Competition Law Policy

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Keep current or future pricing, margins, unpublished bid terms, customer plans and business capacity confidential.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.