Mantovani Navigation


Chapter 1:
General Provisions

1 Aim of the Code of Conduct
The aim of Mantovani Navigation Code of Conduct (this “Code of Conduct”) is to state the standards that should be observed by all executives and employees of Mantovani Navigation in order to realize the principles set forth in the Mantovani Navigation Corporate Social Responsibility (“CSR”) Charter. This Code of Conduct articulates the rules that should be observed in carrying out Mantovani’s business activities.
2 Code of Conduct
• (1) Compliance with Code of Conduct In carrying out all aspects of Mantovani Navigation’s corporate activities, all executives and employees must act in accordance with this Code of Conduct, the applicable laws and regulations of the jurisdictions where Mantovani operates, and all internal company regulations. Executives and management employees have a special responsibility to provide guidance and supervision to ensure compliance with this Code of Conduct by their subordinate employees, and executive and manager must set an example for those under their supervision.

• If an executive or an employee become aware of a problem or a potential problem while carrying out business activities, the responsible executives and employees must take initiative and either solve the problem (including taking action to prevent a recurrence of the problem) or implement preventive measures.

• (2) Establishment of required internal company regulations The manager or executive in charge of each division/department must take the necessary steps to ensure the strict implementation of corporate activities in compliance with this Code of Conduct, including establishing internal company regulations consistent with the Code of Conduct, keeping employees informed of specific compliance standards, and offering advice and guidance.
3 Corrective Action to violation of the Code of Conduct
• If an executive or an employee becomes aware of activity that violates or possibly violates this Code, the applicable laws of the jurisdictions, or internal company regulations, he/she must report the activity to his/her supervisor, management of the relevant divisions/departments, and/or the Mantovani Navigation Legal Advisor. In this case, the person reported shall be free from any disadvantage. In addition, information of the person who made a report as well as the reported contents shall be under strict control.