Anti-Corruption Policy

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.