protected reporting to an authority remains available.

Management is responsible for assigning checks, arranging suitable instruction, reviewing this policy and determining any required external reports. Breaches may result in corrective or disciplinary action subject to fair procedures and applicable law. Retaliation for honestly raising a concern is prohibited.

1. Where this policy applies

This policy applies to people working for or representing LT Marine Offshore Services, Inc. when using official accounts or sharing work-related material through personal accounts, messaging groups, forums or other online services. A private group or disappearing message can still be copied and shared.

Personal opinions must not be presented as company statements. Lawful personal expression, trade-union activity, discussion of working conditions, protected disclosures and communication with regulators remain protected. This policy must not be used to suppress those rights or an honestly raised complaint.

2. Speaking for LT Marine

Only a person authorised by management may publish statements, recruitment advertisements or responses on behalf of LT Marine. The responsible person must check accuracy, permission to use images and logos, and any required principal or vessel approval before publication.

Keep official account access with authorised personnel. Use the security controls approved for the account, protect recovery details and remove access when responsibilities end. Do not share company account passwords in group chats or create an unofficial profile that could be mistaken for an official recruitment channel.

3. Protecting people and information

Do not publish crew lists, passport pages, medical details, payroll records, application documents, private messages or identifying incident details without a specific lawful and authorised reason. Photos and videos of identifiable people require a lawful basis and a clear purpose; consent, where relied upon, must be a real choice. A public location does not remove privacy responsibilities.

Check photographs for screens, badges, documents, location details and other people in the background. Respect intellectual-property rights and vessel restrictions. Do not reveal non-public schedules, cargo information, security arrangements or client negotiations. Never enter confidential work material into an unapproved online tool to create a post.

4. Recruitment and online fraud

Recruitment posts must describe genuine opportunities accurately and direct applications to registration.lt-marine.com. Do not promise a job, visa or deployment before the required assessment and approvals, or ask applicants to post documents or government numbers in public comments.

Verify an account or unexpected request through a published LT Marine contact. Do not request passwords or one-time login codes from candidates. Suspected impersonation, payment scams or compromised accounts must be reported promptly; preserve the relevant link or screenshot without spreading the private information further.

5. Respect, safety and corrections

Threats, discriminatory abuse, sexual harassment, doxxing and deliberate impersonation are prohibited in work-related online activity. Treat applicants and colleagues professionally. Do not film or use a phone in a way that distracts from safety-critical duties or breaches shipboard rules.

If an official post is inaccurate, notify its responsible manager promptly so the error can be corrected. For an incident or media enquiry, refer requests for a company statement to management through crewing@lt-marine.com. Preserve evidence relevant to a complaint, legal hold or investigation before making changes; do not organise the destruction of records.

6. Concerns and fair application

Report privacy concerns to dpo@lt-marine.com; misconduct can be raised under our Speak Up & Whistleblower Policy. Tell us if continued online contact feels unsafe. Use platform reporting and blocking tools where appropriate.

Any investigation or monitoring must have a lawful purpose, be proportionate and respect the applicable privacy notice. Staff must not demand personal account passwords. Management must assess alleged breaches fairly and apply any employment or contractual action under applicable procedures. Management must communicate this policy and review it when online practices or risks change.

1. Purpose and responsibility

LT Marine Offshore Services, Inc. expects responsible conduct from staff and persons acting on its behalf. Managers must consider how recruitment, deployment, purchasing and office activities affect people and the environment, and address risks within the company’s role and control.

This policy sets expectations for our work and business partners. It must be read with our Quality, Modern Slavery, Anti-Corruption and Speak Up policies and with the employment terms and laws applicable to an assignment.

2. Fair opportunities and treatment

Recruitment and work decisions must use relevant qualifications, competence, experience and lawful assignment requirements. Do not use irrelevant personal characteristics, family connections or payment offers to favour or exclude a candidate. Where a role has a genuine legal or safety requirement, explain and apply it consistently.

Respect dignity at work. Bullying, harassment, discriminatory treatment and retaliation are prohibited. Staff must give people a fair opportunity to raise an issue, seek assistance and participate in a review. Respect lawful representation, freedom of association and collective bargaining. Do not use complaint records to create an exclusion list.

3. Seafarer welfare and safe assignments

The responsible crewing team must explain material employment terms and the routes for raising welfare concerns before deployment. Check qualifications and required documents, communicate joining arrangements and escalate unresolved concerns about suitability, working conditions or support.

Respect applicable standards for pay, rest, medical support and repatriation, and the responsibilities of the shipowner and other parties. Do not hide a serious concern to meet a joining deadline. Record welfare requests, the person assigned to follow up and the action taken, while limiting access to personal information.

LT Marine’s 24/7 Hotline: +63 919 003 3093 is available for operational and welfare support. Immediate danger requires the vessel’s emergency procedure or relevant emergency services. A hotline call does not replace an onboard safety report or formal claim where one is required.

4. Safety and environmental care

Follow the safety procedures and authority arrangements for the workplace or vessel. Report unsafe conditions and near misses promptly. If an activity appears unsafe, pause where safe to do so, alert the responsible supervisor and follow the applicable stop-work and emergency procedures.

Office teams must avoid unnecessary printing, use energy and materials responsibly, and send electronic equipment and hazardous waste through appropriate disposal routes. When arranging travel or purchasing, consider practical ways to reduce waste and unnecessary journeys without compromising safety or the worker’s rights.

5. Suppliers and community support

Staff selecting suppliers must consider relevant labour, safety and environmental risks as well as price and service. Raise credible evidence of exploitation, unsafe practices or corruption rather than treating a low price as sufficient justification to proceed.

Any company donation or community activity requires management authorisation, a clear purpose, recipient checks proportionate to the risk and an accurate record. Do not use a donation to secure business, influence an official or pressure staff to contribute. Participation in voluntary activities must not determine a person’s work opportunities.

6. Concerns and improvement

Service feedback may be sent through our Feedback & Complaints channel. Suspected misconduct can be raised through dpo@lt-marine.com under our Speak Up & Whistleblower Policy. Honest reports must be handled without retaliation and with access limited to those who need it.

Management must assign responsibility for this policy, consider patterns in complaints and welfare cases, and record proportionate improvement actions with owners and target dates. Review progress and outstanding actions periodically. Public statements about results, partnerships or environmental performance must be supported by evidence; do not claim a certification or achievement that has not been verified.

1. Who is responsible

LT Marine Offshore Services, Inc. (LT Marine) is the personal information controller for the website-related activities described in this notice.

Office: 4/F Five E-Com Center Building, Palm Coast Avenue corner Pacific Drive, Mall of Asia Complex, Pasay City, Philippines.
Data Protection Officer: Diane Tapia.
Privacy email: dpo@lt-marine.com.

You may address a written request to the Data Protection Officer at our office. This notice explains the public website and related enquiries, feedback and misconduct reports. Registration and seafarer services have existing collection-specific notices; see section 3.

2. Information we receive

• Website requests: the hosting and network services receive technical information needed to deliver a page, such as an IP address, request time, requested address, browser information and a referring page when your browser supplies it. Security and diagnostic logs may record that information.
• Messages you send: your name, email address, organisation, role, enquiry or concern, and other information you choose to include. Email links open your email application; this public website does not itself submit a contact form or upload documents.
• Feedback and reports: relevant service or vessel references, dates, people involved, correspondence and information needed to review the concern. Information may also come from the organisation or person raising a concern about you.

Please send only information needed for your request. Keep passport and government numbers, medical records, banking information and unnecessary information about other people out of an initial email. Ask us to arrange an appropriate exchange method if sensitive documents are needed.

Providing an enquiry is voluntary. Without sufficient contact or case information, we may be unable to answer or investigate it. Visiting the public website does not require creating an account.

3. Recruitment and crew portals

Applications and crew accounts are handled in separate systems. These may collect CVs, qualifications, sea-service history, identity documents and, at later stages where needed, employment, medical, beneficiary, payroll and deployment information.

• Registration portal privacy notice
• Seafarer portal privacy notice

For privacy requests about applications and crew records, contact Diane Tapia, Data Protection Officer, at dpo@lt-marine.com. The Privacy Rights Request Guide explains how to make a request.

Read the notice displayed at the point of collection before providing information. A request to read or acknowledge a privacy notice does not, on its own, provide consent for every use of personal data. Where consent is required, it must relate to the specific processing explained to you.

Microsoft Azure in Central India hosts LT Marine's registration and crew records. This location is outside the Philippines and the European Economic Area (EEA). LT Marine remains accountable for the personal data it controls. See section 6 for international processing and section 8 for privacy requests.

4. Purposes and legal grounds

These grounds concern ordinary personal data. Sensitive personal information under Philippine law, special-category data under the GDPR and criminal-offence information require their own applicable legal conditions and safeguards. A general contractual or legitimate-interest ground does not automatically authorise those categories. Collection-specific information must explain the relevant condition when that processing is necessary.

We do not treat browsing this website or agreeing to a privacy notice as blanket consent. If a particular activity depends on consent, you may withdraw that consent without affecting the lawfulness of processing before withdrawal. Separate grounds may still require retention or other processing.

5. Who may receive information

Access is limited to the people and recipients needed for the relevant purpose. Depending on the matter, these can include authorised LT Marine personnel; providers of website hosting, security, email and other necessary IT services; professional advisers; people whose input is necessary for a fair review; and authorities where disclosure is lawfully required.

The public website is delivered through Vercel infrastructure. The separate registration and crew systems use Microsoft Azure. A principal or another organisation may act as a separate controller for information it receives; read the relevant portal notice for recruitment-related sharing and section 3 for the current privacy contact.

For misconduct reports, we aim to restrict identifying information to those who need it. Absolute confidentiality cannot be guaranteed where disclosure is needed for a fair investigation or a legal obligation. Read our Speak Up & Whistleblower Policy for the reporting arrangements.

6. International processing

LT Marine operates in the Philippines and works with overseas principals and service providers. Website delivery and communications may involve infrastructure in other countries; registration and crew records are hosted in Microsoft Azure Central India.

Where the GDPR applies and a disclosure constitutes a restricted international transfer, the applicable transfer requirements must be met. Depending on the destination and circumstances, these can include an adequacy decision or appropriate safeguards such as approved standard contractual clauses and the necessary transfer assessment. An individual's direct submission to LT Marine is not automatically the same as a transfer between two separate organisations.

Transfer arrangements: the Azure hosting location is confirmed. The specific provider contracts, transfer mechanisms and assessments have not yet been verified. This notice does not confirm that an international-transfer safeguard is in place. Hosting in India or processing in the Philippines does not itself provide an EU adequacy basis for a restricted transfer.

To ask about the recipient, destination and safeguards for a particular disclosure, or to request a copy of applicable safeguards subject to lawful redactions, contact dpo@lt-marine.com. Use of this website is not consent to a restricted international transfer.

7. Retention and protection

Our retention policy is to keep personal information only for as long as it is needed for its purpose and applicable legal or documented preservation requirements, then securely delete or anonymise it. The relevant criteria are:

• Routine enquiries: the time needed to answer and follow up the enquiry. Correspondence needed for a contract, complaint or claim is assessed against that continuing purpose and its applicable requirements.
• Feedback and reports: the time needed to review, act on and follow up the matter, together with any continuing legal, claims or corrective-action need. Identifying information should be removed when that need ends.
• Technical logs: the time needed for service delivery, troubleshooting and security, taking account of the service, its configuration and any documented incident or legal hold. Provider-managed logs can have different periods.
• Recruitment and employment. See the Applicant & Crew Records Retention Policy for the period or criteria that apply to device drafts, applications, employment records and backup copies.

Record-specific periods depend on the record and the requirement that applies to it. You may ask the DPO about the period or criteria for your records. Restricted backup copies may remain until their ordinary secure replacement cycle; a deletion request must also be considered in backup-restoration procedures.

The exact provider-managed logging and backup periods have not yet been confirmed. This notice does not promise automatic deletion after a fixed period or change the deletion behaviour of Vercel, Cloudflare, email or Azure services. Contact the DPO for the retention information relevant to your request.

We use organisational, physical and technical safeguards appropriate to the processing and its risks. No website or email service can guarantee absolute security. The public website does not make decisions with legal or similarly significant effects about you through automated profiling; recruitment processing requires its own assessment and notice.

8. Your rights and requests

Your rights depend on the law and the circumstances. Under Philippine law these can include information, access, objection, correction, blocking or erasure, data portability and compensation where available. Where the GDPR applies, rights can also include restriction, portability and objection to processing based on legitimate interests; deletion and portability are subject to their legal conditions.

Email dpo@lt-marine.com with the records or service concerned and the action you seek. A particular form is not required. We may request proportionate information to verify your identity or authority, but please do not send an identity-document copy unless we explain why it is needed and how to provide it safely. Rights requests are ordinarily free; any lawful exception will be explained.

We will respond without undue delay within the applicable legal period. For GDPR requests this is normally one month after receipt. Where an extension is permitted because of complexity or the number of requests, we will explain it within the first month; the extension can be up to two further months. Philippine requests are handled under applicable NPC rules and guidance.

Some records must be retained to comply with law or protect the rights of others. If we cannot grant a request, we will explain the reason and the available complaint route. If you need assistance submitting a request, contact the DPO.

You may complain to the Philippine National Privacy Commission. Where GDPR rights apply, you may also complain to the competent EEA supervisory authority, including in the country of your habitual residence, work or alleged infringement. You do not have to give up those rights to use a company complaint channel.

9. Cookies, links and updates

Read the Cookie Policy for the public website and the separate storage identified on registration and login services. Our updated public website loads its fonts from its own files and contains no analytics or advertising code.

Maps and social-media destinations are ordinary links. When you open one, its operator receives your request and its own practices apply. A link to an LT Marine portal does not remove LT Marine's responsibility for the information it controls there.

We will revise this notice when relevant practices change. The date above identifies this version. Significant new purposes or consent-dependent uses require appropriate notice and, where necessary, a fresh choice before that processing begins. The notice is information about data handling, not a waiver of privacy rights.

1. Tell us what you need

Identify the service or record involved and what you want us to do. The email address you used to apply, an approximate application date or a case reference can help us find it. Tell us how we can reply safely.

• Access or correction. For example, “I applied for a deck position in June. Please send me a copy of my application” or “My recorded sea-service dates are incorrect. How can I update them?”
• Future vacancies or deletion. You can say, “Please stop considering my closed application for future openings and tell me which records you can delete.” Tell us separately if you also intend to withdraw an active application.
• Other uses. You can ask who received your data and why, object to a use, ask about restriction, blocking or portability, or withdraw a particular consent. The rights and exceptions that apply depend on the processing and the applicable law.

2. Verify the request safely

Leave passport scans, medical details, bank information and passwords out of your first message. Diane may need additional evidence to confirm your identity before disclosing or changing records. She should explain what is necessary and how to provide it securely.

If you act for someone else, state your relationship and the action they authorised. We may need specific proof of authority and identity. A family relationship alone may be insufficient to disclose a seafarer's file.

3. What happens next

We will identify the records, assess the request under the applicable law and explain the action taken. If a record must be retained for a legal duty or claim, we will explain the applicable limit and what can still be done. Requests are generally free. Any permitted charge must be explained.

For Philippine requests, NPC guidance requires action without undue delay and within 30 working days after receipt of the request and any necessary supporting information. For complex or numerous requests, an extension of up to 15 working days can apply with an explanation. Where the GDPR applies, the usual response period is one month from receipt. A permitted extension of up to two further months requires notice and reasons within the first month.

4. Follow up or complain

Reply to the correspondence or email dpo@lt-marine.com with the date and reference of your request. If you disagree with the response, explain what is outstanding and ask Diane to review it.

You may seek assistance or lodge a complaint with the Philippine National Privacy Commission under its complaint procedure. Where the GDPR applies, you may contact the competent EEA supervisory authority, including in the place of your habitual residence, work or the alleged infringement.

Read our Privacy Notice for the purposes and recipients of processing and the Applicant & Crew Records Retention Policy for retention by record type.

1. Unsubmitted drafts on your device

The public registration form currently saves an unfinished draft in the browser as you edit. It checks the age of the draft when you return and discards it if more than two days old. An abandoned draft can remain on the device until the next check or until you clear the site's browser data.

Use “Start a new registration” or clear site data for the registration domain to remove a local draft. Successful submission also clears the local draft. A submitted application is held separately by LT Marine. To request deletion of that record, contact the DPO. The Cookie Policy explains the browser storage used by each site.

2. Active and closed applications

The registration portal keeps an application while the office considers it. For an applicant who is not hired, its published rule is 12 months from closure, including a withdrawal or a file kept for a later opening. If the office reopens the file during that period, the period starts again on the next closure.

The registration privacy notice says the application, submitted documents and office notes are due for deletion at the end of that period. You can ask to end future-vacancy consideration earlier. Diane can check the status and closure date of your own record and confirm the outcome of a deletion request.

3. Current and former crew records

During employment, the purpose and type of record govern retention. Employment agreements and sea-service records may be needed to document an assignment. Pay and contribution records, medical fitness documents and information about an injury or claim each require a separate assessment of the applicable duty and period.

The crew portal notice currently says former seafarers' records are being retained while the company determines the required periods. The disposal schedule for these records is still under review. Management must establish the purpose, applicable rule, starting event and review or disposal date for each category, and act on records whose justification has expired. You can ask for a review of your individual records now.

4. Claims, backups and secure disposal

If a complaint, claim or legal duty requires particular records to be preserved, management must identify the relevant records, restrict access, record the reason and review the hold. When it ends, reassess the records against their normal retention criteria.

Once retention is no longer justified, responsible teams must securely erase or irreversibly anonymise electronic records and securely destroy paper copies. Where other organisations hold copies, the DPO must consider applicable notification duties and each recipient's role.

Deletion from a live system and replacement of its restricted backup copies can occur at different times. The backup rotation period has yet to be confirmed. Restoration procedures must account for deletions already actioned. For access, correction or deletion, use our Privacy Rights Request Guide.

1. What cookies and browser storage do

Cookies are small records a website asks your browser to store and return with requests. Local storage keeps information on a device for the website that saved it. Session storage, browser caching and comparable technologies can serve different purposes. Privacy and consent requirements depend on what the technology does, not only its name.

This policy distinguishes the public marketing website from the registration and sign-in services. Storage used by a portal does not mean that the marketing page uses the same storage.

2. The public marketing website

The public website at lt-marine.com / www.lt-marine.com has no analytics tags, advertising pixels, embedded social widgets or embedded maps. Its fonts, images and icons are served with the website. There are no optional analytics or advertising categories to turn on in this version.

The privacy popup offers a necessary-only choice and cookie settings. It saves only the preference record described below, after you choose to save. Closing the popup without saving does not record agreement. This acknowledgement is not consent to recruitment, medical-data processing or every purpose in a privacy notice.

The browser can cache requested website files for performance. The hosting or network service still receives technical request information, even when it sets no cookie. Infrastructure security protections may vary by request; any necessary security storage must be assessed against its actual purpose.

You can reopen settings using Cookie settings in the footer. If optional tracking is introduced, it must first be documented and, where required, blocked until you make a valid purpose-specific choice. Refusing optional tracking must not prevent ordinary access to the public information.

3. Identified registration and login storage

The draft excludes several sensitive fields and does not store the bytes of uploaded files, but it can still contain names, contact details, work and education history and file names. The current registration portal has no opt-in or off switch for this automatic draft saving. The available current controls are starting a new registration and clearing browser site data. An optional draft-saving choice must be implemented in the portal before relying on it for EU consent requirements.

The “Remember my email” option on the seafarer sign-in page is a separate browser preference. Consult that service before enabling it on a shared device; this public-site inventory does not establish its implementation or lifetime.

This inventory reflects an unauthenticated public source and response review on 29 October 2026. It does not describe all storage after sign-in, a security challenge or a change to service configuration. Registration and crew processing must also be explained in their own privacy notices.

4. Providers and external destinations

Vercel delivers the public marketing site. Microsoft Azure Central India hosts the registration and crew records. Cloudflare provides network/security services for the reviewed registration and seafarer domains. Necessary service delivery can involve request logs independently of cookies.

The reviewed portal pages load Google Fonts from Google, which receives the browser request. The public marketing update serves fonts locally; that change does not update the separately hosted portals. The registration response also advertises Cloudflare network-error reporting. These processing activities belong in the relevant provider inventory and privacy assessment.

Opening a map, social page or another external link lets the destination apply its own storage practices. We do not embed those third-party services in this public website.

5. Your choices

You can inspect and remove cookies and site data in your browser's privacy or site-data settings. Remove data for the relevant hostname: clearing the marketing website does not necessarily clear registration or login storage. Removing a session cookie can sign you out or interrupt an unfinished form.

For this public website, open Cookie settings in the footer to review or forget the saved necessary-only choice. If browser storage is blocked, the choice applies for the current visit and the notice may appear again later. This local preference is not a server-side recruitment-consent record.

For a registration draft, “Start a new registration” clears the saved draft as currently implemented; browser site-data settings can also remove it. Keep your own safe copy of information you still need. Local-storage controls and expiry must be enforced within the registration portal itself.

The automatic registration-draft feature already requires review and an appropriate user choice; it is not fixed by this marketing-site policy. Optional storage controls must be enforced by the service that writes it. If analytics or advertising is later added, provide clear purpose-based settings, optional categories off by default, an accessible refusal option, and a continuing way to withdraw consent. A privacy-notice link or continued browsing does not substitute for required consent.

6. Questions and changes

For storage or privacy questions, contact Diane Tapia, Data Protection Officer, at dpo@lt-marine.com, or write to LT Marine Offshore Services, Inc., 4/F Five E-Com Center Building, Palm Coast Avenue corner Pacific Drive, Mall of Asia Complex, Pasay City, Philippines.

See the Privacy Notice for rights and complaints. We will update this policy when the site's technologies or their purposes change.

1. About this website

This website is operated by LT Marine Offshore Services, Inc., 4/F Five E-Com Center Building, Palm Coast Avenue corner Pacific Drive, Mall of Asia Complex, Pasay City, Philippines. It provides information about our business, services, vacancies and contact channels. Questions about the website can be sent to crewing@lt-marine.com.

These terms concern use of the public information website. An employment contract, seafarer employment agreement, collective agreement, principal agreement or portal-specific terms govern the services they cover. Mandatory legal rights continue to apply.

2. Recruitment and service information

A vacancy, enquiry, application or account does not guarantee an interview, employment, deployment, a particular vessel or a contract. Requirements and availability can change. Confirm the current details with authorised LT Marine personnel and read the relevant contract before accepting an engagement.

Applications should use the official registration portal. Verify an unexpected recruitment message or request for money through a published company contact before acting. Do not send sensitive documents to an unverified recipient.

3. Responsible use and content

You may read, link to and make reasonable personal or business-reference use of public pages. LT Marine's logos and original website materials remain protected by applicable intellectual-property law. Reproduction or commercial use beyond lawful exceptions requires the relevant permission.

Do not impersonate someone else, submit information you know is false, attempt unauthorised access, disrupt the service, or upload unlawful or harmful material. Do not obtain or share another person's private records through this website.

4. Accuracy and external services

We aim to keep website information accurate and current. Please ask us to confirm information on which you intend to rely for a contract, deployment or regulatory decision. We may correct content or maintain the website as needed.

Links can lead to separate services and external organisations. Read the terms and notices applicable to the destination. LT Marine remains responsible for its own conduct and processing; an external link is not a guarantee of another organisation's content.

Nothing in these terms excludes liability or removes rights that cannot lawfully be excluded, including applicable worker, consumer and data-protection rights.

5. Privacy and raising concerns

The Privacy Notice and Cookie Policy explain information handling and storage. They provide information; these terms do not create blanket consent to personal-data processing.

For a service concern, use Feedback & Complaints. For suspected wrongdoing, use the Speak Up & Whistleblower Policy. You may also approach an appropriate authority or seek advice without first completing a company process.

Applicable law and mandatory rights determine the available remedies and competent forums. These terms do not require you to waive access to a regulator, a court or another remedy available under applicable law.