Anti-Bribery Policy

Introduction and Purpose:

DTA Maritime LLC (Hereafter referred as “DTA” or “DTA Group”) is committed to complying with the laws and regulations of the countries in which its businesses operate and acting in an ethical manner, consistent with the principles of honesty, integrity, fairness and respect.

Bribery and the related improper conduct referred to in this policy document are serious criminal offences for both the company and any individuals involved. They are also inconsistent with DTA values.

Laws prohibiting the types of improper payments covered by this policy apply in all of the countries in which DTA has operations in, or engages with in trading activities. Many laws, such as the Australian Criminal Code, the US Foreign Corrupt Practices Act and the UK Bribery Act, have application at home and abroad.

The purpose of this policy is to:

Policy Application:

This policy applies across the DTA Group to all directors and employees of Group companies (DTA personnel).

Policy

DTA personnel must:

Understand and comply with this policy;
Not give, offer, accept or request bribes, facilitation payments, secret commissions or other prohibited payments or engage in money laundering or cause any of them to be given, offered, accepted or requested;
Not approve any offers, or make, accept or request an irregular payment or other thing of value, to win business or influence a business decision in favour of the DTA Group;
Comply with any reporting and approval processes for gifts, entertainment or hospitality;
Not offer or receive any gifts, entertainment or hospitality to or from public or government officials or politicians;
Obtain required approvals for donations and sponsorship;
Maintain accurate records of dealings with third parties; and
Be vigilant and report any breaches of, or suspicious behaviour related to, this policy.

See Annexure A for more detail on the application and implementation of this policy.

Policy Amendment:

This policy cannot be amended without approval from the DTA Board or its authorised representative/s.