1. Group Anti-Bribery Policy Group Compliance

2. Wallem Group 2 New Challenges in Compliance More Acts…Foreign Corrupt Practices Act (US) / Bribery Act 2010 (UK) Law enforcement actions are increasingly proactive and aggressive Global enforcement – any individual or company relates to these countries More accountable – to ensure business stakeholders are in compliance More stringent – “Facilitation payments” are prohibited

3. Group ComplianceWallem Group 3 Impacts to Wallem “Anti-Bribery” may become a standard term to do business Our Principals / clients who are subjected to these Acts will ask Wallem to comply with these Acts and their internal policies Wallem staff may personally be liable Damage to our reputation

4. Group ComplianceWallem Group 4 Group Anti-Bribery Policy Zero tolerance Guidelines on “Facilitation Payment” Do not prevent normal business activities such as business promotion and client entertainment All of us are responsible to implement this policy onshore and onboard FAQ

5. Group ComplianceWallem Group 5 Scenarios Scenario one We are very often coming across PSC inspectors and port authorities asking for money to give clear passage or threaten delaying the vessel. Practically it is very easy to delay a vessel or give deficiency, even though vessel has just came out from the yard. To avoid such delays the Master often pays gratuity. Scenario two We usually give a gift to the management of our Principal (such as a bottle of whiskey or a nice pen) during a business visit. We may also provide dinners to the staff of our Principal who visit our office.

6. Group ComplianceWallem Group 6 Scenarios Scenario three It is customary to give a souvenir or a gift to a new client to establish business relationship. The souvenir or gift may vary from a pen to even cash sponsorship for our client to celebrate their special event. Scenario four We arrange officials of the Immigration Bureau to provide an overseas clearance service which requires the officials to attend onboard a cruise vessel before the vessel arrives in the port. We agree in advance with the local Immigration Bureau to provide a small sum of cash allowance to each of these officials for purchasing food or refreshment.

7. Group ComplianceWallem Group 7 Group Anti-Bribery Policy Q & A