EASTERN TANKER Co.,Ltd

1. Definitions

A. An ethical problem between the company and employees

An ethical problem between the company and employees refers to a megative effect to company's functions caused by an employee's personal business.

B. Gifts

Gifts define cash, merchandise, securities, vouchers and other articles that prossess economic values.

C. Treats

Treats define entertainment provided procided by the means of incitations to meals, alcohol-consumption, sport events and other leisure activities.

D. Convenience

Concenience refers to the provision of the means of transportation, accommodation and sponsorship not included under the articles that define Gifts and Treats.

E. Reporter

A reporter is the employee with the responsibility to report when faced with situations that involve gifts, treats and convenience defined in the guidelines.

F. Interested Party

An interested Party defines to an internal/external individual or organization whose rights/profits may be affected by decisions or behaviors of employees in terms of job functions.

G. Generally Acceptable

Generally acceptanle refers to the giver's intention in gifts, treats and convenience originate from ordinary and voluntary gratitude.

H. Person in Charge of Ethical Affairs

Presidents is the chief person in charge of ethical affairs and Managing Directors of each group are in charge of ethical affairs.

I. Unavoidable circumstances

"Unavoidable circumstances" refer to being obliged to recerve a gift, treat or object of convenience as rejection may be considered impolite, or to receive the article through a third party without awareness.

J. Proper price

A "proper price" is the price normally accepted in the retail market.

2. Applicability

A. The guidelines apply all full-and part-time employees, advisors and agents, etc.

B. And other guidelines defined by our company obtain priority to these guidelines.

3. Application into Job Functions

A. Receiving illegal gift is not permitted.

1. 1) Items to declare
   1. (a) Employees shall not receive any gift from related in carrying out job functions.
   2. (b) If an employee receive any form of gifts from a related party under unavoidable circumstances, he/she shall report on the gift within three working days to the internal person in charge of ethical affairs and take necessary actions according to given instructions.
   3. (c) Employees shall not receive any gift from other employees, or through their family members, relatives or acquaintances.
2. 2) Reporting Procedure
   1. (a) If an employee receives any gift, he/she shall report to the person in charge of ethical affairs and take necessary actions according to any instructions given.
   2. (b) If an employee wishes to keep gift from customers as a souvenir;
      • - The employee shall report to the person in charge of ethical affairs should it be promotional articles with the logo or mark of donor.
      • - The employee shall report to the person in charge of ethical affairs and pay a proper price if the donor defines the limit of acceptable gift value that exceed the acceptable value of gift defined by the Guidelines for the HSM Code of Ethics.
3. 3) Rejection of Gifts

   When an employee is offered with gifts from interested parties, he/she shall take the following actions:

   1. (a) Explain the company’s Code of Ethics and Guidelines for HSM Code of Ethics. Politely reject the offer.
   2. (b) If rejection may be considered impolite, accept it and make the necessary report according to the Guidelines for HSM Code of Ethics.

B. Receiving any form treats is not permitted

1. 1) Items to declare
   1. (a) The employee shall not receive any form of treats from interested parties in carrying out job functions.
   2. (b) An Employee shall report on any treat that not regarded generally acceptable under unavoidable circumstances to the person in charge of ethical affairs.
   3. (c) If dining with an interested party may be considered as a from treats, the employee shall refrain from or avoid it.
   4. (d) If more than one person is involved, the person at the highest position shall be the reporter.
   5. (e) Any action performed by family members, relatives or acquaintances shall be deemed as that of the reporter himself/herself.
   6. (f) The guidelines are not applicable for official events approved by the company.
   7. (g) Treat Report and Rejection Procedures are the same as Gift Report and Rejections Procedures.

4. Other Ethical Problems

A. Receiving items of convenience is not permitted

1. 1) The employee shall not receive any item of convenience from interested parties in carrying out job functions.
2. 2) If an employee receives any items of convenience under unavoidable circumstances, the employee shall report to the person in charge of ethical affairs.
3. 3) Any action performed by family members, relatives or acquaintances shall be deemed as that of the reporter himself/herself.
4. 4) The guidelines shall not be applicable for official events approved by the company where facilities, meals, and transportation services are provided to all participants.
5. 5) Report and Rejection Procedures are the same as Gift Report and Rejections Procedures.

B. The illegal disclosure of company’s confidential information is not permitted

1. 1) Employees shall not disclose customers’ personal information internally/externally without prior approval.
2. 2) Employees will not disclose confidential information about the company, they will be prosecuted to the full extent of civil or criminal law

C. Protection of company assets and prohibition of misuse

1. 1) Employees should do their best to safely protect company assets from any possible damage.
2. 2) Employees shall not use company assets (corporate money, knowledge, information, copyrights, office facilities and other commodities) or working hours for personal use.

D. Debt redemption/guarantee is not permitted

1. 1) Employees shall not contact interested parties to settle their debts, credit card payments, or loan redemption carrying out their job functions.
2. 2) The same regulation applies to the share of property provided by the interested party, guarantee of loan arrangement by the interested party, or joint investment with the interested party in real estate, movable estate, securities, rights of trade, or membership carrying out their job functions.
3. 3) Any action performed by family members, relatives or acquaintances should be deemed as that of the reporter himself/herself.

E. Loans on movable/real estate are not permitted.

1. 1) Loans from any interested party should be deemed as receiving illegal gift with the exception of loans from financial institutes approved by the national law under lawful procedures.
2. 2) Employees shall not borrow the interested party’s assets or use them as security for personal convenience or profits.
3. 3) If an employee profits from purchasing movable/real estate from an interested party carrying out job functions at a price lower than the proper price, the difference should be deemed as receiving illegal gift.
4. 4) Any action performed by family members, relatives, or cquaintances should be deemed as that of the reporter himself/herself.

F. Guarantee on Future Business is not permitted promise

1. 1) Employees shall not receive employment, recommendations for employment, or contract conclusion offered by interested parties in carrying out their job functions.
2. 2) Any action performed by family members, relatives, or acquaintances should be deemed as that of the reporter himself/herself.

G. Infringement on other person’s property rights is not permitted

1. 1) Employees shall not use copies of illegal software for official business.
2. 2) Employees should not infringe a third party’s intellectual property rights (i.e.copyright, information on the internet, etc.).

H. illegal actions that take advantage of an employee’s position at the company are not permitted

1. 1) Employees shall not be engaged in unfair trade with any interested parties(other employees, customers, partners, etc.) by taking advantage of their superior position.
2. 2) Employees shall not abuse their authority for personal profits.
3. 3) Employees shall not request any future employment assistance, nor receive any offer of this nature.

I. Stock acquisition or employment by the company directly related to an employee’s job functions are not permitted

1. 1) Employees should not acquire shares of the company directly related to their job functions.
2. 2) Employees shall not be hired as an employee, executive, advisor or consultant of the company owned by the interested party.

J. Business with a company owned by EUSU ShipManagement employee is not permitted

1. 1) Business with a company owned by EUSU ShipManagement employee is not permitted.
2. 2) However, if the employee’s products or service has a patent that must be inevitably purchased by the company, the transaction is permitted after receiving a prior approval from the internal person in charge of ethical affairs.