Speak Up & Whistleblower Policy

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.