Anti-Corruption Policy for Marco Marine Companies

This Anti-Corruption Policy for Marco Marine Companies (“Policy”) prohibits corruption of all officials (clients, vendors, partners, all Marco Marine business relations.), which means paying money or giving something of value to an official to obtain an improper benefit. This Policy similarly prohibits the payment of bribes or kickbacks in commercial transactions that do not involve officials. Corruption is prohibited by the laws in almost every jurisdiction of the world. This Policy also prohibits money laundering, which is the process of concealing funds that have been illegally obtained.

Marco Marine Companies, and all of its subsidiaries and joint ventures worldwide (MMD), requires its channel partners (for example, resellers, advisors, original equipment manufacturers, and distributors), consultants, lobbyists, and other third-party representatives (collectively, MMD Representatives) to comply with this Policy. MMD Representatives acting on behalf of Marco Marine Companies can expose MMD to liability under anti-corruption and anti–money-laundering laws, including the United States Foreign Corrupt Practices Act (“FCPA”). Further, corruption promotes poverty, hunger, disease, and crime, and it keeps societies and individuals from reaching their full potential. Corruption is one of the leading obstacles to economic and social development. MMD is committed to observing the standards of conduct set forth in the FCPA and the anti-corruption and anti–money-laundering laws of the countries/regions in which it operates. MMD is also committed to taking reasonable steps to ensure that MMD Representatives comply with these standards of conduct and laws in its dealings with or on behalf of MMD.

Compliance with Anti-Corruption Laws

Each MMD Representative will comply with all applicable anti-corruption laws, including the FCPA. No MMD Representative shall, directly or indirectly, offer or pay anything of value (including gifts, travel, entertainment expenses, and charitable donations) to any official or employee of any government, government agency, political party, or public international organization, or any candidate for political office, to (i) improperly influence any act or decision of such official, employee, or candidate for the purpose of promoting the business interests of MMD in any respect, or (ii) otherwise improperly promote the business interests of MMD in any respect.

Vetting of MMD Representatives

MMD will conduct a due diligence or “vetting” of each MMD Representative to determine that its relationship with the representative does not pose a risk to MMD of noncompliance with this Policy. As part of this process, MMD will ask the MMD Representative to respond to a questionnaire and, if appropriate, provide additional information that may be necessary in the reasonable judgment of MMD. MMD appreciates the understanding and cooperation of each MMD Representative in this regard.

Anti–Money Laundering

No MMD Representative shall use its relationship with MMD to attempt to disguise the sources of illegally obtained funds.

No Retaliation

MMD Representatives will not retaliate against anyone who has, in good faith, reported a possible violation of this Policy, or refused to participate in activities that violate this Policy.

Enforcement

MMD will enforce this Policy in accordance with the terms of its contracts with MMD Representatives.

 

Espergaerde

February 1st 2014

 

Poul Rasmussen Managing Director