Logical Maritime Services Limited having the meaning as set out in the Companies Act, 2019 (Act,992) (“Company”) is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the Company’s behalf is responsible for maintaining the Company’s reputation and for conducting business honestly and professionally.

The Anti Bribery and Corruption Policy sets out the company’s policies and procedures aimed at preventing acts of bribery and corruption and has been designed in compliance with domestic legislation governing bribery and corruption, including:

The Whistle Blower Act,2006 (Act,720)

Anti-Money laundering Act,2008(Act,497) as amended

Income Tax Act,2015(Act,896) as amended

The policy provides guidance on the standard of behaviour to which all Employees must adhere, which standards also reflect common sense and good business practices that must be adopted. It is also designed to help Employees identify prohibited practices so that bribery, corruption and money laundering is avoided. The policy also provides the needed guidance whenever the employees are in doubt as to whether or not an act constitutes bribery and /or corruption.

The Company considers that bribery and corruption has a detrimental impact on business by undermining good governance and distorting free markets.

The Company benefits from carrying out business in a transparent and ethical way. The Company does not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, officers, agents or consultants or any person or companies acting for it or on its behalf. The board and senior management are committed to implementing and enforcing effective systems to prevent and eliminate bribery, in accordance with the Laws on Bribery.

The Company and its subsidiary companies have issued an anti-bribery and corruption policy, together with policies on gifts and corporate hospitality (“Policies”), outlining the Company’s position on preventing and prohibiting bribery and corruption. These Policies apply to all employees and they are required to familiarise themselves and comply with these Policies.

A bribe is a financial advantage or a reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of the Company are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its anti-bribery measures, the Company accepts transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure, whether given or received.

A breach of these Policies by an employee will be treated as grounds for disciplinary action. Employees and other individuals acting for the Company should note that bribery is a criminal offence that may result in up to 10 years imprisonment and/or an unlimited fine for the individual and an unlimited fine for the Company.

The Company has a policy of not conducting business with service providers, agents or representatives that do not support appropriate anti-bribery and corruption objectives.

The success of the Company’s anti-bribery and corruption measures depends on all employees, and those acting for the Company, playing their part in helping prevent bribery. Therefore, all employees and others acting for, or on behalf of, the Company are encouraged to report any suspected bribery in accordance with the procedures set out in the Policies or in the case of third parties to the Company Secretary. The Company will support any individuals who make such a report in good faith.


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