This Code of Ethics expresses the ethical principles, commitments, and responsibilities that form the foundation of the corporate activities and management of AEM Srl.

AEM Srl firmly believes it is necessary to adopt ethically proper conduct, in full compliance with the law, as well as with its bylaws and regulations.

For this reason, AEM Srl adopts this Code of Ethics (the “Code of Ethics”) together with the Organization, Management, and Control Model (the “Model”), in line with the provisions of Legislative Decree no. 231/2001, which introduced into the Italian legal system the administrative liability of legal entities.

The decision to promote ethical conduct was first made concrete by drafting this Code of Ethics, which was submitted to the approval of the Board of Directors.

The Code of Ethics is a set of principles and guidelines established to inspire the activities of AEM Srl and to guide the conduct not only of its employees but also of all those who come into contact with the Company in the course of its business.

The objective is to ensure that the Company’s efficiency and reliability are accompanied by ethical conduct.

In drafting the Code of Ethics, the guidance provided by Confindustria was also taken into account, as Confindustria has formulated guidelines (“Guidelines”) for creating organization, management, and control models aimed at preventing offenses pursuant to Legislative Decree no. 231 of June 8, 2001, which regulates the administrative liability of companies.

The Guidelines include, among the most important components of the control system, the adoption of a code of ethics, recommending that the components of the control system conform to a set of principles that have been considered in the preparation of the Code of Ethics.

Therefore, the Code of Ethics is a foundational component of the organizational model and control system adopted by AEM Srl, in the conviction that conducting business ethically is crucial for the Company’s success.

The Code of Ethics is distributed to all employees and supplements compliance with the civil and criminal laws that bind all individuals, including obligations arising from national collective bargaining agreements.

Hence, the following are the general concepts to be regarded as fundamental principles of our conduct.

This Code of Ethics was approved by the Board of Directors of AEM Srl on September 7, 2016.

1.2 Mission

AEM Srl operates in the maritime and international shipping sector.

Its legal, administrative, and operational headquarters are located in Genoa (Via C.R. Ceccardi 1/9) and it has a branch in Livorno (Via Pieroni 27).

AEM Srl deems the following values to be fundamental:

- Respect for individuals, regarded as an indispensable resource for the existence and development of AEM Srl.

- Professionalism and integrity of each individual—whether employee, associate, or external party—are fundamental values for achieving corporate objectives. Employees at every level must interact and collaborate to maintain a climate of mutual respect within the Company so as to safeguard everyone’s dignity and reputation.

- Environmental protection, seen as essential for the Company’s development, in full compliance with national regulations and with the interests of the community. This protection must be ensured by implementing and monitoring corporate processes, by ensuring the competence and awareness of employees in compliance with national regulations, and by paying close attention to available technologies during both design and operational phases, in order to minimize environmental impact.

- Health and safety protection, pursued with the utmost commitment by adopting the most suitable measures to create a working environment that guarantees employee health and safety, and by continuously monitoring the risks associated with the Company’s operational activities.

AEM Srl has always considered the respect of these values to be the cornerstone of its business activities.

Within this context, the decision to adopt an organizational model aimed at preventing the crimes referred to in Legislative Decree 231/2001 represents a further milestone in the Company’s growth path and in strengthening relations with commercial partners and national institutions.

1.3 Recipients

The Code of Ethics is addressed to corporate bodies and their members, employees, temporary workers, consultants, and collaborators of any kind, as well as to any other party who may act in the name and on behalf of AEM Srl and, generally speaking, to all those with whom the Company comes into contact in the course of its activities (hereinafter, the “Recipients”).

1.4 Scope of Application

The rules of the Code of Ethics are an essential part of the contractual obligations of personnel pursuant to Articles 2104 and 2105 of the Italian Civil Code.

Article 2104 of the Italian Civil Code, entitled “Diligence of the employee,” states: “The employee must use the diligence required by the nature of the work to be performed, by the interest of the enterprise, and by the higher interest of national production. The employee must also comply with the instructions for the performance and regulation of the work given by the employer and by the latter’s associates who hierarchically depend on the employer.”

Article 2105 of the Italian Civil Code, entitled “Obligation of loyalty,” states: “The employee must not carry on business, on his own account or on behalf of a third party, in competition with the employer, nor disclose information concerning the organization and production methods of the business, or use such information in a manner that may be detrimental to the business.”

1.5 Contractual Value of the Code of Ethics

Compliance with the rules of the Code of Ethics must be considered an essential part of the contractual obligations of AEM Srl’s employees, managers, and directors, pursuant to and in accordance with Articles 2104, 2105, and 2106 of the Italian Civil Code. Article 2106, entitled “Disciplinary sanctions” states: “Failure to comply with the provisions contained in the preceding two articles may result in the application of disciplinary sanctions, depending on the seriousness of the infringement.”

A serious and persistent violation of the rules set forth in this Code of Ethics undermines the relationship of trust established with AEM Srl and may lead to disciplinary measures and claims for damages, without prejudice, for employees, to compliance with the procedures laid down by Article 7 of Law 300/1970 (known as the “Workers’ Statute”) and by the applicable national collective bargaining agreement.

Compliance with the rules of the Code of Ethics must be considered an essential part of the contractual obligations assumed by collaborators. Any conduct by collaborators who have relationships with AEM Srl that is in conflict with the rules set out in the Code of Ethics may lead to the immediate termination of the contractual relationship, in addition to any claim for damages by AEM Srl should such conduct cause harm to the Company.

1.6 Communication and Dissemination of this Code of Ethics

AEM Srl undertakes to inform all Recipients about the provisions and application of the Code of Ethics, recommending its observance. In particular, AEM Srl, also through the designation of specific internal functions, takes care of:

- Disseminating the Code of Ethics among the Recipients;

- Interpreting and clarifying the applicable provisions;

- Verifying actual compliance with the Code of Ethics;

- Updating the provisions as needed based on circumstances that may arise over time.

1.7 Monitoring the Application and Updating of the Code of Ethics

AEM Srl commits to ensuring compliance with the Code of Ethics through the support of a Supervisory Body, which is responsible for overseeing, monitoring, implementing, updating, and enforcing the Code, as well as ensuring its dissemination and comprehension.

1.8 Disclosure Obligations

All employees must promptly and confidentially report to the Supervisory Body—guaranteeing, subject to legal obligations, the anonymity of the reporting individuals—any information of which they become aware in the course of their work concerning violations of legal provisions, the Code of Ethics, or any other corporate regulations that may in any way involve or harm AEM Srl.

Any such reports, as well as any violation of the Code of Ethics discovered through other checks, will be promptly examined and assessed by the Supervisory Body. Based on its findings, the relevant functions will determine whether to adopt any disciplinary measures.

1.9 Violations of the Code of Ethics

Violations of the Code of Ethics give rise to the disciplinary sanctions prescribed by the applicable national collective bargaining agreement and may also result, depending on the seriousness of the violation, in civil or criminal proceedings.

1.10 Revision of the Code of Ethics

The revision or updating of the Code of Ethics is approved by the Board of Directors of AEM Srl, including upon proposal by the Supervisory Body.

Once approved, the document is promptly disseminated to the Recipients.

Capitolo 2 – Ethical Principles

2.1 Responsibility and Performance of Activities

Recipients act fairly, in good faith, with diligence, efficiency, and integrity, conducting themselves in a spirit of cooperation and mutual collaboration, in compliance with internal procedures, making the best use of the tools and time at their disposal, and assuming responsibility for their tasks. The activity carried out by each person is oriented towards improving their own skills and enhancing their professionalism.

Any activity carried out on behalf of AEM Srl must be aimed solely at satisfying its interests. Therefore, any actual or potential conflicts between personal interests and the interests of AEM Srl must be avoided or, at least, disclosed in advance, since such conflicts frequently result in violations of applicable regulations.

In particular, it is necessary to avoid situations in which membership in certain entities or associations, as well as personal relationships (e.g., family ties) of an employee, may create conflicts of interest with AEM Srl.

In dealings with third parties, no donations, benefits (whether direct or indirect), gifts, acts of courtesy, or hospitality are permitted, unless of a nature and value not exceeding 500 Euros, such that they cannot be interpreted as designed to obtain preferential treatment or otherwise compromise, directly or indirectly, the image of AEM Srl.

All actions and operations carried out and the conduct of each Recipient in performing their assigned functions or tasks must meet the criteria of formal and substantive legality and must protect AEM Srl, in accordance with applicable regulations and internal procedures, as well as adhere to the principles of fairness.

Recipients must not use for personal purposes any information, property, or equipment at their disposal in carrying out their duties or tasks.

2.2 Protection of Company Assets and Information

Each Recipient is responsible for safeguarding and preserving corporate assets, both tangible and intangible, entrusted to them for the performance of their duties, as well as for using them properly and in compliance with Company purposes and applicable regulations.

2.3 Gifts, Presents, and Other Forms of Benefits

Recipients of the Code of Ethics must not accept, even on festive occasions, any gifts or other benefits related to their professional activities, except for items of modest value as described in the Petty Cash Management procedure.

Recipients must refrain from any conduct not permitted by applicable laws, commercial practices, or by any codes of ethics of companies or institutions with which they have relationships.

Shareholders, business partners, customers, suppliers, and anyone who comes into contact with AEM Srl in any capacity will contribute to strengthening the Company’s image in line with the values of transparency, correctness, and fairness.

Chapter 3 – Administrative and Financial Management

3.1 Administrative Management and Financial Statements

All preparation of financial statements and any other type of accounting documentation must be carried out in compliance with applicable laws and regulations, using acknowledged accounting practices and principles, and must faithfully reflect business events in accordance with criteria of clarity, truthfulness, and accuracy.

AEM Srl adopts criteria of truthfulness, accuracy, completeness, and clarity of the information required to ensure transparent accounting records. These criteria represent and constitute a fundamental value for AEM Srl and guarantee shareholders and third parties the possibility of making a clear assessment of the Company’s economic, asset, and financial situation.

To this end, all documentation of transactions must:

- Be recorded in the accounting system to substantiate each entry;

- Be complete, clear, truthful, accurate, and valid;

- Be retained on file for any appropriate review for the period mandated by law.

Anyone who becomes aware of possible omissions, falsifications, or irregularities in the keeping of accounts and related supporting documents, or of violations of the principles set forth in the Code of Ethics or in applicable laws, is required to report them promptly to the Supervisory Body.

The aforementioned violations constitute disciplinary offenses and are duly sanctioned, as they undermine the relationship of trust with AEM Srl.

3.2 Payments

AEM Srl does not make illicit payments of any kind and conducts all its financial transactions under the principle of absolute traceability and transparency.

Chapter 4 – Relations with Third Parties

4.1 Relations with Public Administration

Relations with the Public Administration, public officials, or individuals performing a public service must be conducted in strict compliance with the applicable laws and regulations and must not in any way compromise the integrity or reputation of AEM Srl.

Only the properly authorized corporate functions and personnel shall undertake commitments and manage relationships with these parties, strictly adhering to internal procedures and ensuring transparency.

In dealings with such parties, Recipients shall refrain from offering, even through intermediaries, money or other benefits to the involved public official, their family members, or persons in any way connected to them, and from seeking or establishing personal relationships of favor, influence, or interference aimed at directly or indirectly affecting their activities.

Only tokens of modest value are permitted, in accordance with the specific directives issued by senior management.

4.2 Relations with Political, Trade Union, and Professional

AEM Srl non eroga contributi, diretti o indiretti, sotto qualsiasi forma, a partiti, movimenti, comitati e organizzazioni politiche e/o sindacali, a loro rappresentanti e candidati, tranne quelli previsti da normative specifiche.

4.3 Relations with Suppliers

Selection of suppliers is guided by principles of objectivity, competence, cost-effectiveness, transparency, and fairness, in compliance with internal procedures and applicable regulations.

Suppliers are required to:

- Comply with the applicable laws, customs, and practices;

- Adhere to the principles of this Code of Ethics;

- Comply with the principles of the Organization, Management, and Control Model of AEM Srl;

- Respect the laws in force on labor, with particular attention to child labor and the provisions of law on health and safety;

- Refrain from supporting, in any way, directly or indirectly, mafia-like or terrorist organizations;

- Guarantee respect for the human rights of workers.

4.4 Relations with Customers

Relations with customers are aimed at fully meeting their needs, with the objective of building a solid relationship based on fairness, honesty, efficiency, and professionalism.

Chapter 5 – Human Resources

5.1 Protection of Workers

AEM Srl guarantees workers’ freedom of association. It rejects all forms of discrimination on the basis of age, gender, sexual orientation, health status, race, nationality, political opinions, and religious beliefs. It also repudiates any discrimination in hiring policies and in the management of human resources.

Furthermore, AEM Srl undertakes to prevent any form of mobbing and labor exploitation, whether direct or indirect, and to recognize merit as the determining criterion for any pay increases and career advancement of each individual worker.

5.2 Respect and Development of Human Resources

Human resources are an essential factor for the existence, development, and success of every enterprise. Therefore, AEM Srl dedicates particular attention to enhancing, protecting, and developing the abilities and skills of all its employees, so that they may fully express their potential and professionalism and thereby contribute to achieving the Company’s objectives in compliance with the social and environmental responsibilities defined by AEM Srl’s management.

Chapter 6 – Environment, Health, and Safety

6.1 Environmental Protection

AEM Srl is committed to safeguarding the environment as a primary asset. For this purpose, it directs its choices to ensure the compatibility between economic initiatives and environmental needs.

AEM Srl is convinced that the full compatibility of its activities with the surrounding territory and environment is a fundamental condition for both the acceptability of its activities and for achieving its development objectives. This responsibility is borne by directors, managers, all employees, and collaborators of the Company, without exception.

6.2 Protection of Health and Safety

By fully complying with health and safety regulations, AEM Srl promotes a culture of workplace safety, encourages responsible conduct among employees, and provides adequate preventive measures to safeguard the health of its personnel.

Therefore, every activity of AEM Srl and each individual employee must comply with and uphold workplace safety regulations, strictly adhere to the law and any related obligations, and observe all measures required by the Company’s internal procedures and regulations.

Recipients of the Code of Ethics, within the scope of their duties, actively participate in the process of risk prevention regarding themselves, their colleagues, and third parties.

6.3 Duties of Workers in the Field of Workplace Health and Safety

Workers must take care, as far as they are able, of their own safety and health and that of other people in the workplace who may be affected by their actions or omissions, in accordance with their training and the instructions and equipment provided by the employer. They must observe the rules and instructions given by the employer, managers, and supervisors for the protection of their own and others’ health and safety.

Chapter 7 – IT Systems

7.1 Use of IT Systems

With regard to the use of IT systems, each AEM Srl employee is responsible for the security and proper use of the systems they operate and is subject to current legal and corporate provisions as well as the terms of software license agreements.

Except as provided by civil and criminal laws, improper use of Company assets and resources includes using online connections for purposes other than those related to the employment relationship.

Each employee must exercise the necessary care to prevent possible criminal acts committed through the use of IT systems.

Supervisory Body

For any reports, please write to the Supervisory Body via the following email address: segnalazioniodv@aemitalia.com

Ethical code

AEM Srl CODE OF ETHICS

Approved by the Board of Directors on September 7, 2016

Supervisory Body

Connecting ports around the world

Genoa Agency

Livorno Agency