Modern Slavery Policy

This policy has been written in accordance with the Modern Slavery Act 2015 to assist in combatting modern slavery and human trafficking. Mainport and all subsidiaries has pledged to conduct its business in a fair, honest, and open manner. We are committed to zero tolerance of any form of slavery, human trafficking or child labour and all forms of corruption and bribery, both directly and indirectly within our supply chains, associated with these criminal acts.

Within its day-to-day operations Mainport has in place a range of measures to help ensure modern slavery and human trafficking are not taking place in its business. We set out some of these measures below:

• In addition to general observation for unusual behaviour onboard our vessels, as per security procedures, Mainport provides guidance to employees to support immigration and border agency initiatives to reduce human trafficking. Awareness of this issue is promulgated across all group businesses.

• Mainport is committed to working continually with other companies and organisations to share knowledge, learning and best practise and co-operates with a series of law-enforcement projects that help to combat human trafficking and modern slavery.

• Regularly monitoring key strategic risks as part of our ESG commitment and reporting these to Senior Management, and the Board of Directors. These risks include threats to human rights and ensuring we conduct ethical business activities.

• Our Whistleblowing Policy, setting forth a system in which employees and third parties, including employees from suppliers, can securely report concerns, suspicions or knowledge of misconduct or unethical behaviour, including any concerning slavery, human trafficking and human rights violations. Reporting parties are protected from retaliation in any form.

• Company standards, policies and procedures, setting out employees’ obligations and the process to report suspected and known incidents of modern slavery and human trafficking, and consequences for failure to report.

The Company does not tolerate slavery, forced labour or human trafficking anywhere in our operations or supply chain. We are committed to acting ethically and with integrity in all our business dealings and relationships, in addition to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers. To achieve this, the Company ensures transparency within the organisation and with suppliers of goods and services to the organisation.

The Company believe that the prevention, detection and reporting of modern slavery in any part of our business is the responsibility of all those working for us or under our control, therefore continuously develop of awareness and training of all staff across locations to enable identification of potential issues is crucial.