Sanctions Policy

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 operations@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.