Anti-Harassment, Bullying & Dignity at Work Policy

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.