Anti-Bribery Policy

1. Our Commitment

ID Shipping Agency maintains a strict zero-tolerance approach to bribery, corruption, and improper payments in all its maritime operations.

We conduct our business with integrity, transparency, and full compliance with applicable anti-corruption laws in every jurisdiction where we operate.

We do not tolerate any form of bribery, whether direct or indirect, in dealings with private entities or public authorities.

2. Scope of Application

This Policy applies to:

• Directors and Senior Management

• Employees and operational staff

• Agents and representatives

• Sub-agents and contractors

• Third-party service providers acting on behalf of the Company

It covers all Company activities, including port agency, shipyard operations, Turkish Straits transit coordination, customs interactions, logistics services, and financial transactions.

3. Prohibited Conduct

ID Shipping Agency strictly prohibits:

• Offering, promising, or giving any improper payment or benefit

• Requesting or accepting any improper advantage

• Facilitation payments intended to expedite official actions

• Indirect bribery through intermediaries

• Any attempt to improperly influence port authorities, customs officials, shipyard personnel, or regulatory bodies

Bribery may include cash, gifts, hospitality, commissions, rebates, or any other benefit intended to secure an improper business advantage.

4. Dealings with Public Officials

Given the nature of maritime operations, interactions with port authorities, customs administrations, harbour masters, and other public officials require heightened scrutiny.

No payment, gift, or benefit may be provided to a public official with the intention of influencing a decision or securing improper advantage.

Where permitted by law, any legitimate and proportionate hospitality must be transparent, reasonable, and properly documented.

5. Third-Party Due Diligence

ID Shipping Agency conducts appropriate due diligence when engaging third parties.

We reserve the right to refuse or terminate relationships where:

• Ownership structures lack transparency

• Unusual payment arrangements are requested

• There is a risk of legal or reputational exposure

The Company may be held responsible for the actions of third parties acting on its behalf. Accordingly, all third-party relationships must align with this Policy.

6. Gifts and Hospitality

Reasonable business hospitality may be acceptable where it:

• Is lawful and customary

• Is modest and proportionate

• Is not intended to influence decision-making

• Is properly recorded

Cash gifts or cash equivalents are strictly prohibited.

7. Financial Transparency and Record Keeping

All Company payments must be:

• Properly authorized

• Accurately recorded

• Supported by legitimate documentation

• Transparent and traceable

False accounting, undisclosed commissions, or off-book transactions are strictly prohibited.

8. Reporting and Non-Retaliation

Employees and business partners are expected to report any suspected violations of this Policy.

ID Shipping Agency ensures that no individual will suffer retaliation for reporting concerns in good faith.

9. Enforcement

Violations of this Policy may result in:

• Disciplinary action

• Termination of employment or contract

• Legal reporting where required

10. Leadership Commitment

Senior Management fully supports and enforces this Policy.

The Company continuously reviews its internal controls and compliance framework to ensure ongoing effectiveness and alignment with international best practices.

Approval

This Anti-Bribery and Corruption Policy is approved and endorsed by Executive Management and applies across all operations of ID Shipping Agency.