Moorhouse Logistics Ltd SRL (hereinafter "MHL" or "we") is committed to promoting honest and ethical business conduct by all its employees, directors, managers, and agents (hereinafter collectively referred to as "Representatives") and to complying with the laws that govern business conduct worldwide. We believe that adhering to a specific code of ethics is a fundamental asset that fosters strong relationships with our Representatives and all parties MHL collaborates with. This commitment is outlined in the present Business Code of Ethics and Professional Conduct (hereinafter the "Code"). The Code establishes rules and standards of behavior and performance and forms part of the terms and conditions of employment. No violations of the Code will be tolerated, and disciplinary action is foreseen for those in breach. The Code applies to all Representatives of MHL, who are required to read and understand its contents to ensure compliance with the principles of business integrity and ethics outlined herein. This Code is based on the current legislation of Romania and the generally recognized principles and norms of business ethics. While it does not cover every possible case or situation a Representative may encounter, it provides fundamental principles for resolving complex ethical situations.

The objectives of the Code are: 
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(i) to establish corporate standards of business ethics for MHL and regulate the activities of all Representatives in     challenging ethical situations;
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(ii) to guide all Representatives in understanding, supporting, and adhering to common principles of business ethics.
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(iii) to create a positive environment based on respect  for individuals and to foster conditions for their development.

1. Reporting of Illegal or Unethical Behavior 

‍Representatives are required to report any observed illegal or unethical behavior to their respective managers. This includes cooperation in internal investigations of misconduct. MHL will take all necessary actions to protect individuals who report such behavior in good faith from retaliation. Illegal or unethical behavior can also be reported anonymously via the following email address: hr@mhlog.com. All communications will be treated confidentially and investigated to the extent reasonably possible. 

‍2. Legal Compliance 

‍We comply with all Romanian laws and regulations, and Representatives are strictly required to do the same. It is the personal responsibility of each Representative to adhere to applicable laws, rules, and regulations, with particular emphasis on legislation related to accounting and auditing. If any Representative is unsure whether a situation violates the law, they should consult their manager to obtain approval for legal counsel. 

‍3. Fair Business Conduct

 We conduct our business in a fair and ethical manner, always prioritizing our customers' interests and conforming to accepted professional standards. It is strictly forbidden to offer or accept any monetary benefits or gifts to gain business advantages to which we would not otherwise be entitled. If such benefits or gifts are received, they must be disclosed and approved in advance. Representatives must deal honestly, ethically, and fairly with MHL’s customers, suppliers, competitors, and colleagues. No Representative should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or other unfair practices. We strive to ensure the competitiveness of our clients and aim to establish long-term, mutually beneficial relationships. Customer loyalty and trust are earned through honest and ethical business practices.  

‍4. Corruption and Bribery 

‍MHL maintains a zero-tolerance policy towards bribery, which includes the acceptance, offering, solicitation, or promise of benefits, whether monetary or in kind, to gain business advantages to which we would not otherwise be entitled. Full compliance with laws prohibiting bribery is required, with no exceptions. 

‍5. Fairness at Work 

‍It is of utmost importance to treat all colleagues with respect and ensure that no one is subjected to harassment, bullying, discrimination, or degrading behavior. Discrimination on the grounds of race, gender, faith, sexual orientation, or any other factors is strictly prohibited. 

‍6. Health and Safety 

‍MHL is committed to providing a safe and healthy work environment for all Representatives. In turn, each Representative is required to follow all applicable safety and health regulations and report accidents, injuries, and unsafe conditions. 

‍7. Drugs and Alcohol 

‍The possession or use of any substance prohibited by law is not tolerated in the workplace, during the execution of agency services, or in any context while representing MHL. Alcohol consumption is not permitted in the workplace. However, moderate alcohol consumption is allowed outside the workplace, such as during business meetings, provided it is objectively acceptable, moderate, and in accordance with local customs and laws. 

‍8. Confidential Information & Data Protection 

‍Confidential information, including business-sensitive data, is treated with the utmost care. MHL ensures full compliance with laws and regulations regarding confidentiality and monitors any legislative changes. Where necessary, confidentiality agreements are executed. The privacy of personal data is protected, and all Representatives are required to uphold the highest standards in this regard. Any personal data processing is done in accordance with applicable laws, with particular care given to the complexities of the shipping industry. 

‍9. Protection of the Environment 

‍MHL and its Representatives are committed to adhering to environmental protection regulations and contributing to continuous environmental improvement. MHL maintains a zero-tolerance policy for any violations of environmental laws or regulations. 

‍10. Documents 

‍All MHL documents, including those formalizing relations with customers, partners, authorities, competitors, and employees, are developed and approved in accordance with this Code. 

‍11. Relationships Between Employees 

‍Relationships between MHL employees, regardless of position or role, are based on mutual respect, assistance, openness, teamwork, and cooperation. Disparaging or offensive behavior is unacceptable. 

‍12. Relationships Between Managers and Subordinates

Manager-subordinate relationships are founded on openness, fairness, and mutual support. Managers provide equal opportunities for all subordinates to fulfill their duties ,support initiative, share responsibility, and ensure fair evaluation of performance. Subordinates, in turn, must demonstrate respect, discipline, and conscientiousness in performing their duties and tasks related to MHL’s operations. 

‍13. Use of MHL Resources 

‍Employees are required to treat MHL property and resources with care and use them exclusively for business purposes.