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Ethics Policy

Corporate Business Ethics Policy

Code of Business Conduct

September 2021, version 1.01

  • DYNAMARINe (the "Company") has an excellent reputation of conducting all of its business according to the highest principles of business ethics. We are proud of this reputation. We are committed to conducting our business activities with honesty, and in full compliance with the applicable laws and regulations. We also believe in treating our employees with the same principles. Our ethical principles are the values that set the ground rules for all that we do as management and employees of DYNAMARINe. As we seek to achieve responsible commercial success, we will be challenged to balance these principles against each other. In this respect the Company has set out a Code of Conduct, which is integrated into our Management System.

    All members of Company personnel (directors, managers, employees) have a clear understanding where the Company stands on basic ethical issues, so that all can act accordingly.

    The Business Ethics Policy sets down the guidelines for business conduct at DYNAMARINe. It is our firm intention that these standards and rules guide the actions of all personnel. We ask everyone to pledge his or her support to this important policy.

  • All DYNAMARINe personnel are responsible for their own professional behaviour. To ensure that all are able to deliver the highest standards possible, the company provide customized internal training in a continuous basis based on their individual training needs.

    All DYNAMARINe personnel are expected to use the Code to guide their behaviour at all times – whether at work or away from work, online or offline.

    The Code of Business Conduct was prepared to provide members of personnel, as well as those with whom we do business, with a formal statement of the Company's commitment to the standards and rules of ethical business conduct.

    All members of personnel are expected to review this Code, and in so doing, agree to comply with its principles1.This Code should be considered the basis on which each member of personnel conducts business on behalf of DYNAMARINe and is the cornerstone of DYNAMARINe's ethical business practices.

    This Code cannot cover all circumstances or anticipate every situation. Members of personnel, encountering situations not addressed specifically by this Code should apply the overall philosophy and ethical standards observed by honourable people everywhere.

    Situations that are not covered may be reviewed by managers, or as appropriate, senior management of the Company.

    DYNAMARINe has a policy against:

    1. Child Labour
    2. Uninsured employment
    3. Conducting business with sanctioned entities
    4. Unlawful transactions

    If, the company discover that any of her suppliers, service providers or even clients make use any of this practices, even on a case by case basis, will immediately take all the required measures to cancel their cooperation in a lawful and safe way, as soon as possible.


    1This Policy is being distributed to each during each enrollment of an employee who acknowledge its content and merits.

  • Following are the standards of professional behaviour each DYNAMARINe Personnel is expected to deliver.

    1. Honesty and integrity

    All personnel are expected to be honest and act with integrity at all times. This behaviour will not compromise or abuse their position.

    2. Authority, respect and courtesy

    All personnel are expected to act with self-control and tolerance, treating members of the public and colleagues with respect and courtesy. All personnel will use their powers and authority lawfully and proportionately and will respect the rights of all individuals.

    3. Equality and diversity

    All personnel are expected to act with fairness and impartiality. All personnel will not discriminate unlawfully or unfairly.

    4. Use of force

    All personnel are expected to use force as part of their role and responsibilities, and only to the extent that it is necessary, proportionate and reasonable in all the circumstances.

    5. Orders and instructions

    All personnel are expected to give and carry out lawful orders only, and will abide by Company Code of ethics.

    6. Duties and responsibilities

    All personnel are expected to be diligent in the exercise of their duties and responsibilities.

    7. Confidentiality

    All information collected by company’s services, are considered confidential and all personnel are expected to treat it only for the intended scope. Disclosure of confidential information, outside of the intended scope, is strictly prohibited

    8. Fitness for work

    All personnel are expected to ensure, when on duty or at work, that are fit to carry out their responsibilities.

    9. Conduct

    All personnel are expected to behave in a manner, whether on or off duty, which does not bring discredit at DYNAMARINe services or undermine client confidence.

    10. Challenging and reporting improper behaviour

    All personnel are expected to report, challenge, or take action against the conduct of colleagues which has fallen below the standards of professional behaviour.

  • The assets of the Company are to be used solely for the benefit of the Company and only for valid business purposes. The assets of DYNAMARINe are much more than our equipment, inventory, company funds, or office supplies.

    Our trustworthy assets include technologies, concepts, business strategies and plans, financial data, and other information about our business. These assets may not be improperly used to provide personal gain for members of personnel or others. Members of personnel may not transfer any of the assets to other people, except in the ordinary course of business.

  • As part of his/her job, a member of personnel may have access to confidential information about DYNAMARINe, its customers, suppliers and competitors.

    Until such material information has been made public, this information is not to be disclosed to co-workers who do not have a business need-to-know, nor to external physical or business entities for any reason except in accordance with established Company procedures, which may include confidentiality agreements when appropriate.

    Members of personnel may not use confidential information obtained on the job for personal financial gain through Company’s commercial activities or other personal financial transactions. "Confidential information" includes information or data on products, business strategies, information related to Principals, processes, systems, procedures, etc., as well as all financial data.

  • Members of personnel are expected to avoid any outside financial activity that might influence their work, company decisions or actions.

    Members of personnel are expected also to avoid outside employment or activities that materially decreases the performance, impartiality, judgment, effectiveness, or productivity expected from everyone on his or her job.

    Specifically,, they strictly avoid situations in which private interests’ conflict or interfere with their loyalty to the Company’s and her clients’ interests. Conflicts can arise from situations that may result in a direct benefit or from situations that have a negative impact on the Company. Examples of conflict of interest include the following situations:

    1. Using the position in the Company to hire family members or friends, including consultants;
    2. Making significant use of Company time or resources for private personal interests such as surfing the net or doing private mailings;
    3. Making significant use of Company time and resources for commercial activities not related directly to the Company;
    4. Using position in the Company to influence purchasing decisions for own interests.

    These situations are provided as illustrations, so this list is not complete.

  • DYNAMARINe obtains and keeps its business because of the quality and value of our services, and the respect and confidence we instil in our customers. Conducting business with suppliers and customers can pose ethical or even legal problems, especially in the sector the Company is involved in, where local laws and practices may be different from those with which we are familiar.

    The following guidelines are intended to help all members of personnel to make the "right" decision in potentially conflicting situations:

    1. Members of personnel may not accept neither offer gifts or money under any circumstances from and/or to suppliers or customers.
    2. Purchases or sales of goods and services must not lead to members of personnel or their families receiving personal rewards.
    3. Rewards may take many forms and are not limited to direct cash payments.

    In general, if a member of personnel stands to gain personally through the transaction, this is prohibited. Such practices are not only outside of the current code of ethics, but in many cases may be illegal. Payments or offers of benefit of any kind other than those included in standard marketing policies of the Company may not be made to customers or prospective customers as an inducement for them to buy our services.

    The use of DYNAMARINe's funds or assets for any purpose, outside the law or this Code, is strictly prohibited. Any payment which is improper when made by a member of personnel is likewise improper if made by another third party on behalf of DYNAMARINe, where DYNAMARINe knows or has reason to know that the payment to a third party is for any purpose other than that disclosed on the payment documentation.

    It is accepted as a reasonable business practice, members of personnel to offer or accept entertainment to or from customers, principals, suppliers in the course of normal business communication. However, offering or accepting entertainment, that is not a reasonable adjunct to a business relationship, but is primarily intended to gain favour or influence, should be avoided.

    Agreements with agents, sales representatives, or consultants must be in writing in Company’s standard format and must clearly and accurately set forth the services to be performed, the basis for earning the commission or fee involved, and the applicable rate or fee. These agreements should be completely transparent to the company.

    Any such payments must be reasonable in amount, not excessive in light of the practice in the trade, and commensurate with the value of the services rendered. In some countries, local laws may prohibit the use of agents or limit the rate of commissions or fees.

  • Communications with Competitors

    It is not illegal and may be appropriate for representatives of DYNAMARINe and its competitors to meet and talk during business events, conventions, fairs etc. In such conversations, comment on such topics as pricing, sales levels, marketing methods, inventories, business goals, non-public market studies, and any proprietary or confidential information shall be avoided. Discussions regarding customers must be limited to the exchange of credit information.

    About Competitors

    As a business that competes in the marketplace, DYNAMARINe may seek economic knowledge about its competitors. However, we will not engage in illegal or improper acts to acquire a competitor's trade secrets, customer lists, and information about company facilities, technical developments or operations. In addition, DYNAMARINe or any of her representatives, will not hire a competitor's employees for the purpose of obtaining confidential information, or urge competitors' personnel, customers, or suppliers to disclose confidential information, nor shall seek such information from competitors' employees subsequently hired by DYNAMARINe.

    Dealing With Each Other

    DYNAMARINe is committed in maintaining a positive constructive working environment where all members of personnel may pursue personal career satisfaction. Discrimination of any kind is not tolerated.

    Implementation

    This Business Ethics Policy outlines the way we want to treat others, as well as the way we want to be treated. All personnel are fully aware of this policy and are expected to adhere to it.

    Everyone is encouraged to consult with managers, as appropriate, prior to taking any action whenever the proper course of conduct is in doubt. Any failure to adhere to this policy may result in action, up to and including termination of employment.

    Such violations or any other inappropriate activity in the workplace may be reported to any member of management. The management of the Company shall always take appropriate action. Failure to report any violations of this policy, failure to cooperate with any investigation of any alleged violation of this policy or the submission of information that is known to be false in response to an investigation of any alleged violation of this policy is, in itself, a violation of this policy. Reprisal action against any member of personnel who in good faith reports suspected violation of this policy is not permitted, and any such reprisal actions will be deemed a violation of this policy. All managers are responsible for ensuring this policy is used to guide the actions of Associates. They are also responsible for investigating any alleged violations of the policy.

On Behalf of the Management