FEDNAV CODE OF BUSINESS CONDUCT AND ETHICS


Fednav is committed to doing what's right. Fednav acts, and expects others to act, with honesty and integrity when dealing with our fellow colleagues, customers, service providers, and business partners. Where the right course of action is not evident, Fednav's Code of Business Conduct and Ethics serves as a basis for the expectations which apply to all employees, officers, and directors.

Compliance with Laws
Fednav will, at a minimum, conducts its business and affairs in compliance with all laws, rules, and regulations, and in accordance with the Company's high ethical standards.

Bribery, Corruption and Facilitation Payments
Fednav does not allow taking, offering, providing, or promising any bribe or unlawful facilitation payment, regardless of the value.

Trade Influence and Competition
Fednav deals fairly with its customers, suppliers, competitors, officers, and employees; and does not take unfair advantage of any other party through fraud, manipulation, concealment, abuse of privileged information, misrepresentation, or omission of material facts or any other unfair practices. Fednav conducts its business and affairs in compliance with all applicable competition legislation.

Money Laundering
Fednav conducts its business and affairs in compliance with all applicable anti-money laundering legislation.

Conflicts of Interest
Employees, officers, and directors avoid situations in which their personal interests or actions conflict with, or appear to conflict with, the interests of Fednav.

Business Gifts and Hospitality
Fednav prohibits the giving or receiving of gifts or hospitality with the intention of influencing business decisions, judgements, or outcomes. Reasonable gifts and hospitality are provided and
accepted only in the interest of maintaining genuine business relationships.

Discrimination and Harassment
Fednav respects the right to be treated with dignity, courtesy, and respect in an environment free from harassment or discrimination. Fednav has zero tolerance for harassment or discrimination in any form.

Reporting Illegal or Unethical Behaviour
Fednav encourages its directors, officers, and employees to speak up and report concerns about any illegal, fraudulent, corrupt, or unethical behaviour or any other breach of its Code of Business Conduct and Ethics. Third parties are also encouraged to report any such concerns by contacting [email protected]. Alternatively, such reports may be submitted anonymously by using the Whistleblower system.

Fednav will treat all concerns seriously and will follow up conscientiously, discreetly, and without bias, which may include carrying out an investigation. Fednav does not tolerate any form of retaliation against those who report concerns in good faith.