www.thebunkerfirm.com THE BUNKER FIRM INC. sales@thebunkerfirm.com
1261 Mohawk Road Suite 6
Ancaster, ON L9G 3K9
Canada

CODE OF CONDUCT

CONTENTS

1. OBJECTIVE

2. CORPORATE SOCIAL RESPONSIBILITY
   • HEALTH & SAFETY
   • STAFF DEVELOPMENT
   • EQUAL OPPORTUNITY
   • THE ENVIRONMENT

3. PERSONAL CONDUCT

4. BUSINESS PRACTICE
   • COMPETITION & ANTI-CORRUPTION
   • COMPLIANCE PROGRAMS
   • WHISTLEBLOWING CONCERNS

5. OBJECTIVE
   The objective of this Code of Conduct is to describe the corporate social responsibility (CSR) requirements as well as the standards applying to personal conduct and business practice in THE BUNKER FIRM INC (hereafter ‘TBF’).
   TBF is a company specializing in the purchase, sale and supply of fuel and lube oil to ships as well as risk management and associated services.

6. CORPORATE SOCIAL RESPONSIBILITY
   TBF aims to conduct our business in an ethical, sustainable and socially responsible manner and will comply with the rules and legislation governing the areas in which we operate. At the very core of our business are our employees. Their hard work, commitment and persistence drive our growth and take our business to new heights. We firmly believe that for our people to deliver the very best results, they must feel their very best.

The following sections will set forth our CSR requirements in four key areas:

a) Health & safety
Everywhere in the group, we seek to create satisfactory and optimum working conditions for our employees. Work is planned and performed with the highest possible consideration and care for their well-being. Routines ensuring the health and safety of our employees are continually developed and improved with the aim of attaining the best possible foundation for happy, healthy and productive staff. Our focus on the individual human being transcends our own organization with subsidiaries across the globe actively engaged in community projects of various kinds.

TBF emphasizes open and honest communication internally in the group as well as with all other stakeholders of the group. Trust is essential in every aspect of our business and helps create the kind of work environment, cooperation and business relationships that inspire, motivate and add true value.

b) Staff development
To ensure the welfare, job satisfaction and motivation of our employees, we provide ample opportunity for them to continually develop their professional and personal competencies through internal and external education and training programs. Management considers staff development a key factor in the further development of our group, and employees are encouraged and expected to seek out courses and training that keep their professional and personal skills sharp and up to date at all times to the overall benefit of the group and the employees themselves.

c) Equal opportunity
Our policy is that all employees, irrespective of gender, nationality, skin color and religion, must have equal career and management opportunities. This philosophy is supported by our open-minded, unprejudiced culture which allows each individual employee to make the best possible use of his/her skills. Likewise, TBF’s internal management training programs are available to anyone with the right skills.

When recruiting new colleagues, we evaluate the professional and personal skills of candidates. In our view, gender says nothing about a person’s competencies, level of commitment or ability to cooperate with others which is why it is no decisive factor for us. In the TBF offices across the world, our highly skilled staff – male and female – work together in making the most of their talents.

The industry in which we operate is characterized by a high degree of multiplicity – and so is TBF. We believe that as an international group with business partners across the globe it is not just a great advantage to be represented by employees with different cultural backgrounds and nationalities. It is an absolute must.

Just as is the case with gender, an individual’s religious and sexual orientation will have no impact on his/her career opportunities within our group. We recruit reliable, respectful and competent professionals of any orientation.

d) Environment
TBF acknowledges the influence of the climate changes, along with the role that transportation and energy play in assisting people traveling and goods being transported by sea. Being a group specializing in oil trading, we do whatever in our capacity to reduce the impact on the environment. A particularly important area of focus in our line of business is prevention of oil spill, which is why we take all necessary measures to avoid causing harm to nature. With the Sulphur cap just around the corner, we are constantly looking for ways to improve environmental and operational performance and at the same time facilitate man’s ability to journey at sea.

In all our subsidiaries, we recycle and seek to reduce power consumption wherever and whenever possible with the aim of protecting our surroundings and the climate from human-induced harm and hazards.

3. PERSONAL CONDUCT
   TBF expects our employees to act in complete compliance with the law as well as with internal standards and practices. Our employees should likewise abstain from assisting associates and any other individuals in any breach of such laws, standards and practices.

Employees must treat each other and any other persons, with whom they come into contact, with respect and must not behave in such a way as to offend local customs and culture.

Behavior of detrimental nature, such as harassment, discrimination, threats and degrading actions, is strictly prohibited, and any violations hereof will not be tolerated.

All employees are bound by the duty of confidentiality and must prevent any unauthorized persons from accessing information or learning about business secrets that could harm the group, our customers and other associates in any way. No employee must use or contribute to the use of insider information but behave impartially in business matters of any kind.

4. BUSINESS PRACTICE
   At TBF, we know that every lasting business relationship is based on mutual trust and respect. We also know that trust is earned and should not be taken for granted. Keeping promises and meeting expectations are key to building a trustful relation where two parties can rely on each other.

TBF expects its business partners and customers to respect human rights and refrain from using child labor. This also means that we condemn any use of forced, bonded or prison labor as well as harsh disciplinary measures. Any business partner of TBF must abide by applicable law and regulation, provide accurate business information and live up to any agreements made.

When communicating internally and externally, announcements and other business information presented by TBF must comply completely with applicable law. Likewise, accounting information provided by the group must meet accounting standards and be reported accurately, fully and correctly.

Working in the bunker industry requires responsibility also in supply chain management and therefore TBF takes full ownership of every step of our supply chain in our end to end customer experience. Our knowledge and practical insights in procurement and supply chain management have been built up over a decade at the very forefront of the bunker industry.

We know the origin of all our products – where and how they have been sourced, shipped and supplied to our customers in compliance with laws and regulations. We never compromise on quality, transparency and decency. Safety and sustainability in the process create comfort to our customers.

Quality, proactivity and attention to detail must characterize everything we do. This means that we always strive to create value for our customers and suppliers in any way that we can, and that we aim to avoid unnecessary bureaucracy and obsolete routines. We set high standards for our employees and expect initiative from all, while at the same time displaying a high degree of humanity and compassion.

Trade sanctions, including financial sanctions, are difficult, sensitive and intricate matters. If our business partners are involved in transactions, such as business dealings with a sanctioned country, entity or person, it is a requirement of ours that they ensure compliance with applicable legislation.

A. Competition & anti-corruption
It is a fundamental principle that TBF must act in full compliance with applicable competition laws and anti-corruption laws. Due to the global nature of our activities, it is imperative that our Group of companies complies with all relevant rules and legislation in those countries where the group operates. TBF’s activities are subject to a number of anti-corruption laws, i.a. the Danish Criminal Code, the UK law against corruption (the UK Bribery Act) and the American anti-corruption law (the U.S. Foreign Corrupt Practices Act). TBF has introduced a compliance program to ensure that the group has adequate procedures to prevent fraudulent behaviour among individuals within the group or persons associated with the group. Furthermore, each employee is to sign our Anti-Bribery policy document.

B. Compliance program
It is our policy that all personnel must have a general understanding of competition and anti-corruption laws and possess the tools and knowledge necessary to ensure that TBF acts in full compliance herewith. Furthermore, it is our policy that all personnel must demonstrate proper business ethics and code of conduct. To realize this goal, TBF has taken a number of initiatives to further the knowledge of competition law and anti-corruption law. The program consists of regular training of relevant personnel in competition-law and anti-corruption law matters. Furthermore, each employee is to read and sign all CSR related documents. Employees must always report to management in cases of doubt and are encouraged to consult management with any questions or grey-zone matters.

C. Whistleblowing concerns
We strongly encourage our employees to promptly raise any concern of breach or potential breach of this Code of Conduct, TBF Anti-Bribery policy or the law. TBF will never retaliate or allow retaliation for concerns raised in good faith.