• Conducting all aspects of its business with honesty and integrity and to provide a working environment where high standards of ethical, moral and legal business conduct are encouraged and
• Providing a workplace characterized by open communication regarding its business

This Policy has been issued in accordance with the terms and conditions of Law 4990/2022, which transposed EU Directive 2019/1937 on the protection of persons who report breaches of EU law into Greek Law. This Policy provides a means for inter alia employees(including home workers, seafarers, self-employed persons, consultants, contractors, persons belonging in the administrative, management or supervisory bodies of MINERVA MARINE Inc. and MINERVA DRY Inc., including non-executive members, as well as volunteers and trainees to raise concerns that cannot be, or have not been, adequately addressed via usual reporting channels, without fear of retaliation or discrimination over such reports made in good faith, including, but not limited to, the following:

• Potential or actual infringement/ breach relating to the protection of privacy and personal data, and the security of network and information systems
• A criminal offence
• Non-compliance with legislation or Company’s procedures, particularly in relation to health

and safety at work or environmental protection

• Dishonesty, either verbal or written (including intentionally maintaining official log books or records inaccurately)
• Malpractice or unethical conduct
• Harassment or bullying
• Financial or non-financial misadministration or malpractice or impropriety or fraud
• A safety or security risk or hazardous condition that may impact the life or health of individuals on board the vessel
• Miscarriages of justice
• The deliberate concealment of any of the

If an employee has a legitimate concern in (holding reasonable belief that the information he has relates to) one of the above areas and wishes to raise it in good faith, he must raise it with the Master, DPA or other Company’s representative who may help resolve the concern quickly and effectively.

Although the Company’s Top Management maintains an open reporting policy, endeavouring to address individuals’ concerns internally, a concern can also be raised by submitting a report to the independent third-party contractor handling such reports. Details for filing a report can be found in Company’s website under the section “OPEN REPORTING LINE”.

Reports can be made without fear of retaliation and even be anonymous. Upon receipt of a report, same will be assessed by the Company Management  and an investigation may commence, if deemed necessary, as per applicable law’s requirements. Any victimization of a member of staff who makes a report, or any attempt to deter him from reporting, will be regarded serious disciplinary offense resulting in action under the Disciplinary Procedures.