EISA Limited, a service provider, operating in the ports of Bulgaria, Ukraine and Georgia, contracted to shipping agencies EISA Bulgaria, EISA Ukraine and EISA Georgia, (hereinafter ‘EISA’ or ‘we’) has always been committed to promoting honest and ethical business conduct by all the employees, directors, managers, shareholders and agents of the aforementioned shipping agencies (hereinafter collectively referred to as ‘Representatives’ or ‘You’) and to complying with the laws that govern the conduct of its business worldwide. As a matter of principle we believe that complying with a specific code of ethics is a fundamental asset which builds firm relationships with our Representatives and all the parties EISA collaborates with. This commitment is stipulated in the present business Ethics and Conduct Code (the ‘Code’). The Code outlines rules and standards of behavior and performance and forms a part of the terms and conditions of employment. No violation of the rules and standards stipulated in the Code is tolerated and disciplinary action is foreseen for those in breach. The application of the Code extends to all Representatives of EISA. All Representatives are required to read and comprehend the Code so as to secure compliance with the principles of business integrity and ethics stipulated herein.

1. Reporting of Illegal or Unethical Behavior

Representatives are required to report to their respective managers, any observed illegal or unethical behavior. This includes the cooperation in internal investigations of misconduct. We undertake to take all necessary action in order to protect any individual who has proceeded to such reporting in good faith from any possible retaliation. Any illegal or unethical behavior may be reported on an anonymous basis to the following email address: compliance@eisalimited.com.cy. All communications will be considered and investigated and treated confidentially to the extent reasonably possible.

2. Legal Compliance

We comply with the laws and regulations of all the countries in which we operate and Representatives are strictly required to do the same. We are kept informed of changes in local laws and regulations by our local correspondents and ensure adherence to the standards of business conduct relevant to the agency service provided by EISA. It is the personal responsibility of each Representative to adhere to the standards and restrictions imposed by the applicable laws, rules and regulations, and with emphasis on relevant legislation relating to accounting and auditing matters.

Any Representative who in uncertain whether a situation potentially violates any applicable law, rule, or regulation should contact their respective manager in order to obtain approval to consult legal counsel.

3. Fair business conduct

We conduct our business in a fair and ethical manner, in full support of the interests of our customers and conforming to accepted professional standards of conduct. It is explicitly forbidden to offer or accept any monetary benefits or gifts to achieve business advantages which we would not otherwise be entitled to. Should any such monetary benefits or gifts be received, it is mandatory to be disclosed and approved of in advance. Representatives must deal honestly, ethically and fairly with EISA’s customers, suppliers, competitors and other Representatives, and no Representative should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. Honest conduct is considered to be conduct that is free from fraud or deception.

4. Corruption and bribery

EISA maintains a zero tolerance policy towards bribery, which is the acceptance, offering, solicitation or promise of benefits, monetary or in kind, in order to gain business advantages to which we would otherwise not be entitled. Full compliance with the relevant laws prohibiting bribery is applied with no exceptions whatsoever.

5. Fairness at Work

It is of the utmost importance to treat all people with whom we work with respect and to ensure that no one is exposed to harassment, bullying, discrimination or other behaviour that may be perceived as degrading. As a matter of policy there is no discrimination against others on the grounds of race, gender, sexual preference or any other grounds.

6. Health and Safety

EISA takes all necessary measures in order to provide its Representatives with a safe and healthy work environment. Each Representative in turn, is required to follow all applicable safety and health rules, regulations and laws and by reporting accidents, injuries and unsafe equipment, practices or conditions.

7. Drugs and alcohol

Possession or use of any substance prohibited by law is not tolerated in the workplace, during the execution of our agency services or in any other context while representing EISA. Consumption of alcohol in the workplace is not allowed. Outside of the workplace and in the framework of business meetings, alcohol consumption is allowed when it is objectively acceptable, and in such cases it must be consumed in moderate amounts and in accordance with local customs and applicable laws.

8. Confidential Information & Data Protection

Confidential information is treated with the utmost care, and includes any business sensitive information. Full compliance with laws and regulations relating to confidential information is always ensured, and any changes in the relevant legislation is monitored. Wherever the circumstances require a confidentiality agreement is executed.

Privacy of personal data is protected and treated with confidentiality and all Representatives are required to uphold the utmost standards in relation to such protection. Any personal data processing is made in accordance with the applicable laws and regulations and bearing in mind the relevant complexities involved in the shipping agency industry which requires a higher standard of care.

9. Protection of the Environment

EISA and all Representatives hereby agree to adhere to environmental protection regulations and to contribute towards achieving continual environmental protection improvement. EISA has a zero tolerance policy to any violation of local or national environmental rules, regulations or laws whatsoever in relation to environmental protection.