EXMAR report 2025

3.4 GOVERNANCE 125 Furthermore, our Charter Party Agreements with our clients include regular sanction clauses but also tailor- made anti-bribery, anti-corruption and ethics clauses. In addition, relevant BIMCO clauses are included: clauses provided by the Baltic and International Maritime Council. As the world’s largest direct membership organization for shipowners, charterers, shipbrokers and agents, BIMCO provides information and advice while promoting fair business practices and facilitating harmonization and standardization of commercial shipping practices and contracts. Through the tools and expertise that we can leverage from this platform, we are able to reduce the risk of corruption and bribery by, for example, avoiding port calls to countries with a low score on the International Corruption Index. Lastly, each vessel has a class approved Ship Security Plan (SSP), aligned with the International Ship and Port Facility Security (ISPS) Code. The SSP details all procedures to ensure vessel, crew and cargo security. Key elements of such a plan focus on prevention, detection, response, recovery and compliance and include a threat assessment, risk mitigation strategies and response procedures. In addition, employees can always reach out to the Company Security Officer (CSO) (ashore) or a dedicated Ship Security Officer (SSO) (offshore), if needed. 3.4.3.3.1 Reporting process The process of reporting and investigating potential corruption or bribery is aligned with the policies mentioned above and the Compliance Model. A clear distinction is made between reporting, investigating, preventing and detecting. Investigations are separated from the chain of management involved in the prevention and detection of corruption and bribery. One way to report risks or the need for increased attention to a topic is through the Key Risk Officers, whose findings are subsequently reported to the Audit & Risk Committee and, in turn, presented to the Board of Directors. Like in 2024, in 2025, we had 0 convictions for violation of anticorruption and anti-bribery laws, resulting in 0 fines or penalties. 3.4.3.3.2 Training EXMAR’s policies and procedures are complemented with dedicated training, enhancing proper behavior regarding corruption and bribery. For office employees – including top management -, such training consists of a multiple-choice test through an e-learning tool, presenting a series of questions that describe business conduct situations (incl. potential corruption and/or bribery) in which one could find themselves. A minimum score must be achieved, and the training must be repeated every five years. The program was first implemented at our headquarters and is now progressively extended to all subsidiaries. Besides, our seafarers are also offered e-learnings, organized by MACN and provided on three levels: ratings, officers and masters. At EXMAR, we consider our top management (ExCo & BoD), captains and chief engineers (onboard) to hold functions-at-risk for corruption and bribery. Where for top management, this goes without saying; for captains and chief engineers this is due to their central role in interactions with shore-based entities, increasing the opportunities for corruption and bribery. As mentioned above, top management is expected to follow the same compliance training as the other office personnel. Captains and chief engineers, on the other hand, receive training by MACN. This is a new development rolled out during 2025, allowing these employees to interact with someone from MACN to discuss strategies to tackle corruption and facilitation payments. Employees can share experiences, while MACN provides practical tools to address these challenges effectively. Note that, in the report of 2024, the percentage of functions-at-risk that had completed their mandatory anti-corruption and anti-bribery training included all office personnel at our HQ in Antwerp. For 2025, the definition of functions-at-risk was revised and narrowed for office employees, including only Exco and BoD members (top management). To allow comparison between the percentages, a recalculation was made for 2024. The table below demonstrates the updated percentages for functions at risk that have received and completed their mandatory anti- corruption and anti-bribery training. 2024 - ORIGINAL 2024 - RESTATED 2025 62.91% 59.03% 81.94 % 3.4.3.4 POLITICAL INFLUENCE AND LOBBYING At EXMAR, we draw a clear distinction between direct political influence and lobbying efforts conducted through industry groups, ensuring that all engagements align with ethical standards and regulatory requirements. Our Compliance Risk Universe framework ensures robust oversight of political influence and lobbying activities. Thereby, we systematically assess and manage potential risks while maintaining transparency and accountability. The CFO is responsible for follow-up and communication with the ARC. In this context, it is relevant to mention our membership of several economic groups or sector groups, such as the Belgian Investor Relations Association VZW, Intertanko, Ammonia Energy Association, BIMCO, Voka, SIGGTO, Singapore Shipping Association and the Royal Belgian Shipowners Association (RBSA). These memberships could be considered as ‘lobbying’ in the broadest sense of the word. However, being a member only and not actively participating in external interactions,