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          1. Moran Corporate Governance

            MSA Anti-Bribery Policy

            Overview

            Moran Shipping Agencies, Inc. (MSA) strictly prohibits offering or providing payments or anything of value to government officials or private individuals for the purpose of gaining or retaining business or business advantages. This prohibition applies to all MSA business activities and those of its affiliates, anywhere in the world, regardless of whether the exchange is with a government official or private individual. Payments or items of value used to secure a business advantage are unacceptable and can expose MSA, its employees, and affiliates to possible criminal penalties and reputational harm.

            This anti-bribery policy applies to all officers, employees, agents, or other intermediaries acting on behalf of MSA. Each officer and employee of MSA has a responsibility and obligation to conduct business activities ethically and in compliance with the Foreign Corrupt Practices Act, 15 U.S.C. § 78dd-1 et seq., as well as those applicable anti-bribery laws of foreign countries. MSA must ask all business partners who represent or act on behalf of MSA to comply with applicable bribery and corruption laws. Where appropriate, business partners must show that they have appropriate programs to prevent bribery in place.

            Actions and items prohibited by this policy include cash payments, gifts, entertainment, investment opportunities, travel expenses, employment opportunities, charitable contributions, or any type of benefit to a recipient, their friends, family, or business partners. These payments are unlike and distinguishable from reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the business activities of Moran Shipping Agencies.


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