The Company is committed to high standards of ethical, moral and legal business conduct. The Company values input from its employees and expects all its Directors, Officers and Employees to adhere to a high standard of personal and professional integrity and to avoid any conduct that might reflect unfavorably upon the Company’s personnel or upon the Company itself. In line with the Company’s commitment to open communication, the Top Management (the “Management”) of the Company has adopted this whistleblower policy (the “Policy”) to provide an avenue for Employees, Directors, Officers, Contractors, Subcontractors and Agents (the “Employees”) to raise concerns without fear of retaliation for reports made in good faith.
I. Scope
This Policy shall encompass:
• The receipt, retention and treatment of complaints, whether or not in anonymous form, received by the Company regarding accounting, internal accounting controls, auditing matters (the “Accounting Matters”),
• The receipt, retention and treatment of complaints, whether or not in anonymous form, received by the Company relating to vessel operational matters, especially environmental management (the “Environmental Matters”),
• The receipt, retention and treatment of complaints, whether or not in anonymous form, received by the Company relating to, inter alia, breaches of the Company’s Code of Ethics (the “Ethics Matters”).
The Accounting Matters shall include but not be limited to, the following:
• Fraud or deliberate error or omission in the preparation, evaluation, review or audit of any of the Company’s Financial Statements,
• Fraud or deliberate error or omission in the recording and maintaining of the Company’s financial records,
• Deficiencies in or noncompliance with the Company’s internal accounting controls,
• Misrepresentation or false statement to or by a Senior Officer or Accountant regarding a matter contained in the Company’s financial records, Financial Statements or audit reports,
• Deviation from full and fair reporting of the Company’s financial condition.
II. Submission of Complaints
The Employees shall take all appropriate actions to stop any known misconduct by fellow Employees or other Company’s personnel. The Company will continue to encourage Employees in the first instance to address their concerns with their immediate supervisor or point of contact with the organization. Management will also maintain an ‘open door policy’ to address individuals’ complaints for resolution internally, whenever possible.
For cases where the individual feels he or she cannot submit concerns through ‘usual channels’, the Employees shall report any known or suspected misconduct to the Management. The Company will not retaliate or allow retaliation for reports made in good faith. Members of the public who become aware of or suspect breaches of the Company’s internal policies or illegal actions by any Employee of the Company are also encouraged to report their concerns in writing, whether or not on an anonymous basis, to the Management at 2 Kyvelis Street, 16671 Vouliagmeni, Athens, Greece.
III. Treatment of Complaints
Complaints relating to accounting, internal accounting controls or auditing matters shall be dealt with by the Management. The Management may delegate the investigation of such complaints to the any such other person or persons it deems appropriate. Complaints regarding all other matters shall be dealt with by the Company’s legal counsel. The legal counsel may delegate the investigation to the same persons as are available to the Management. The person(s) investigating the complaint shall report to the Management in a timely manner all findings of fact, conclusions and proposed recommendations for remedial action, if any. Confidentiality shall be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.
The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any Employee in the terms and conditions of employment based upon any lawful actions of the Employee with respect to good faith reporting of complaints.
The Company’s Management is responsible for investigating and resolving all reported complaints and allegations brought up by members of the public concerning violations of the Company’s internal policies, its Code of Ethics or illegal actions by any Employee of the Company.
IV. Reporting and Record Retention
The Management shall maintain a log of all complaints, tracking their receipt, investigation and resolution. The Management shall maintain records of all steps taken in connection with any investigation of a report including investigation of reports that are found to be unsubstantiated.
V. Amendments
The Management shall review the Policy periodically and may amend it at any time, consistent with requirements of applicable laws, rules and regulations.
