Anti-Bribery and Anti-Corruption Declaration

Effective Date: January 1, 2025
Last Updated: September 16, 2025

1. Introduction & Corporate Commitment

Seachios® Marine Services, a multinational maritime services provider headquartered in Brazil and strategically established with corporate partnerships in Uruguay, Argentina, and Panama, hereby issues this Anti-Bribery and Anti-Corruption Declaration as a binding corporate instrument.

This declaration affirms our zero-tolerance stance toward bribery, corruption, extortion, facilitation payments, and all unethical practices. It reflects our institutional values of integrity, transparency, accountability, and global compliance, ensuring that all business conducted under our name adheres to the highest international legal and ethical benchmarks.

2. Absolute Zero-Tolerance Policy

Seachios strictly prohibits and condemns all forms of bribery or corruption, including but not limited to:

• Improper Payments & Bribery: No offering, giving, requesting, or receiving of financial or non-financial advantages to secure improper business or governmental decisions.

• Facilitation Payments: Absolute prohibition, regardless of local customs or jurisdiction.

• Kickbacks & Extortion: Zero tolerance for coercive practices or reciprocal payment schemes.

• Conflicts of Interest: Mandatory disclosure and management of any situation where personal interests conflict with corporate duties.

• Gifts & Hospitality: Strictly regulated, ensuring no perception of influence over business outcomes.

This applies universally — to employees, contractors, agents, suppliers, intermediaries, partners, and affiliates across all jurisdictions of operation.

3. Legal and Regulatory Compliance Framework

This declaration enforces compliance with the most stringent anti-corruption laws worldwide, including but not limited to:

• Brazil: Clean Company Act (Law 12.846/2013).

• Uruguay: Law 17.060 on Transparency in Public Functions and Anti-Corruption, and Law 18.381 on Access to Public Information.

• Argentina: Corporate Criminal Liability Law (Law 27.401) and related anti-bribery provisions.

• Panama: Law 59 of 1999 and Law 70 of 2019 on anti-corruption and public sector transparency.

• United States: Foreign Corrupt Practices Act (FCPA).

• United Kingdom: UK Bribery Act 2010.

• OECD Anti-Bribery Convention and UNCAC – United Nations Convention Against Corruption.

By aligning with these frameworks, Seachios not only complies but exceeds minimum legal requirements, setting a corporate standard of excellence in ethical governance.

4. Binding Scope of Application

This declaration applies without exception to:

• Employees, executives, and directors.

• Contractors, subcontractors, consultants.

• Agents, intermediaries, representatives.

• Suppliers, affiliates, and joint venture partners.

No individual or entity conducting business with or on behalf of Seachios is exempt from these obligations.

5. Governance & Enforcement Mechanisms

5.1 Oversight & Corporate Governance

• The Board of Directors and Executive Leadership hold ultimate accountability.

• A dedicated Chief Compliance Officer (CCO) leads our compliance program, supported by regional monitors in Brazil, Uruguay, Argentina, and Panama.

5.2 Policies & Internal Controls

• Financial Oversight: All payments are documented, auditable, and strictly reviewed.

• Third-Party Due Diligence: Comprehensive risk assessments, background checks, and contractual safeguards for all intermediaries.

• Contractual Clauses: Mandatory anti-corruption clauses in agreements with suppliers, contractors, and business partners.

5.3 Whistleblower Protection

• Confidential Channels: Secure and anonymous systems for reporting violations.

• Non-Retaliation: Strong guarantees protecting individuals reporting in good faith.

• Swift Investigations: Independent inquiries with documented outcomes and disciplinary measures.

6. Education & Awareness

Seachios invests in continuous training to embed compliance into its corporate culture:

• Mandatory Training: For employees and third parties upon onboarding and regularly thereafter.

• Specialized Training: For high-risk roles such as procurement, operations, and government relations.

• Cultural Alignment Programs: Reinforcing values of transparency, ethics, and accountability.

7. Enforcement & Disciplinary Actions

Violations of this declaration result in immediate, proportionate, and uncompromising action, including:

• Internal Sanctions: Suspension, dismissal, or termination of contracts.

• External Actions: Referral to authorities for civil or criminal prosecution.

• Business Remedies: Termination of partnerships, supplier contracts, or agency agreements.

8. Monitoring, Auditing & Continuous Improvement

Seachios ensures permanent vigilance and refinement of its anti-bribery program through:

• Independent Audits: Regular internal and third-party audits.

• Risk Assessments: Ongoing evaluations of operational and geopolitical risks.

• Policy Updates: Timely revisions aligned with evolving international standards.

9. Affirmation of Global Ethical Leadership

Seachios® Marine Services affirms that integrity is not negotiable. By upholding absolute transparency and compliance, we safeguard:

• Trust with clients and regulators in Brazil, Uruguay, Argentina, Panama, and beyond.

• Reliability in the global maritime industry.

• Sustainable and ethical growth, built on long-term stakeholder confidence.

10. Contact Information

For inquiries, compliance matters, or reporting violations, please contact:

Compliance Office – Seachios® Marine Services
📧 Email: compliance@seachios.gr
📞 Phone: +55 11 3042-0019
🏢 Address: Rua Visconde de Rio Branco, 67 – Centro, Santos – SP, 11013-030, Brazil

11. Final Declaration

This Anti-Bribery and Anti-Corruption Declaration is issued as a binding corporate commitment by Seachios® Marine Services and its affiliated partners in Brazil, Uruguay, Argentina, and Panama.

It stands as a pillar of corporate governance and ethical leadership, reaffirming our zero-tolerance approach to corruption, our global compliance obligations, and our dedication to operating with integrity and excellence across all maritime and commercial activities.