Business ethics are no different than personal ethics. The same high standard applies to both. As a Brandel Marine employee or agent, you are required to adhere to the highest standards regardless of local custom.

Employees and agents are expected to be honest and ethical in dealing with each other, with clients, vendors and all other third parties. Doing the right thing means doing it right every time. You must also respect the rights of employees and third parties. Your actions must be free from discrimination, libel, slander or harassment. Each person must be accorded equal opportunity, regardless of age, race, sex, sexual preference, color, creed, religion, national origin, marital status, veteran’s status, handicap or disability.

Misconduct cannot be excused because it was directed or requested by another. In this regard, you are expected to alert management whenever an illegal, dishonest or unethical act is discovered or suspected. You will never be penalized for reporting your discoveries or suspicions.

Employees should report any violation of the securities laws of the Republic of Ghana and any compliance issues and ethics violations of the Company‘s Code of Ethics as set forth below:

• You are encouraged to direct concerns or report violations to your immediate supervisor.
• If you believe your concerns have not been addressed satisfactorily by your supervisor, or if you are uncomfortable discussing concerns with your supervisor, please report your concerns by the following methods:
  • Calling a Company Compliance Hotline number as set forth below (which can be done anonymously); or
  • Submitting a report on the Company’s multi-language compliance website brandelmarine.org(which can be done anonymously).
• All communications through the Brandel Marine Compliance Alert Line will be handled with the utmost discretion.

Employees, agents and vendors are expected to cooperate in internal investigations of misconduct and violations of this Code. Company policy prohibits retaliation against persons making reports in good faith.