OPEN REPORTING LINE

Introduction

As a means of accountability and transparency and in full compliance with the requirements of the Law 4990/2022 as same may be amended (the “Law”), which transposed EU Directive 2019/1937 into Greek Law, the Companies have introduced this Program to enable all individuals to voice concerns internally in a responsible and effective manner when they discover information which they believe indicates malpractice and/or breaches of EU law.

Individuals who are faced with a difficult ethical situation/dilemma and feel uncomfortable about raising the matter through the Companies’ normal reporting process, will be able to address it through this procedure.

Our Open Reporting Line is fundamental to the Companies’ professional integrity. In addition, it reinforces the value the Companies’ places on personnel to be honest and transparent. It provides a method of properly addressing, in good faith, concerns that individuals might have, while also offering open reporters protection from victimization, harassment or disciplinary proceedings and any form of retaliation.

What is Open Reporting?

Open Reporting is the confidential disclosure by an individual (the open reporter) of any concern relating to a risk, malpractice or perceived wrongdoing that affects others (such as clients, suppliers, the Companies, other employees or the public interest). The Companies consider such wrongdoing to include without limitation:

• Bribery or money laundering;
• Financial or non-financial misadministration or malpractice or impropriety or fraud;
• General malpractice – such as immoral, illegal or unethical conduct; (including instances where someone’s health, property and/or safety has been put in danger)
• Gross misconduct;
• Potential infringement / breach of the Companies’ policies;
• Potential infringement / breach of the Companies’ Code of Conduct.
• Potential or actual infringement/ breach on protection of privacy and personal data, and security of network and information systems.

Who does this procedure apply to?

This procedure applies to everyone who carries out work for and everyone who does business with the Companies including without limitation:

All employees including home workers;

Self-employed persons;

Persons belonging in the administrative, management or supervisory bodies of the Companies, including non-executive members;

Volunteers and trainees;

All seafarers serving on board vessels managed by the Companies;

Contractors and sub-contractors;

Agencies;

Partners;

Consultants.

What are the fundamental elements of this program?

All individuals who raise a concern are protected from victimization, harassment or disciplinary action and any form of retaliation as a result of such disclosure. All information will be carefully investigated and interviews with all witnesses and other parties involved will take place.

Open Reporters might wish either to identify themselves or to remain anonymous. In both cases, the open reporters will be protected at all stages. However, the Companies are not accountable for maintaining anonymity in case the open reporters has told others of the alleged wrongdoing.

Possible outcome after reporting a concern

Anyone who reports a concern shall be protected and all relevant information disclosed will remain confidential;

The following actions may be taken after investigation of the alleged wrongdoing;

• Disciplinary action (up to and including dismissal) against the wrongdoer depending on the results of the investigation; or;
• No action if the allegation proves unfounded.

The open reporter will be kept informed of the progress and the outcome of the investigation, within the constraints of confidentiality.

Reporting methods

Open Reporting Line’s reports are confidential. If the reporter wishes to remain anonymous he may do so. The Companies has selected a specialized and independent third party companies to handle the reports and to ensure the highest level of security and confidentiality.

To Make a Report for Minerva Marine Inc. and the Vessels managed by Minerva Marine Inc. click HERE and follow the instructions.

To Make a Report for Minerva Dry Inc. and the Vessels managed by Minerva Dry Inc. click HERE and follow the instructions.