Explain the Company’s commitment to compliance with U.S. economic sanctions and the related requirements and obligations of all employees, officers, directors, and third parties acting on the Company’s behalf;
Describe the U.S. economic sanctions risks that the Company face;
Provide an overview ofS. economic sanctions and related penalties;
Explain the record-keeping requirements related U.S. economic sanctions compliance; and
Identify reporting procedures for potential or actual violations of law or this Policy.
The Policy is designed to familiarize all employees, officers, and directors, as well as its affiliated management companies with economic sanctions laws and regulations and provides guidance to ensure that you do not knowingly or unknowingly violate sanctions. Strict compliance with the Policy is required regardless of location, residency, citizenship or nationality.
Safe Bulkers takes very seriously all allegations of illegal or unethical conduct, including any violation of U.S. sanctions. All Company employees, officers, and directors must immediately report any potential, suspected, or actual violation of applicable law or its Policy to the CCO, including any suspected or actual violation of U.S. sanctions laws by the Company or any of its employees, officers, directors, Managers, agents or other third party business partners acting on the Company’s behalf.
If, for any reason, an employee feels uncomfortable reporting sanctions-related concerns to the CCO, the employee shall address their concerns directly to the President of the Company, or to the Company’s Whistleblower hotline at email@example.com. Submissions to the Whistleblower Hotline may be submitted anonymously and will be accessible only to the Company’s Audit Committee and outside counsel.
The Audit Committee, CCO and/or designees are responsible for investigating, or overseeing the investigation of, any information or allegations concerning possible violations of U.S. economic sanctions or its Policy. The Audit Committee and/or CCO will have authority to retain and consult with outside legal counsel to assist in carrying out their duties.