Code of Ethics

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

1. Introduction and Purpose

Seachios® Marine Services, a multinational leader in maritime solutions headquartered in Brazil and strategically established with partnerships in Uruguay, Argentina, and Panama, issues this Code of Ethics as a binding framework for ethical, professional, and responsible conduct across all operations.

This Code of Ethics aims to:

• Establish clear standards of ethical behavior and transparent decision-making.

• Foster a corporate culture based on integrity, accountability, and respect.

• Ensure compliance with national and international legal frameworks, including environmental, labor, data protection, and anti-corruption standards.

• Serve as a reference for employees, executives, contractors, suppliers, agents, and partners, ensuring that all activities conducted under the Seachios name reflect our values and commitments.

This Code is an integral pillar of our Corporate Governance and Integrity Framework.

2. Core Corporate Values

Our ethical and operational philosophy is anchored in the following principles:

• Integrity: Conducting business with honesty, transparency, and consistency.

• Accountability: Taking full responsibility for our decisions and their social, economic, and environmental impact.

• Excellence: Striving for the highest standards in maritime service delivery and stakeholder relations.

• Sustainability: Integrating sustainable practices into operations, in compliance with international environmental protocols.

• Respect: Ensuring fairness, dignity, and inclusiveness in all professional interactions.

3. Ethical Principles and Standards of Conduct

3.1 Compliance with Laws and Regulations

• National Compliance: Strict adherence to the Brazilian Civil Code, Uruguayan Commercial Law, Argentine Commercial and Maritime Codes, Panamanian Corporate Law, and other applicable domestic frameworks.

• International Compliance: Alignment with MARPOL, SOLAS, ISM Code, IMO standards, ILO Maritime Labour Convention, and OECD guidelines.

3.2 Anti-Corruption and Anti-Bribery

• Zero Tolerance: No bribery, corruption, facilitation payments, or undue influence.

• Compliance Frameworks: Adherence to the Brazilian Clean Company Act, U.S. FCPA, UK Bribery Act 2010, OECD Anti-Bribery Convention, and UNCAC.

• Mandatory Reporting: All employees and stakeholders must immediately report suspected violations.

3.3 Environmental Responsibility

• MARPOL and ISO 14001 Compliance: Integrating environmental stewardship into all operations.

• Pollution Prevention: Adoption of advanced waste management, emissions control, and ballast water treatment systems.

• Sustainability Commitment: Reducing environmental footprint across global operations.

3.4 Fair Labor Practices and Human Rights

• Equal Opportunity: Commitment to diversity, inclusion, and a workplace free of discrimination or harassment.

• ILO Maritime Labour Convention: Full compliance with labor rights and seafarer welfare standards.

• Human Rights: Respect for communities impacted by our operations.

3.5 Confidentiality and Data Protection

• Data Governance: Compliance with GDPR (EU), LGPD (Brazil), CCPA/CPRA (U.S.), and equivalent laws in Uruguay, Argentina, and Panama.

• Confidentiality Obligation: Safeguarding sensitive operational and client information.

• European Data Infrastructure: Maintenance of robust cybersecurity systems with protection at the highest international level.

3.6 Conflict of Interest

• Avoidance and Disclosure: Employees, directors, and partners must disclose potential conflicts.

• Decision-Making Integrity: Corporate interests must prevail over personal or external influence.

4. Responsibilities of Stakeholders

4.1 Employees

• Understand, internalize, and comply with this Code of Ethics.

• Report promptly any suspected ethical or compliance violation.

• Conduct themselves with professionalism and integrity at all times.

4.2 Leadership and Management

• Lead by example through ethical decision-making.

• Ensure that ethical principles are embedded in strategic and operational decisions.

• Provide training, resources, and enforcement mechanisms to uphold compliance.

4.3 Partners, Suppliers, and Contractors

• Align with Seachios’ ethical standards and contractual obligations.

• Ensure subcontractors and employees comply with the Code.

• Undergo due diligence and monitoring to ensure sustained compliance.

5. Reporting Violations and Whistleblower Protection

5.1 Reporting Channels

• A secure, anonymous, and confidential whistleblowing system is available at: compliance@seachios.gr.

• Reports are processed with independence, urgency, and impartiality.

5.2 Non-Retaliation Policy

• Absolute prohibition of retaliation against good faith whistleblowers.

• Protection guaranteed by corporate policy and applicable laws.

6. Enforcement and Disciplinary Measures

Violations of this Code of Ethics will result in:

• Internal Actions: Written warnings, suspension, or termination of employment/contracts.

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

• Corrective Measures: Adoption of remediation plans to prevent recurrence.

7. Continuous Improvement and Corporate Culture

7.1 Periodic Reviews

This Code is subject to annual review and updates to ensure compliance with evolving laws and best practices.

7.2 Training and Awareness

• Mandatory compliance training for all employees and relevant third parties.

• Targeted programs for high-risk functions such as procurement and government relations.

• Ethics awareness campaigns reinforcing corporate values.

7.3 Cultural Integration

The Code of Ethics is not merely a policy but a corporate culture principle, deeply embedded in Seachios’ operational DNA across Brazil, Uruguay, Argentina, and Panama.

8. Final Commitment

Seachios® Marine Services reaffirms its unwavering dedication to ethical leadership, transparency, compliance, and accountability.

This Code of Ethics stands as a pillar of our governance framework, ensuring that all operations under the Seachios name reflect trust, responsibility, and excellence in the global maritime industry.

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