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Remuneration Policy

Our staff members are remunerated on the basis of a fixed salary in line with market conditions. (Depending on the position and assessment there is the possibility that our staff members receive a partial, limited and maximized variable remuneration). We direct our staff to act ethically, with due care and customer-oriented, focusing on the interests of our clients and our company in the long term. The assessment of these conduct requirements determines both the amount of the fixed and of the variable income of our staff members.

Data Protection and Privacy

This data protection policy applies to EF Marine which is established in Singapore and has a subsidiary office in Netherlands (“EFM” or “we”). As a global company, it is the policy of EFM to fully comply with the requirements of the EU General Data Protection Regulation (Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 – “GDPR”), the Singapore Personal Data Protection Act 2012 (PDPA), and all relevant data protection regulations in the jurisdictions in which we operate. We have appropriate data protection compliance framework in place to protect the personal information we are controlling or processing in connection with the services we are providing. Who we are? EFM is a specialized Marine Underwriting Agent with its head office in Singapore and a subsidiary office in the Netherlands. Our Clients typically are Shipowners, Ship Operators, Charterers of vessels, Freight Forwarders and Port Operators. EFM need to process personal data to manage insurance policies and settle claims. Our contact details can be found at https://efmarinegroup.com/contact Our Supervisors The Personal Data Protection Commission (PDPC), Singapore The European Data Protection Supervisor (EDPS) Dutch Data Protection Authority (DPA), Netherlands Personal Data Definition ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’)”. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Our policies and standards EFM handles personal data with the greatest care and use it only for legitimate and specified business purposes. We respect the privacy rights of EFM's employees, customers, clients, business partners and other individuals whose personal data we have and use. We protect personal data by implementing appropriate technical and organisational measures in our data processing operations. We obtain personal data fairly and only use it for legitimate business purposes. We hold ourselves accountable for demonstrating compliance with applicable legal and regulatory requirements and understanding of our roles and responsibilities. These principles are applicable to all EFM's entities worldwide. They are derived from internationally recognized privacy principles as well as the foundational principles of the European Union's (EU) General Data Protection Regulation (GDPR) and the Singapore Personal Data Protection Act (PDPA). We take care to understand relevant laws and regulations and assess the risks that arise as personal data is processed in our global operations. Our role as a data controller What kind of personal data do we process? We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information. Information about you – for example name, age, gender, date of birth, nationality. Contact information – in some cases, for example, we may receive your email, address, postcode and phone number. Online information – for example cookies and IP address (your computer’s internet address), if you use our websites. Financial information – we may process information related to payments you make or receive in the context of an insurance policy or claim. Contractual information – for example details about the policies you hold and with whom you hold them. We also might collect data falling within the Special Category of personal data as per GDPR regulation (Art. 9, 2 (f)). EFM processes health information as e.g. medical records, diagnosis and description of injury/illness when needed to handle personal injury/illness claims. This information will only be used for the specific purposes for which it was provided and to carry out agreed service. Why do we process this data? We use personal data for the following purposes: Performance of financial crime and sanctions screening Assessment of underwriting risk and provision of underwriting service Collection of sums due, accounting, invoicing, and payment processing Performance of claims investigations and meeting claims obligations Loss prevention assessment Marketing and promotion of our services and products Establishment and maintenance of relationships between our service providers (including professional advisors), auditors, clients, and employees General management and reporting purposes, such as invoicing and account management Legal and regulatory compliance To maintain our records and accounts All other purposes related to our business Who do we share personal data with? Our employees have access to and process personal data based upon a "need to know" basis in order to do their job. We regularly check who has access to our systems and data. We may also share personal information with the following third parties, some of which are based in other countries: Our service providers and agents e.g. IT companies who support our technology. Our professional advisers: auditors; reinsurers; medical agencies and legal advisers. The client who provided us with your data. When applicable, we apply cross-border rules in line with European data protection laws and regulations. So, if any personal data needs to be processed by internal services teams or by third parties outside the EU, we make sure adequate safeguards are in place with those internal and external parties. We typically do this by using EU model contract clauses to make sure this processing also complies with EU data protection laws and regulations. How long we keep personal data? We keep your personal information for as long as necessary for dealing with any dispute or proceeding, for regulatory or compliance reasons, to monitor and evaluate the performance of our services and products or for other associated historical reasons. We will store personal data in compliance with the GDPR’s data minimization and storage limitation principles. This means it will be safely stored digitally in a specific folder with limited access. Only the persons directly dealing with the data for the intended purpose (for example handling of a claim) will have access to the folder. If it is stored physically it will be stored in a separate locked closet with restricted access. Personal data will be deleted once it is no longer needed for the purpose for which it was originally collected, unless we have other lawful grounds or legal obligations to retain it. Further notes on our implementation of the GDPR Many of the disclosures and safeguards required by the EU's GDPR reflect widely accepted standards and laws which apply around the globe and are described throughout this document. In addition, we also set forth here additional information required by the GDPR. What are our legal grounds for processing personal data? We only process personal data for legitimate business purposes and when a legal ground as set out in data protection law is applicable. There are a number of legal grounds that may apply, and the table below describes the ones most likely to be relevant to you. Consent - We may process your personal data when we obtain your consent or when our client obtains consent from you. Contractual necessity - Your personal data may be processed on the basis that such processing is necessary to enter into or perform a contract with you. Compliance with a legal obligation - Your personal information may be processed where we have a legal obligation to perform such processing, such as where we share information with our regulators, law enforcement agencies of the courts. Necessary for an insurance purpose - The laws that implement GDPR include legal ground for processing your medical and other sensitive personal data when it is necessary to do in connection with an insurance product, in particular the handling of claims. Legitimate interests - when we have a legitimate interest in so doing and we can demonstrate that our interests are not outweighed by your rights or interests. Your GDPR (EU) privacy rights Under GDPR you have the following rights regarding our processing of your data: Access your data - You have the right to file a subject access request (SAR) to obtain a copy of your personal data as well as other supplementary information. We have a legal obligation to give effect to the rights of data subjects. Rectify your data - You have the right to require us to have inaccurate personal data, which is processed by, or on behalf of us, rectified, or completed if it is incomplete. This may involve providing a supplementary statement to the incomplete data. Have “portability” of your data - you can ask us to send your personal data to either you or another organization in a structured, commonly used and machine-readable format (portable format) provided that (1) the processing is carried out by automated means and (2) the processing is based on your consent or on the performance of a contract with you. Right to object - You have the right to object to the processing of personal data that is collected on the grounds of legitimate interests or the performance of a task in the interest/exercise of official authority. The right to object only applies in certain circumstances. Whether it applies depends on the purposes for processing and the lawful basis for processing. Prevent marketing - You have a specific right to object to our use of your information for direct marketing purposes, which we will always act upon. Restrict processing - In certain circumstances in which the relevant personal data either cannot be deleted or where you do not wish to have the data deleted, we may continue to store the data, but the purposes for which the data can be processed will be strictly limited (e.g. the exercise or defence of legal claims). Right to be forgotten - You can ask us to delete your personal information if deleting your data is not in conflict with our legal and regulatory obligations. If we are using consent to process your information and you withdraw it, you can ask us to erase your information. Object to automated decision making - You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. If you wish to exercise any of the rights set out above, you must make the request in writing to the Data Protection Officer (details below). Please note some of these rights are restricted in some circumstances. If you have provided your consent to any of the processing of your personal data, you have the right to withdraw your consent to that processing at any time, where relevant. Please contact the Data Protection Officer if you wish to do so. If you object to processing based on legitimate interests, we must no longer process that personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or that the processing is required for the establishment, exercise or defence of legal claims. If you are unhappy with how we process your personal data you have the right to complain to a data protection regulator or supervisory authority. The list of data protection regulators can be found at: https://edpb.europa.eu/about-edpb/board/members_en DATA PROTECTION OFFICER All requests can be sent to: Kelsi Deng, Data Protection Officer Email: dataprotection@efmarinegroup.com EXERCISING YOUR RIGHTS If you wish to exercise any of the rights set out above, you must make the request in writing to the Data Protection Officer (details above). Please note some of these rights are restricted in some circumstances. We will revert with the requested information without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by you. If you have provided your consent to any of the processing of your personal data, you have the right to withdraw your consent to that processing at any time, where relevant. Please contact the Data Protection Officer in writing if you wish to do so. If you object to processing based on legitimate interests, we must no longer process that personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or that the processing is required for the establishment, exercise or defence of legal claims.

EF Marine announces strategic alliance with Swiss Re Corporate Solutions

EF Marine announces strategic alliance with Swiss Re Corporate Solutions to offer Fixed Premium Protection and Indemnity (P&I) insurance to cover increasingly complex marine risks. EF Marine (EFM) teams up with Swiss Re Corporate Solutions to further penetrate the Fixed Premium Protection & Indemnity (P&I) sector. This agreement will support small to medium size companies active in the marine logistics chain by offering tailor-made solutions to manage increasingly complex marine risks. The alliance offers Ship Owners, Charterers and MultiModal operators access to a wide range of insurance products and outstanding service, backed by Swiss Re’s brand and financial strength. Singapore, 27th December 2018 – EF Marine is pleased to announce a Managing General Agent (MGA) agreement with Swiss Re Corporate Solutions effective January 1, 2019. The alliance between Swiss Re Corporate Solutions and EF Marine will be an excellent proposition to the market, providing a partnership that will be beneficial to small and medium sized Ship Owners, Charterers and Multimodal operators globally. Edwin Li, Managing Director at EF Marine, says: ‘We are happy to be working with Swiss Re Corporate Solutions. Our underwriters have in-depth knowledge of clients’ businesses and are supported by skilled claims professionals who are determined to provide quick solutions and 24/7 emergency response assistance. By working with Swiss Re Corporate Solutions, we can offer our clients some of the largest capacities in the market from one of the largest and financially secure (re)insurance companies in the world.” With the strong growth in the Asia Pacific maritime industry, there is a trend of ship owners moving from classic mutual insurance model towards fixed premium P&I due to the increasingly complex marine risks. These risks include increased trade transparency, competition and regulatory pressures, which expose charterers to new liabilities that require high level of specialization and service from insurers. “Combining EF Marine’s best-in-class P&I capabilities and expertise with our capacity and flair for innovation, will allow us to deliver tailor-made solutions to a fast evolving sector that faces new liabilities and more complex risks,” states Peter Schraa, Head of Marine Cargo, APAC. “We’re excited to partner with EF Marine to expand our product range beyond Cargo, Project Cargo and Hull and Machinery covers.” About Swiss Re Corporate Solutions Swiss Re Corporate Solutions provides risk transfer solutions to large and mid-sized corporations around the world. Its innovative, highly customised products and standard insurance covers help to make businesses more resilient, while its industry-leading claims service provides additional peace of mind. Swiss Re Corporate Solutions serves clients from over 50 offices worldwide and is backed by the financial strength of the Swiss Re Group. Visit corporatesolutions. swissre.com or follow us on linkedin.com/company/swiss-re-corporate-solutions and Twitter @SwissRe_CS. About EF Marine EF Marine is a fixed premium P&I specialist. Through a team of highly skilled marine professionals in Singapore (head office) and Rotterdam offering a combined P&I experience of over 150 years, EF Marine has profound knowledge of complex marine risks. With a global reach, broad range of products and deep understanding of the marine logistical supply chain EF Marine works closely together with its clients and brokers. By doing so it provides unrivalled service and real tailored solutions. The combination of EF Marine’s strengths, and the exclusive and long-term support of Swiss Re, makes EF Marine a market leader from the start. EF Marine | Ensuring the Future, Your Future – www.EFMarineGroup.com For Media enquiry: Mileage Communications Pte. Ltd. Ms Patsy Phay Email:patsy@mileage.com.sg Tel: +65-62 22 16 78

EF Marine approved in India

We are pleased to advise that we are now an approved insurance provider for the purpose of the Indian Merchant Shipping (Regulation of Entry of Ships into Ports, Anchorages and Offshore facilities) Rules, 2012. The evidence of the approval can be found on the website of the Directorate General of Shipping (DG Shipping). WHY IS THIS APPROVAL IMPORTANT? The Merchant Shipping (Regulation of Entry of Ships into Ports, Anchorages and Offshore facilities) Rules, 2012 came into force on 20 April 2012. From that day on it is required that that any vessel of 300 GT or more, which are not Indian flagged, must be adequately insured against maritime claims when entering or leaving ports, terminals, anchorages or seeking port facilities in Indian territorial waters. Operators of vessels will need to evidence that they have a valid Protection and Indemnity (P&I) insurance against maritime claims from an insurance provider approved by the Government of India. The P&I insurance must be valid during the vessels stay in the port areas or offshore terminal under the jurisdiction of India or areas in the Coastal Waters of India. Without it, vessels are not allowed to enter or leave Indian territorial waters or facilities governed by Indian jurisdiction. WHAT DO I NEED TO DO WHEN I WANT TO ENTER/LEAVE INDIAN WATERS WITH MY VESSEL? The vessel’s agent will need to submit a valid P&I certificate of an approved insurance provider (together with the Blue Cards, if applicable) to the relevant Port Authority which in turn will grant approval. WHAT DO I NEED TO DO WHEN I ENCOUNTER ISSUES WITH THE PORT AUTHORITY? In the unlikely situation that you are encountering issues with an Indian Porth Authority, you can contact our readily available 24/7 emergency service at +65 62 38 75 59, or you can contact one of our approved P&I Correspondents. An overview of our P&I Correspondents in India can be found here. QUESTIONS? Should you have any questions following this information, please do not hesitate to contact us. Our contact details can be found here. ABOUT EF MARINE EF Marine provides Fixed Premium P&I solutions to Shipowners, Charterers and MultiModal operators. EF Marine have a global client base and offices in Singapore and Rotterdam. EF Marine provide ‘AA-‘ rated security from Swiss Re with limits up to USD 500m. Through our partnership with Swiss Re we provide our clients with first class security combined with EF Marine’s extensive knowledge of the P&I market.

Shipowners’ P&I

Main risks as a Shipowner   Liability to cargo – when entering a charter party and/or issuing a Bill of Lading for transporting cargo(es) on your vessel you take on contractual liabilities. Shortage of, damage to or perhaps even non-delivery of cargo(es) are some of the liabilities you may be confronted with. Our cover protects you against those and various other liabilities related to cargo. Illness, Personal Injury, Death – hopefully not something you will be confronted with, but a ship can be a dangerous working place. When a member of your crew becomes ill, injured or even worse, dies on board of your vessel, you will have a liability under the crew contract (or in tort) to that crew member or his/her next of kin. Other persons will also board your vessel. Surveyors, pilots, passengers, customs, stevedores to name a few. You will not have an employment contract with them, this however does not mean that you will not be liable if something happens to them on board of your ship. Our cover protects you against those and various other liabilities related to crew members and other persons. Third party liability – Third Party liability is your responsibility to an individual or a company for any errors caused by the you or your crew resulting in financial loss to that individual or company. Examples of this type of liability can be seen in pollution, collision claims, wreck removal as well as personal injury claims. Liability for Costs – costs, which must be made to defend a liability claim are covered. The costs that are regularly incurred are survey expenses and lawyer fees. Even if you are not liable you can be held liable. Full details of this insurance (including applicable limits) can be obtained on request.      

COVID-19 | UPDATED GUIDANCE FROM THE INTERNATIONAL CHAMBER OF SHIPPING (ICS)

The International Chamber of Shipping (ICS) has issued an updated Guidance for Ship Operators for the Protection of the Health of Seafarers. This best practice was issued to help protect the health of seafarers and passengers as well as the general public. The Guidance is for use on all types of ship and tries to consider the needs of both cargo and passenger ships. It is recognized that cargo ships are unlikely to have a fully trained doctor or nurse on board and that medical treatment on cargo ships will be provided by a crew member with training to STCW medical requirements. Because a ship is a closed environment, after being at sea for 14 days or more, and if no seafarers show signs of illness, a ship may be considered as free from COVID-19 and therefore safe. Any crew change or visit from shore-based personnel, including a pilot, may introduce the virus on board despite best practice quarantine and testing. Seafarers should therefore remain vigilant for the symptoms of COVID-19 in themselves and others and report such symptoms immediately to the person responsible for medical care on board. A copy of the full Guidance can be found at https://www.ics-shipping.org/docs/default-source/resources/covid19-guidance-for-ship-operators-for-the-protection-of-the-health-of-seafarers-v3.pdf?sfvrsn=4 Further guidance documents and posters in various languages can be found at https://www.icsshipping.org/free-resources/covid-19 QUESTIONS? Should you have any questions following this information, please do not hesitate to contact us. ABOUT EF MARINE EF Marine provides Fixed Premium P&I solutions to Shipowners, Charterers and MultiModal operators. EF Marine has a global client base and offices in Singapore and Rotterdam. EF Marine provides ‘AA-‘rated security from Swiss Re Corporate Solutions with limits up to USD 500m. Through our partnership with Swiss Re Corporate Solutions we provide our clients with first class security combined with EF Marine’s extensive knowledge of the P&I market.

United States Ramps Up Sanctions Pressure on Venezuela with Issuance of Executive Order 13884

For more than a decade, the United States has employed sanctions in responsive to activities of the Venezuelan government and Venezuelan individuals. The US measures against the government of Venezuela were significantly extended in January 2019 as US imposed sanctions on Venezuela’s state-oil company Petroleos de Venezuela, S.A. (PdVSA). On 5 August 2019, a further significant development took place with the issuance of the Executive Order (EO) 13884. The EO, entitled ‘Blocking Property of the Government of Venezuela’, is designed to further increase pressure on the Nicolás Maduro regime by blocking all property and property interests of the Government of Venezuela under US jurisdiction, and by authorizing the Department of Treasury to sanction additional persons who have assisted or supported the Government of Venezuela, including through the provision of goods or services. The full text of the EO can be read at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/13884.pdf On August 6, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended several existing general licenses and issued numerous general licenses authorizing a number of activities. OFAC also issued new frequently asked questions, FAQs no.665-681. IMPACT ON US PERSONS EO 13884, although not a full embargo, broadly prohibits virtually all US Persons from dealings and transactions with the Government of Venezuela, including all Venezuelan state-owned enterprises. US Persons includes US companies, their branches, US banks, citizens and green-card holders, as well as any person when they are physically located in the United States. Any funds, property, contracts or other property interests that come into the possession or control of US Persons must be blocked and reported to OFAC. The EO includes a broad definition of the Government of Venezuela which is, as follows:  ‘The state and Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (PdVSA), any person owned or controlled, directly or indirectly, by the foregoing, and any person who is acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime.’ OFAC FAQ no. 680, issued on August 6, clarifies that the above definition of the government of Venezuela expressly excludes the Venezuelan private sector. The FAQ states that without specific authorization from OFAC, US persons are generally prohibited from engaging in transactions with the Government of Venezuela or entities in which the Government of Venezuela owns, directly or indirectly, a 50% or greater interest (which includes PdVSA), even if those entities are not specifically named on the US Specially Designated Nationals and Blocked Persons List (SDN List). IMPACT ON NON-US PERSONS EO 13884 also provides that any non-US person determined to have material assistance to, or goods or services in support of, the Government of Venezuela, its agencies and any entity in which it holds a 50% or greater interest could itself be sanctioned and have its property in the United States blocked. Regarding whether the provision of ocean transportation could be considered either ‘material assistance’ or ‘service’ in support of an entity whose property is blocked under the EO, legal firm Freehill Hogan & Mahar LLC suggested that it would certainly seem conceivable that OFAC could make this determination and comments by US National Security Advisor John Bolton suggest that Executive Order 13884 could be construed broadly. The client alert issued by FHM can be read at https://www.freehill.com/wp-content/uploads/2019/08/ NYDOCS1-509645-v1-Client_Alert_on_Venezuela_-_Executive_Order_138841.pdf OUR RECOMMENDATION Due to the broad reach of US sanctions and the punitive consequences of breaching this EO, both US and non-US persons should proceed with extreme caution when considering whether to engage in any business which could be deemed providing material assistance or goods/services in support of the Government of Venezuela or entities in which the Government of Venezuela owns, directly or indirectly, a 50% or greater interest (which includes PdVSA). We also recommend clients to evaluate their current dealings involving Venezuela and conduct thorough due diligence to ensure that they are not at risk of breaching sanctions. If you have any queries, please do not hesitate to contact us.

Clarification on the scope of EU Ban on Russian Coal and Fertilisers

On the 10th August 2022, the EU published new FAQs with the aim to clarify the application of provisions regarding the carriage of coal and other solid fossil fuels as well as certain types of fertiliser. Through these clarifications, it has become clear that the sanctions will have a much wider impact on the entities involved in the carriage of these commodities than initially presumed. The ban was adopted by the EU on 8 April 2022, as part of a fifth package of sanctions against Russia in response to Russia’s military aggression against Ukraine, following a wind-down period of four months. The package was implemented by amendments of Council Regulation (EU) No 833/2014 (“Reg 833”) and contains the following restrictive measures: Purchase, import, or transfer bans on goods listed in Annex XXI pursuant to Art 3i of Reg 833 (e.g. Russian coal and other solid fossil fuels, wood); Purchase, import or transport bans on goods listed in Annex XXII rt 3j of Reg 833 (e.g. coal products) The texts of Annex XXI and Annex XXII as referred to above can be found in Council Regulation 2022/576. https://eur-lex.europa.eu/eli/reg/2022/576/oj It was widely interpreted at the time the regulations were adopted that these restrictions only prohibited the purchase, import or transfer of the mentioned products where they were destined for an EU Member State. The actual scope is wider as clarified below. On 17 April 2022, the EU issued a FAQ. Whilst it made clear the definition of ‘transfer’, which includes “not only the movement of goods through customs controls, but also the transport of goods, including (but not exhaustively) their loading and trans-shipment”, the prohibition still ostensibly required goods to be destined for the EU. On 14 June 2022, the EU published a further FAQ which sought to clarify that EU companies were restricted from purchasing restricted Russian-origin goods regardless of its destination. This was interpreted that only that EU entities were prohibited from purchasing such Russian cargoes intended for delivery both into and outside the EU, but not otherwise being involved in their carriage. However on 10 August 2022, the EU issued a revised FAQ which states “The prohibition on transfer applies irrespective of the final destination of the goods, whereas the prohibition on the import applies by nature to goods moving ‘into the Union’. Provided the transfer falls within the scope of Article 13 of Council Regulation 833/2014, it is not relevant whether the goods are destined for the EU or not.” The scope of Article 13 of Council Regulation 833/2014 as referred to above is: within the territory of the Union; a) on board any aircraft or any vessel under the jurisdiction of a Member State; b) to any person inside or outside the territory of the Union who is a national of a Member State; c) to any legal person, entity or body, inside or outside the territory of the Union, which is incorporated or constituted under the law of a Member State; d) to any legal person, entity or body in respect of any business done in whole or in part within the Union. This means, with immediate effect, EU persons are now clearly prohibited from: purchasing coal products (as listed in Annex XXII) and certain fertiliser products (as listed in Annex XXI) of Russian origin or that are exported from Russia; transporting such goods irrespective of their destination; and importing such goods into the EU. As an entity subject to the jurisdiction of the EU, EF Marine is prevented from providing insurance and reinsurance for the carriage of any of the above mentioned type of cargoes as “insurance and reinsurance service” are included by the EU in the provision of “financial assistance” in sections (2)(b) of both Article 3i and 3j. We strongly advise shipowners and charterers’ to conduct self-checks on all parties involved in the transport of coal, fossil fuel and fertilisers, especially shippers, consignees and cargo owners, to ensure there is no exposure to sanction risks. QUESTIONS? Should you have any questions following this information, please do not hesitate to contact us. ABOUT EF MARINE EF Marine provides Fixed Premium P&I solutions to Shipowners, Charterers and MultiModal operators. EF Marine has a global client base and offices in Singapore and Rotterdam. EF Marine provides ‘AA-‘rated security from Swiss Re Corporate Solutions with limits up to USD 500m. Through our partnership with Swiss Re Corporate Solutions we provide our clients with first class security combined with EF Marine’s extensive knowledge of the P&I market.

COVID-19 | IACS POSITION ON SURVEYS

Due to the COVID-19 pandemic, routine tasks such as performing class surveys can become an operational challenge. Despite taking all precautions and careful planning, as a Shipowner you might still be found in breach of your class requirements due to the vessel being quarantined, a COVID-19 related delay occurs in reaching the port where the class survey was due to take place or a class surveyor is not being allowed to travel to the survey location or is simply unavailable due to contracting the COVID-19. Not having valid class certificate can lead to losing your insurance cover (including P&I), put you in breach of your contractual obligations but also might prevent your vessel to enter a port. To assist in avoiding such a situation caused by reasons beyond your control, the International Association of Classification Societies (IACS) together with the IMO and the Flag States have taken a number of resolutions which are meant to ease the pressure on Shipowners during these difficult times. The IACS has in this respect issued a letter to the industry regarding the common approach towards extension of surveys following the challenges posed by the COVID- 19 pandemic. For example, they offer to use other class member approved surveyors in case their designated surveyor is not available. They also confirm that their Procedure for Suspension and Reinstatement or Withdrawal of Class (PRC1) in case of exceptional circumstances will apply to COVID-19 related delays: a three months additional delay will be granted in preforming the necessary surveys. A link to the letter can be found at: http://www.iacs.org.uk/covid-19/ Would you run into an issue due to COVID-19 restrictions in respect of your class requirements, it is our recommendation to always check with your class society what are the possibilities as they will be the ones deciding on providing an extension of the certificates on a case by case basis. They will also be the one in a position to provide you with assistance and guidance on how to keep all your certificates valid in these difficult times. QUESTIONS? Should you have any questions following this information, please do not hesitate to contact us. ABOUT EF MARINE EF Marine provides Fixed Premium P&I solutions to Shipowners, Charterers and MultiModal operators. EF Marine has a global client base and offices in Singapore and Rotterdam. EF Marine provides ‘AA- ‘rated security from Swiss Re Corporate Solutions with limits up to USD 500m. Through our partnership with Swiss Re Corporate Solutions we provide our clients with first class security combined with EF Marine’s extensive knowledge of the P&I market.

UN, US Latest Sanction Focus on Shipping Industry

On 14 May, the U.S. Treasury Department, along with the State Department and the Coast Guard issued a global advisory to alert the maritime industry and those active in the energy and metals sectors to deceptive shipping practices used to evade U.S. economic sanctions, with a focus on Iran, DPRK (Democratic People’s Republic of Korea), and Syria. Earlier this year, the United Nations (UN) Security Council has released the 2019/2020 UN Panel of Experts of North Korea Sanctions Report. The report accuses DPRK of increasing illegal coal exports, imports of petroleum products and continuing with cyber-attacks on financial institutions and cryptocurrency exchanges to gain illicit revenue. Maritime activities have been identified as facilitating this revenue stream for DPRK. This Circular is intended to bring this to your attention. The U.S. Sanctions Advisory for the Shipping Industry The new advisory titled “Guidance to Address Illicit Shipping and Sanctions Evasion Practices” was built on prior shipping guidance issued by OFAC. According to the advisory, approximately 90 percent of global trade involves maritime transportation and “malign actors” are always seeking novel ways to exploit global supply chains to their benefit. The advisory encourages entities and individuals operating near or in areas they determine to be high-risk including those that trade in crude oil, refined petroleum, petrochemicals, steel, iron, aluminum, copper, sand, and coal to review the advisory and take appropriate action as deemed necessary or advisable.  In addition, the advisory identifies and addresses the following deceptive shipping practices, noting that those in the industry must be vigilant against these tactics and should exercise heightened due diligence, as necessary: Disabling or manipulating the Automatic Identification System (AIS) on vessels Physically altering vessel identification; Falsifying cargo and vessel documents; Ship-to-Ship (STS) transfers; Voyage irregularities; False flags and flag hopping; and Complex ownership and management. Furthermore, the advisory details best practices that may assist in more effectively identifying potential sanctions evasion. These practices are: Institutionalize sanctions compliance programs; Establish AIS best practices and contractual requirements; Monitor ships throughout the entire transaction lifecycle; Know your customer and counterparty; Exercise supply chain due diligence; Contractual language; and Industry information sharing. The full content of the advisory can be read at: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/05142020_global_advisory_v1.pdf The 2019/2020 UN Panel of Experts of North Korea Sanctions Report The UN Report noted that the DPRK has continued to make profit for its ballistic missile programme through the illicit import of refined petroleum and export of commodities. Stringent sanctions measures have therefore remained in force. The report outlines the main areas of activity deployed by the DPRK to circumvent security council resolutions. New methods of sanctions evasion identified by the panel include: The export of banned commodities transported on self-propelled barges over 100in length undertaking ocean-going voyages; The use of larger Non-DPRK flagged bulk carriers to deliver coal from DPRK-flagged vessels as opposed to the transfer of coal to smaller, lighter vessels for delivery; and The suspected acquisition by the DPRK of a bulk carrier, destined for scrap, to illicitly export coal. In addition, vessels associated with the transshipment of banned commodities originating in the country have called at more ports along the Chinese coast, as reported by a Member State. The full content of the report can be read at: https://undocs.org/S/2020/151 OUR RECOMMENDATION Both UN and the U.S. authorities have delivered the message that the shipping industry have become their recent focus and the relevant authorities are monitoring vessel movements closely with satellites and other resources. It is also made clear that whilst suspicious activity is investigated, vessels may be subject to search and detained at ports. We expect this trend to continue in the near term. Shipowners, especially those in the high-risk areas, are strongly advised to proceed with extreme caution and exercise the fullest due diligence to ensure that they are not at risk of breaching sanction and that that they do not knowingly or inadvertently perform prohibited activities with Iranian, North Korean and Syrian entities, including but not limited to STS operations. QUESTIONS? Should you have any questions following this information, please do not hesitate to contact us. ABOUT EF MARINE EF Marine provides Fixed Premium P&I solutions to Shipowners, Charterers and MultiModal operators. EF Marine has a global client base and offices in Singapore and Rotterdam. EF Marine provides ‘AA- ‘rated security from Swiss Re Corporate Solutions with limits up to USD 500m. Through our partnership with Swiss Re Corporate Solutions we provide our clients with first class security combined with EF Marine’s extensive knowledge of the P&I market.