Code of Conduct

“Doing things right is one of our most important values at Green Maritime Technology. Our policy is to maintain the highest ethical standards in the conduct of our business and in our relations with our stakeholders. Our integrity and reputation for ethical practices are among our most valued assets. Integrity, Value, Quality, Health & Safety and Social Responsibility are all core values that underpin our Code of Conduct.
This Code defines the general framework of acceptable professional conduct for all employees, as well as the way to conduct business transactions with partners. Working here means making a commitment to uphold our company values and following the code of conduct outlined in this document.
Thank you for upholding our values and helping us to improve.
Please never hesitate to seek help if you’re faced with a legal, compliance or ethical issue.”

Introduction
This Code of Conduct applies to all our Stakeholders (all employees, managers and executives as well as all contractors and suppliers

Ethical Principles and Core Values
• Honesty
• Integrity
• Trustworthiness
• Courage
• Respect for others
• Responsibility
• Accountability
• Obedience to the law
• Teamwork
• Commitment to the code

Decision Making and the Code of Conduct
When making a decision, ask yourself the following:
• Is it legal?
• Does it comply with the code?
• Does it reflect our company values and ethics?
• Does it respect the rights of others?
• If you are unsure about any of the answers, ask.

Reporting/Speaking Up
The company encourages all employees to ask questions and raise issues without fear of retaliation and is committed to treating reports seriously and investigating them thoroughly.
Employees must report suspected unethical, illegal or suspicious behavior immediately. The company does not tolerate retaliation against anyone who makes a good faith report of suspected misconduct or otherwise assists with an investigation or audit.

To report a concern:
• Talk to your manager
• Contact Human Resources Manager
• Make a confidential and/or anonymous report online at www.gmtech.gr

No Retaliation
Employees who report a concern in good faith cannot be subjected to any adverse employment action including:
• Unfair dismissal, demotion or suspension
• Unfair denial of a promotion, transfer or other employment benefit
• Bullying and harassment, either in person or online
• Exclusionary behavior
• Any other behavior that singles out the person unfairly

Equal Opportunity
All employee rights are safeguarded and protected from cases of bias and prejudice.
We do not engage in or support discrimination in hiring, remuneration, access to training, promotion, termination, or retirement based on race, national or social origin, caste, birth, religion, disability, gender, sexual orientation, family responsibilities, marital status, union membership, political opinions, age, or any other condition that could give rise to discrimination.
We do not interfere with the exercise of personnel’s rights to observe tenets or practices, or to meet needs relating to race, national or social origin, religion, disability, gender, sexual orientation, family responsibilities, union membership, political opinions, or any other condition that could give rise to discrimination.
We do not allow any behavior that is threatening, abusive, exploitative, or sexually coercive, including gestures, language, and physical contact, in the workplace and, where applicable, in residences and other facilities provided by the company for use by personnel.

Harassment
We Treat all fellow employees, customers, business partners and other stakeholders with dignity and respect at all times.
Any type of harassment, including physical, sexual, verbal or other, is prohibited and can result in disciplinary action up to, and including, termination.
Harassment can include actions, language, written words or objects that create an intimidating or hostile work environment, such as:
We are committed to ensuring that our employees, our contractors and our customers work in safe and respectful environment that is free of bullying.

Conflicts of Interest
A conflict of interest can occur when an employee’s personal activities, investments or associations compromises their judgment or ability to act in the company’s best interests. Employees should avoid the types of situations that can give rise to conflicts of interest.
It’s important for employees to disclose any relationships, associations or activities that could create actual, potential, or even perceived, conflict of interest to their manager or the Human Resources Department.

External Communication on Behalf of the Company
Only the CEO is authorized to represent the company to media and/or legal authorities. Employees should refer all requests for information or interviews to the Administration Department.

Confidentiality
The company and its employees maintain the confidentiality of all proprietary information. Proprietary information includes all non-public information that might be harmful to the company and its customers and business partners if disclosed.
All employees are responsible for maintaining the confidentiality of information gained during their employment by the GMT.
We do not use or disclose the confidential information of a third party, unless they have authorized us to do so and the use or disclosure is permitted by law.

Privacy
The company complies with the requirements of the country’s and international privacy laws. All employees sign an agreement that contains provisions for information confidentiality and non-disclosure.
Employees store all personal information securely, mark it as confidential and store it only for as long as it is needed for the purpose for which is was collected.
When providing personal information, employees limit access to only those with a clear business need for the information.
Employees are required to report any breaches of privacy, including the loss, theft of or unauthorized access to personal information, to their manager.

Competition, Fair Dealings and Antitrust
While the company competes aggressively for new business, relationships with business partners are built upon trust and mutual benefits and compliant with competition/ antitrust laws.
We believe in fair and open competition, we pay respect to our competitors, preventing any scheme of unfair competition and similar practices and promoting the rules of free market

Bribery and Facilitation Payments
GMT does not and will not take part in bribery, corruption or any other illegal act. Those actions will lead to dismissal or termination of the business relationship.
GMT deems bribes to include facilitation payments even if these are tolerated in the country where business is being conducted.
The company will not attempt to influence the judgement or behavior of a person in a position of trust by paying a bribe or kickback. This applies to persons in government and in private business.
The company does not permit facilitation (or “grease”) payments to government officials or private business in order to secure or speed up routine actions.
Employees will refuse any offer or request for an unlawful payment and report the incident to the company’s Management

Gifts and Entertainment
Staff and other stakeholders must not promise, give or accept any gift, reward or benefit from any interested party with whom they have been brought into contact through their duties. They must not canvass gifts or hospitality.
Employees may only accept occasional unsolicited personal gifts of nominal value such as promotional items and may provide the same to customers and business partners. These will usually incorporate that supplier’s or client’s logo.
Management and staff should refrain from offering any gifts or hospitality as a rule. There are limited circumstances in which offering gifts or hospitality may be acceptable and the expenditure must be approved in advance by CEO or the Integrated System Manager.
When in doubt, employees should check with CEO or the Integrated System Manager before giving or receiving anything of value.

Political and Charitable Contributions
The company totally prohibit the offer or receipt of political and charitable donations in connection with the organization’s business
Employees are free to support any political party or entity on a personal level. However, this must be kept separate from company business.
The one and only exception:
Charitable donations to a charity which has or could have no direct or indirect influence over a decision which could affect the organization. For example, a donation to a charity supporting international famine relief, prevention of disease, provision of water etc. when the organization has no involvement in the work undertaken by those charities.

Record Keeping
All documents, databases, voice messages, mobile device messages, computer documents, files and photos are records.
Employees are required to:
• maintain these records and protect their integrity for as long as required
• maintain official record keeping systems to retain and file records required for business, legal, financial, research or archival purposes
• dispose of your records according to the company’s records retention and disposition schedule
Employees should never destroy documents in response to, or in anticipation of, an investigation or audit.

Protection and Proper Use of Company Assets
GMT protects the personal data and intellectual property of personnel and customers and any other interested party.
In accordance with good business practice, all employees have the duty to attentively protect and carefully use GMT’ tangible assets (e.g. buildings and computers) or intangible assets (e.g. trademarks, reputation intellectual property and confidential data).

Health & Safety
We are committed to provide a healthy and safe workplace to our employees. GMT Complies with all applicable health and Safety legislation.
We provide a safe and healthy workplace environment and we take effective steps to prevent potential accidents and injury to workers’ health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the workplace environment
We establish systems to detect, avoid, or respond to potential threats to the health and safety of personnel. We maintain written records of all accidents that occur in the workplace and in company-controlled residences and property.
Our organization provides at its expense appropriate Personal Protective Equipment to personnel. In the event of a work-related injury, our organization will provide first aid and assist the worker in obtaining follow-up medical treatment.
All personnel have the right to remove themselves from imminent serious danger without seeking permission from our organization’s management.

Disciplinary Practices
We treat all personnel with dignity and respect. We have zero tolerance of corporal punishment, mental or physical abuse of personnel, harsh or inhumane treatment. In general, the organization does not make deductions from wages for disciplinary purposes.
Disciplinary Actions will be determined on a case by case basis, depending upon the nature and severity of the non-complied behavior. Action taken may include any one or more of the following:
• Warning
• Removal from first line and depending works, including vessel’s surveys
• In house re-training sessions
• Termination of employment

Environment
The company is committed to operating in an environmentally responsible manner. GMT Complies with all applicable environmental legislation and sustainability commitments
To achieve our environmental goals, we will put our best efforts in Preventing pollution and reducing consumption of resources through waste management strategies that promote waste minimization re-use, recovery and recycling, as appropriate

Forced and Compulsory Labor:
We do not engage in or support the use of forced or compulsory labor. We prohibit all forms of forced and compulsory labor, the engagement in human trafficking and the slavery or servitude. We prohibit child labor and no person is hired under the legal age of employment in no circumstances
We do not withhold any part of any personnel’s salary, benefits, property, or documents in order to force such personnel to continue working for the company. Personnel has the right to leave the workplace premises after completing the standard workday, and be free to terminate their employment provided that they give reasonable notice to their employer.

Freedom of Association And Right To Collective Bargaining:
All personnel of our organization have the right to form, join, and organize labor unions of their choice.
We ensure that representatives of workers are not subjected to discrimination, harassment, intimidation.

Consultants, Representatives and Agents
When it is necessary to engage the services of an individual or a firm to consult for or otherwise represent Green Maritime Technology, consideration must be given to avoiding conflicts of interest between GMT and the person or firm to be employed. Consultants, representatives and agents of GMT must not act on “GMT” behalf in any way that is inconsistent with this Code or the applicable laws or regulations.

Code of Conduct Acknowledgement
By certifying to the company code of conduct, you acknowledge that:
• You have read the entire code of conduct and understand your responsibilities related to it.
• You have had the opportunity to ask questions to clarify any unclear aspects of the code.
• You agree to abide by its principles.
• You agree to report to the company any violations of the code.
• You agree to cooperate in any investigations of violations of the code.