1. Purpose and Scope

This Labor Practices Policy outlines the principles and standards governing the employment conditions of all Company personnel, including both office employees and seafarers. The policy aims to ensure fair treatment, equitable compensation, and compliance with international and local labor regulations.

It applies to all employees of the Company, regardless of position, nationality, gender, or work location.

2. Equal Opportunity and Non-Discrimination

The Company is committed through the respective policy to providing a workplace free from discrimination of any kind. Employment decisions, including hiring, promotion, and compensation, are based solely on merit, performance, qualifications, and career path level.
No employee or applicant will be discriminated against on the basis of race, color, gender, age, religion, nationality, sexual orientation, disability, or any other protected characteristic.

3. Compensation Practices

3.1 Office Employees

• Salaries for office employees are determined according to their level within the established career path framework, ensuring fairness and transparency.
• The Company considers the cost of living and ensures that salaries are at least 30% higher than the national minimum wage in the country of employment.
• Regular market salary analyses and internal equity reviews are conducted to maintain competitiveness and ensure equal pay for work of equal value.

3.2 Seafarers

• Compensation for seafarers is based on their rank and considers  industry standards as reported in the Drewry Maritime Wage Reports.
• Salaries also take into account the cost of living in the seafarer’s country of origin to ensure fair and adequate remuneration.

4. Working Hours, Rest, and Overtime

• The Company respects all applicable local and international labor laws regarding working hours and rest periods, including the Maritime Labour Convention (MLC) for seafarers.
• Employees shall not be required to work beyond the normal working hours, except under circumstances allowed by law and with appropriate compensation or time off in lieu.
• The Company utilizes digital applications to monitor working and resting hours for seafarers to ensure compliance and promote wellbeing.

5. Equal Remuneration and Gender Pay Equity

• The Company is committed to equal remuneration for all employees, regardless of gender or any other demographic factor.
• We regularly review and monitor the gender pay gap to identify and correct any disparities.
• Decisions regarding salary increases, promotions, and bonuses are made objectively based on performance, responsibilities, and experience.

6. Leave and Benefits

• All employees are entitled to paid Annual Leave, Sick Leave, Maternity/Paternity Leave, and other leave types as provided by local legislation.
• The Company ensures all employees can take their entitled leave without any negative consequences to their employment status or compensation.

7. Health, Safety, and Wellbeing

• The Company is dedicated to maintaining a healthy and safe workplace environment for all employees, both ashore and at sea.
• We offer comprehensive medical insurance, mental health support, and wellbeing programs for both office employees and seafarers.
• Additional assistance, such as access to mental health professionals, wellness programs, and counseling services, is available to promote overall employee wellbeing.

8. Compliance and Review

• This policy complies with all applicable national labor laws and international labor conventions, including the ILO and MLC standards.
• The Company conducts regular reviews of this policy to ensure continued alignment with best practices and evolving legal requirements.

9. Policy Governance

The company engages with employees and seafarers through surveys and engagement meeting in order to receive feedback regarding working conditions.

This Labor Practices Policy is approved by Top Management and reviewed annually by the ESG Working Team to ensure it remains fair, transparent, and up-to-date.