Code of Ethics

1. Applicability and binding effect

1.1. This Code applies to all directors, officers, employees, subcontractors, consultants, representatives, and any third party acting for or on behalf of CARGOWARD (“Covered Persons”), in Brazil and internationally.

1.2. Compliance with this Code is a condition of engagement. Covered Persons must comply with applicable laws, port/terminal rules, vessel procedures, and any authority instruction. Where standards differ, the more stringent requirement applies unless prohibited by law.

1.3. This Code complements (and does not replace) CARGOWARD’s Terms and Conditions, HSQE controls, permit-to-work discipline, and data protection policies.

2. Core principles (operational standards)

CARGOWARD’s ethics are operational controls. Covered Persons must act with:

• Lawfulness: comply with all applicable laws and authority requirements.

• Integrity: no misrepresentation of scope, capability, evidence, or outcomes.

• Traceability: maintain complete records, approvals, and evidence packs where applicable.

• Safety discipline: stop work when unsafe; no schedule pressure overrides safety.

• Environmental responsibility: prevent pollution; maintain waste governance and documentation.

• Respect: professional conduct with crew, terminals, authorities, and colleagues.

3. Legal and regulatory compliance (multi-jurisdiction posture)

3.1. Covered Persons must comply with all applicable legal requirements relevant to maritime and port operations, including customs, immigration, port security, occupational safety, environmental controls, and local terminal procedures.

3.2. Where services interface with international frameworks (e.g., IMO conventions such as SOLAS and MARPOL, and safety management expectations aligned with the ISM Code), Covered Persons must support compliance by maintaining evidence-based execution and accurate documentation.

3.3. If any instruction appears unlawful, unsafe, or inconsistent with port/terminal rules, Covered Persons must refuse the instruction and escalate internally.

4. Anti-corruption, bribery, facilitation payments (zero tolerance)

4.1. CARGOWARD prohibits bribery, kickbacks, improper advantages, and facilitation payments.

4.2. Covered Persons must not offer, authorize, promise, request, or accept anything of value to influence a decision, accelerate approvals, or obtain business.

4.3. This applies to all third parties, including agents, intermediaries, vendors, and consultants. Indirect misconduct is treated as misconduct.

4.4. Any extortion attempt or suspicious request must be documented and reported immediately.

5. Sanctions, restricted parties, and compliance screening

5.1. Covered Persons must comply with applicable sanctions and trade restrictions. Where required, CARGOWARD may conduct KYC and restricted-party screening.

5.2. If a compliance concern arises, services may be paused pending review. Covered Persons must cooperate with compliance requests.

6. Conflicts of interest and independence

6.1. Covered Persons must avoid conflicts of interest that could compromise operational integrity, procurement decisions, or client trust.

6.2. Conflicts include: financial interests in vendors, undisclosed relationships affecting decisions, outside roles with competitors, or personal benefits tied to nominations or approvals.

6.3. Conflicts must be disclosed promptly. Mitigation may include recusal, reassignment, or termination of engagement.

7. Gifts, hospitality, entertainment, and travel

7.1. Any gift or hospitality must be modest, lawful, and appropriate, with a legitimate business purpose, and must not influence (or appear to influence) decisions.

7.2. Cash, cash equivalents, personal travel, and lavish hospitality are prohibited.

7.3. When in doubt, decline and report.

8. Fair competition and antitrust conduct

8.1. CARGOWARD competes based on capability, compliance, and execution discipline.

8.2. Covered Persons must not: price-fix, coordinate bids, allocate customers/territories with competitors, share confidential pricing information, or obtain competitor information improperly.

9. Record integrity, documentation governance, and auditability

9.1. Documentation is a core control in maritime operations. Covered Persons must ensure records are accurate, complete, and timely, including: work logs, checklists, permits (where applicable), safety briefings, attendance records, disposal evidence (where applicable), and client-facing reports/certificates.

9.2. Falsification, backdating, omission of material facts, or manipulation of photos/videos is strictly prohibited.

9.3. If evidence cannot be obtained due to operational constraints (visibility, access, safety), records must state such limitations clearly.

10. Safety, permit-to-work, and stop-work authority

10.1. Covered Persons must comply with permit-to-work controls applicable to shipboard and terminal environments, including confined space entry, hot work, work at height, and lifting operations.

10.2. Any Covered Person has authority to call a stop-work when conditions are unsafe. Stop-work decisions must be respected and escalated for review.

10.3. Safety-critical decisions must be documented where practicable.

11. Tank cleaning, gas-free readiness, and confined space controls

11.1. Tank entry and cleaning operations may involve hazardous atmospheres. Covered Persons must ensure strict adherence to isolation, ventilation, gas monitoring, and rescue readiness as required by the vessel/terminal safety system.

11.2. Any “gas-free” statement, measurement, or certificate (if issued) must be time- and location-specific, evidence-based, and never treated as a continuing guarantee.

12. Cargo hold cleaning: integrity of readiness statements

12.1. Cargo hold cleaning involves variable vessel geometry (e.g., tank tops, bilges, frames, upper areas, hatch covers) and cargo history. Covered Persons must represent readiness status based on documented scope performed and observed conditions.

12.2. Acceptance by surveyors, charterers, terminals, or cargo interests must never be misrepresented or implied as guaranteed unless expressly agreed in writing and supported by evidence.

13. Environmental protection and waste governance

13.1. Covered Persons must prevent pollution and comply with port/terminal environmental rules and applicable MARPOL-related expectations.

13.2. Waste, residues, sludge, and chemicals must be handled with containment, traceability, and documentation consistent with operational requirements and available disposal channels.

13.3. Any spill, near-miss, or environmental incident must be reported immediately and documented.

14. Underwater operations: evidence, constraints, and transparency

14.1. Underwater inspection/cleaning work is constrained by visibility, currents, sea state, access limitations, and port authorizations.

14.2. Covered Persons must report limitations transparently and ensure underwater evidence (photos/videos) is authentic and traceable.

15. Confidentiality, client data, and information security

15.1. Covered Persons must protect confidential information, including vessel schedules, port access credentials, client commercial terms, and operational evidence packs.

15.2. Personal data (e.g., boarding lists, IDs, contact information) must be handled lawfully, shared only on a need-to-know basis, and protected using appropriate safeguards.

15.3. Suspected data loss, unauthorized access, or security incidents must be reported immediately.

16. Respectful workplace, human rights, and professional conduct

16.1. CARGOWARD requires professional conduct at all times. Harassment, discrimination, intimidation, and abusive behavior are prohibited.

16.2. CARGOWARD rejects forced labor and human trafficking and expects partners and vendors to uphold equivalent standards.

17. Third-party conduct, vendor controls, and subcontractor governance

17.1. Vendors, subcontractors, and representatives must operate under equivalent ethical and compliance standards.

17.2. Covered Persons must not engage third parties known or suspected to violate laws, safety standards, or ethical requirements.

17.3. Where third parties perform work, selection, oversight, and documentation controls must be applied consistent with operational risk.

18. Reporting concerns and non-retaliation

18.1. Any suspected violation of this Code must be reported promptly to contact@cargoward.com or the relevant manager.

18.2. CARGOWARD prohibits retaliation against anyone who reports concerns in good faith or participates in an investigation.

18.3. Reports should include relevant facts, dates, involved parties, and any supporting evidence.

19. Investigations, corrective action, and enforcement

19.1. CARGOWARD may investigate suspected violations and take corrective action, including retraining, suspension of access, termination of engagement, contract termination, and referral to authorities where required.

19.2. Failure to cooperate with an investigation may itself constitute a violation.

20. Training, acknowledgment, and updates

20.1. Covered Persons may be required to complete periodic compliance, safety, and data protection training.

20.2. This Code may be updated to reflect regulatory changes, operational learnings, and governance best practices. The “Last Updated” date indicates the current version.