Introduction
The Vision of our MVV is to become a company that is “indispensable for customers“, “selectedby customers“, and “grows together with customers”. The trust is the most important among
others, and it is essential for us to ensure compliance in order to maintain their trust. Not only
does ensuring compliance protect such trust, but it also leads to protection of individual employees.
As a member of society and a member of Mitsui & Co. group, we are pleased to comply with allapplicable laws and regulations having in our mind “With Integrity”, Mitsui & Co. Group
Business Conduct Guidelines which fosters a sense of integrity while promoting activities inaccordance with high ethical standards.
The Guidelines describe our basic policy on compliance and other related matters in a concise
manner. Let us fully understand and properly follow these guidelines in our business activities aswell as a private life.
Kazuhiro Okuma
President

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BUSINESS CONDUCT GUIDELINESFOR EMPLOYEES AND OFFICERS
OF ORIENT MARINE CO., LTD.
Enacted: January, 2003
Revised: December, 2004
Revised: February, 2021
Revised:April,2024
These guidelines apply to all employees and officers of Orient Marine Co., Ltd. (the“Company”). Whenever used in these guidelines, the expression “Employees” includes officers
and corporate auditors in addition to staff members (including secondees to and from theCompany, contract employees, and temporary employees), unless the context otherwise
requires.

1．Compliance with the Law and Integrity•Employees should comply with all applicable laws and regulations, whether domestic orforeign.

•Employees should maintain the highest levels of corporate and employee ethical standards,
and, as members of society, conduct themselves with sincerity, in a responsible manner andwith common sense and dignity.

2．Respect for Human Rights and Diverse Cultures•Employees should respect human rights and must not discriminate in any way whatsoever
between persons based on grounds of race, creed, sex, social status, religion, nationality, ageor physical or mental disability.

•Employees will not be the cause of any child labor, forced labor, etc. that may lead toviolations of human rights. In addition, employees will work together with our business
partners to ensure that they will not play any part in violations of human rights.

3．Office Environment and Harassment•

In order that Employees, with individuality and diversity, perform their duties for theCompany to the best of their ability, the Employees should respect the character and2

individuality of one another and make every effort to cultivate an open-minded corporate
culture, and to ensure that the office is an open and comfortable environment in which towork.
•The Employees should not harm, mentally or physically, a person or surrounding people
beyond reasonable range of work, based on advantages at workplace such as an official
position or human relations.

•The Employees should not engage in any sexual behavior against the will of a person orsurrounding people.

•The Employees should not treat others in a disadvantageous or detrimental way for thereason of pregnancy, giving a birth, and taking child-care leave or family-care leave, norengage in any behavior regarding these matters that is harmful to the workplace. In addition
to the foregoing, Employees should not exhibit any language or behavior that can beharmful to the working environment of other workers through any discriminatory act orharassment in the workplace, such as language or behavior that pertains to sexual
orientation or gender identity.

•Employees should not disturb the sound discipline, environment and good order of theoffice by conduct which is contrary to public order and good moral standards.

4．Health and Safety•Employees should place the highest priority on the health and safety of themselves and all
those connected with business activities of the Company, prevent occupational accidents,and protect their health and safety by creating a safe working environment.

•Employees should comply with all applicable laws and regulations regarding occupational
health and safety of each relevant country and region and constantly pursue and comply
with optimal safety standards for each business activity.

5．Compliance with Antitrust Law, etc.
•Employees should not conduct themselves in their dealings with the Company’s competitors
in a manner which results in an illegal restraint of trade, such as collusion with a view to thefixing of price levels or levels of production or supply or the division of markets.

•Employees should not collude with the Company’s competitors in any tender such asdetermining a successful bidder or contract price.

•Employees should not engage in unfair trade practices, such as boycotts, resale pricemaintenance or tie-in agreements.

3•Employees should not unreasonably damage the interests of sub-contractors of theCompany through the unjustified demand to reduce purchase prices, rejection to receive
goods, return of goods or delay of payment of purchase prices.

•Employees should promote fair, transparent and free competition, and carry out appropriate
business transactions that are compliant with the laws and ordinances observed in eachcountry or region.

6．Conflicts of Interest between Employees and the Company•

Employees should not participate in any activity which creates or appears to create aconflict between his or her personal interest and the Company’s business interest, such as
working for the competitors or the customers of the Company or dealing with the Companyfor their own behalf.

•Employees should not use the Company’s property, assets or information system for any
purpose other than that of the Company’s business.

•

Employees should not, without the prior consent of the Company, be engaged in any otheroccupation.

•Employees should not, without the prior consent of the Company, acquire any stock of thecustomers of the Company or the companies to which the Company makes, or is expected
to make, investment where such stock is not listed in any securities exchange.

•On the basis of personal relationships, whether inside or outside the Company and including
familial relationships, Employees should not act in a manner that conflicts with theCompany’s interests, such as by failing to perform their duties properly, nor should theyharm the working environment or motivation of other Employees, such as by causing doubt
in the workplace regarding the proper treatment of personnel.

7．Gift and Favor•

Employees should not render public officials or persons in a similar position any economic
favor such as money, gift or other favor, for the purpose of securing any improper advantage
or excess the range of normal social courtesies.

•Employees should not pay any agent, advisor or consultant any commission which they
have reason to know will be used for influencing public officials or persons in a similar
position in an unlawful manner.

•Employees should not render employees or officers of customers of the Company any
economic favor such as money, gift or other favor, the value of which is greater than a4

generally accepted commercial level at the relevant locale, nor should they receive sucheconomic favor from officers of customers of the Company.

8．Treatment of the Company’s Information•

Employees should hold any secret information of the Company, customer information andpersonal information as strictly confidential and should not divulge such information to any
third party, both during and after their employment with the Company, nor should they use
the same for any purpose other than that of the business of the Company.

•Employees should treat any secret information divulged by a third party as in the samemanner as they treat the secret information of the Company.

•Employees should not infringe the intellectual property rights of any third party, including
the copying of computer software, without express permission of such third party.

•Employees should actively and appropriately disclose in a timely manner any informationof the Company in accordance with any laws and regulations protecting the interests ofinvestors including the rules of any relevant stock exchanges.

•If Employees become acquainted with any information of the Company or its customers
which may materially influence the judgment of investors in the Company or in suchcustomers, they should not sell or purchase any stock of the Company or stock of suchcustomers unless and until such information becomes public and in any event Employees
should comply with all relevant insider dealing laws.

•Employees should not illegally acquire or use any secret business information of a thirdparty.

9．Compliance with Procedures for Export and Import, Applicable Laws and Attention toInternational Situations, etc.
•Employees should comply with the export and import procedures and not engage in theexport or import of prohibited goods.

•For the purpose of securing international peace and security, Employees should comply withnot only all applicable laws and regulations, but also with the internal rules, etc. of theCompany relating to security trade control when they export goods to any foreign countryor engage in other such transactions.

•Employees should understand the laws and regulations applicable to the business, goods
and services, etc. in which they are engaged, and comply with the procedures related to any
necessary permits and approvals.

•Employees should comply with applicable trade, investment and sanctions-related laws and5regulations when forming and executing transactions and business. Employees should also
cooperate with governments and related government agencies appropriately, and pay
sufficient attention to each country's policies and measures considering internationalsituations and economic security.

10．Company Funds, Financial Reporting and Meeting Tax Payment Obligations•Employees should properly manage the assets and funds of the Company and use them only
for appropriate business related purposes. Employees shall not establish or maintain
undisclosed or unrecorded assets or funds.

•Employees should make timely and appropriate accounting reports, ensuring the accuracyof the reports, and should not make any false or misleading entries in the Company’s books
and records.

•Employees should comply with the tax laws of each country and, in accordance with thespirit of the law, perform all obligations to pay taxes in an appropriate and fair manner.

11．Political Donation and Other Contributions•

When making a political donation or other such contribution to various entities, Employees
should clarify its purpose and social significance, and make such donation or contribution via
the use of a method that is appropriate, as well as ensure transparency while complying withapplicable laws and regulations.

12．Social Contribution•As good corporate citizens, Employees should make every effort to establish relationshipsof trust with all stakeholders of the Company with whom they have dealings for thecontinued improvement of corporate value, while carrying out their duties for the Company
and further should try, where possible, to make a positive contribution to the communities inwhich they perform such duties to contribute to the development of a sustainable society.

•Employee responsibilities should extend beyond economic contributions, and Employees need
to be globally active on a consolidated base in different fields, with emphasis on international
exchange (regional contribution), education (cultivation of human resources), and theenvironment.

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13．Protection of Environment•Employees should comply with all laws and regulations relating to the protection of theenvironment and strive to reduce the burden on the environment by paying maximum
attention to the efficient use of resources and energy.

•Employees should strive to consider the environment and to achieve the optimum balance
between economic benefit / return and environmental protection.

•Employees should contribute to the development and spread of environmentally friendly
technology and always take into consideration issues of safety.

14．Action against Antisocial Group•In the situation where an antisocial group makes unreasonable demands on the Company,
Employees should firmly refuse such demands and should not resort to an easy monetary
settlement.

•Employees should never deal with any antisocial group or any entity that is connected withsuch antisocial group.

•Employees should not become involved in any way whatsoever in any act of terrorism,
money laundering, the use of illegal substances, or any other such crimes.

15．Report and Sanction•

If an Employee finds evidence of violation of these guidelines, he or she should inform theChief Compliance Officer, the secretariat of the Compliance Committee, or his or hersuperiors.

•If an Employee desires to inform anonymously, he or she may do so to the designatedoutside lawyers or a third-party hotline described in the "Report / Consultation Route" asotherwise stipulated.

•Employees should cooperate in any investigation of such alleged violation. If, as a result of
the investigation, it becomes clear that there was a violation of these guidelines, sanctions
will be imposed on the violator or his or her superiors in accordance with the regulations ofthe Company.

•The Company ensures that no retaliatory action will be taken against an Employee for
informing of such violation or cooperating in such investigation and makes every effort toprevent such informant and any Employees cooperating in such investigation fromsuffering any disadvantage at his or her office. Any Employee(s) who treats the aforesaid

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Employees unfairly or retaliates against them shall be subject to disciplinary actions.

16．Revision or Abolition•Human Resources & General Affairs Dept. shall be responsible for these Guidelines. Anyrevision or abolition of the present rules shall require approval by the President of theCompany.

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