Policy Statement on Anti-Bribery, Sanctions, Export Control & Anti-Money Laundering
(Dated 22.01.2015)

This statement applies to M.C.L FEEDER (SERVICES) LIMITED (MCL) and to any individual or entity when acting for or on behalf of MCL, including but not limited to all representatives, contractors, sub-contractors, agents and agents subcontractors and other intermediates (“Third Parties”).

MCL remains fully committed to conduct its business in a professional ethical and lawful manner and act with integrity and in compliance with all applicable laws and regulations in force at any given point in time in any location.

All MCL and Third Party employees, officers, directors and contract workers, shall comply fully with all applicable laws and regulations. These include, but are not limited to:

• Laws in relation to anti-bribery.
• Laws and regulations in relation to economic sanctions and export controls.
• Laws and regulations in relation to anti-money laundering and countering the financing of terrorism.

We expect all Third Parties doing business with MCL to avoid participation in or knowingly benefit from any kind of corruption, extortion or bribery. Third Parties must not offer or promise, authorise or give anything of value to any public official in any country or to any business partner in order to gain any improper business advantage.

MCL will enforce compliance of this policy statement. Violations may result in criminal and civil exposure for MCL, any employees and Third Party involved, and can cause significant damage to MCL’s reputation in the market place. MCL will not tolerate that any of its Third Parties violates this statement and will on a regular basis screen and ensure that its Third Parties comply with applicable laws and regulations when acting for or on behalf of MCL.

We expect that all parties with whom MCL does business will confirm that they in all respects will adhere to the principles as set out in this policy statement. If Third Parties do not have adequate procedures to safeguard compliance with MCL Policy MCL will not be interested in doing business with them. If MCL suspects that any of the Third Parties has been or may be involved in any act of bribery or corruption or any other violation of this Policy and relevant laws and conventions it shall take the appropriate steps which may lead to early termination of commercial relationships.

We all have the responsibility to help detect, prevent and report instances of bribery and money laundering. If you have a concern regarding a suspected instance of bribery or corruption, please speak up – your information and assistance is appreciated and needed.

If you have any concerns, please contact the Company Secretary, Pavlitsa Nerouppou via email ()

Should you have any questions about these procedures or concerns, please contact me via e-mail ()

Matthias Geissler
Managing Director