Bribery & Anti-Corruption Policy

Tide Table Logistics Ltd

Purpose:

The purpose of this Bribery & Anti-Corruption Policy is to unequivocally prohibit all forms of bribery, kickbacks, facilitation payments, and any other corrupt or unethical practices in every facet of Tide Table Logistics Ltd’s business operations. This policy underscores the company’s firm commitment to conducting all its activities with the highest standards of integrity, fairness, and transparency. It is designed to ensure that all employees, contractors, agents, vendors, and representatives understand their responsibilities in preventing and reporting corruption, thereby safeguarding the company’s reputation and legal standing.

Tide Table Logistics Ltd recognizes that corruption undermines trust, distorts fair competition, and exposes businesses to severe legal, financial, and reputational risks. Accordingly, the company is dedicated to full compliance with all relevant anti-bribery and anti-corruption legislation across all jurisdictions in which it operates. By embedding ethical business practices into its corporate culture, Tide Table Logistics Ltd seeks to promote a working environment where honesty and accountability are paramount, reinforcing its role as a responsible and trustworthy participant in the global logistics and trade sectors.

This policy not only aims to prevent illegal or unethical conduct but also fosters a proactive approach to identifying and mitigating corruption risks. Through clear guidelines, rigorous enforcement, and continuous training, Tide Table Logistics Ltd commits to upholding transparency and fairness in all dealings with government officials, business partners, clients, and third parties. Ultimately, this policy contributes to the company’s broader objective of sustainable growth built on ethical foundations and regulatory compliance.

Scope:

This Bribery & Anti-Corruption Policy applies universally across all levels of Tide Table Logistics Ltd’s operations, encompassing every geographic location where the company conducts business. It is mandatory for all employees, regardless of their role, seniority, or department, ensuring that every individual within the organization is fully accountable for upholding the principles outlined in this policy.

Beyond employees, this policy extends to all agents, vendors, consultants, contractors, subcontractors, and any other third parties or representatives who act on behalf of or in the interest of Tide Table Logistics Ltd. This comprehensive scope ensures that all external business relationships are governed by the same rigorous standards of ethical conduct and legal compliance that the company demands internally.

No exceptions apply to the coverage of this policy, reflecting Tide Table Logistics Ltd’s unwavering commitment to a zero-tolerance stance on bribery and corruption in any form. By applying this policy globally, the company acknowledges the diverse legal and cultural environments in which it operates, while maintaining a consistent and uncompromising framework for ethical business conduct worldwide.

All covered parties are expected to familiarize themselves with the requirements of this policy, adhere strictly to its provisions, and actively participate in the company’s ongoing efforts to prevent, detect, and address any incidents of bribery or corrupt behavior. Failure to comply with this policy will result in disciplinary actions, up to and including termination, as well as potential legal consequences, underscoring the seriousness with which Tide Table Logistics Ltd treats anti-corruption compliance.

Responsibilities:

All Employees:

• Every employee at Tide Table Logistics Ltd carries a critical responsibility to uphold the highest standards of integrity and ethical conduct in all aspects of their work. Employees must remain vigilant and proactive in identifying and addressing any forms of bribery, corruption, coercion, or other unethical behavior they may encounter during the course of their duties. This includes recognizing subtle or overt attempts to influence decisions or actions through improper means.

• Employees are obligated to promptly report any suspected or actual instances of bribery or corrupt practices without fear of retaliation. Timely reporting is essential to enable the company to investigate concerns thoroughly, take appropriate corrective action, and mitigate potential risks to the company’s reputation and legal standing.

• Additionally, all employees are required to strictly comply with the procedures and controls established within this policy. This includes adhering to gift and hospitality declaration requirements, refraining from facilitation payments, and cooperating fully with due diligence processes involving third-party intermediaries.

• Participation in mandatory anti-bribery and corruption training programs is also compulsory for all employees. These training sessions are designed to enhance awareness, reinforce compliance expectations, and equip staff with the knowledge and tools needed to identify and prevent corrupt practices effectively.

• Through these responsibilities, each employee contributes to fostering a culture of transparency, accountability, and ethical business conduct that is fundamental to Tide Table Logistics Ltd’s ongoing success and legal compliance.

Compliance Officer:

• The Compliance Officer holds a pivotal role in upholding Tide Table Logistics Ltd’s commitment to a corruption-free business environment. They are responsible for thoroughly investigating all reported allegations, suspicions, or concerns related to bribery, kickbacks, and corrupt activities within the organization. This investigation process must be conducted with impartiality, confidentiality, and due diligence to ensure accuracy and fairness.

• Upon completion of investigations, the Compliance Officer is tasked with meticulously documenting all findings, maintaining comprehensive records that detail the nature of the issue, investigative steps taken, and conclusions reached. Where findings indicate significant breaches or risks, the Compliance Officer must promptly escalate these to senior management for review and decision-making.

• In cases where regulatory reporting is mandated by law or company policy, the Compliance Officer ensures that the necessary disclosures are made to the appropriate authorities in accordance with jurisdictional requirements, thereby safeguarding the company’s legal compliance and reputation.

• Beyond reactive duties, the Compliance Officer also leads proactive initiatives by overseeing the development and implementation of remedial actions aimed at preventing recurrence of bribery and corruption incidents. This includes updating policies, refining internal controls, and coordinating with relevant departments to embed anti-corruption best practices.

• Continuous monitoring of the company’s overall compliance posture is a further responsibility, involving regular audits, risk assessments, and training programs to maintain an effective and dynamic anti-corruption compliance framework. Through these comprehensive duties, the Compliance Officer serves as a cornerstone of Tide Table Logistics Ltd’s ethical governance and regulatory adherence.

Procedures:

1. Gifts and Hospitality Declaration:To maintain transparency and avoid any perception of undue influence or bribery, Tide Table Logistics Ltd requires that all gifts, entertainment, or hospitality—whether given to or received from clients, vendors, government officials, or any third parties—that exceed the value of £100 must be formally documented. This documentation takes place through the company’s dedicated Gifts and Hospitality Register, which serves as an auditable record ensuring accountability and oversight.

Before any gift or hospitality of this nature is accepted or offered, it must undergo a thorough evaluation to determine its appropriateness in the context of business ethics, local customs, and anti-corruption laws. The assessment focuses on factors such as the intent behind the gift, the relationship between the parties, the timing relative to business decisions, and the potential impact on impartiality or perceived favoritism.

Approval for accepting or providing such gifts or hospitality must be sought from the Compliance Officer, who will review the details and either authorize or reject the transaction based on compliance standards and the company’s zero-tolerance stance on bribery. This prior approval process is essential to mitigate risks and uphold Tide Table Logistics Ltd’s integrity across all levels of operation.

Any gift or hospitality found to be inappropriate, excessive, or contrary to the company’s ethical guidelines must be declined or returned, with clear communication documented to preserve transparency and deter future attempts at influence. This procedure fosters a culture of openness and reinforces the company’s commitment to ethical business conduct globally.

2. Prohibition of Facilitation Payments:Tide Table Logistics Ltd maintains a firm and unequivocal stance against facilitation payments, which are unofficial fees or gratuities offered to government officials or agents to expedite or secure routine government actions, approvals, or services. These payments, often perceived as small or customary in certain regions, are strictly prohibited under this policy due to their inherent risk of constituting bribery and undermining fair business practices.

Employees, contractors, and representatives of Tide Table Logistics Ltd are required to categorically refuse any requests or solicitations for facilitation payments. Under no circumstances should such payments be made, regardless of the perceived pressure, urgency, or local customs that may appear to encourage such behavior.

If an employee encounters a demand or suggestion for a facilitation payment—whether explicit or implied—they must immediately report the incident to the Compliance Officer. This prompt reporting enables the company to document the event, assess the risk, and take appropriate actions, including engaging with legal counsel or relevant authorities as necessary.

By prohibiting facilitation payments and encouraging transparent reporting, Tide Table Logistics Ltd not only complies with international anti-corruption laws but also fosters an organizational culture rooted in integrity, fairness, and respect for lawful business procedures. This policy reinforces the company’s commitment to operating ethically in all jurisdictions, regardless of local practices or pressures.

3. Third-Party Due Diligence:Tide Table Logistics Ltd mandates rigorous and comprehensive due diligence procedures for all third-party intermediaries, agents, consultants, vendors, and any other external partners prior to formal engagement or contractual relationships. This due diligence is a critical component of the company’s anti-corruption framework, designed to mitigate risks associated with indirect involvement in bribery, kickbacks, or other corrupt practices through third parties.

The due diligence process involves a thorough investigation and assessment of each third party’s background, reputation, and operational history, with particular attention to the following key areas:

• Corruption Risk Indicators: Screening for any history or allegations of corrupt behavior, unethical conduct, or regulatory sanctions related to bribery or fraud. This includes reviewing publicly available information, media reports, sanction lists, and industry databases to identify potential red flags.

• Ownership and Control Structures: Detailed examination of the third party’s ownership, management, and beneficial interests to uncover any hidden affiliations, conflicts of interest, or connections to politically exposed persons (PEPs) or high-risk jurisdictions that might increase corruption risk.

• Compliance History: Evaluation of the third party’s adherence to anti-corruption laws and ethical standards, including any past involvement in investigations, penalties, or compliance breaches.

• Reputational Assessment: Analysis of the third party’s market reputation, references, and business practices to ensure alignment with Tide Table Logistics Ltd’s values and compliance requirements.

This due diligence must be documented comprehensively, ensuring that all assessments, findings, and supporting materials are securely stored for auditability and future reference. The documentation should clearly outline the scope of the review, the sources consulted (such as sanctions lists, beneficial ownership registries, or adverse media reports), and the rationale behind the final risk rating assigned to the third party.

Any concerns, inconsistencies, or red flags identified during the due diligence process—such as opaque ownership structures, links to politically exposed persons (PEPs), a history of regulatory violations, or operations in high-risk jurisdictions—must be immediately escalated to the Compliance Officer. The Compliance Officer is responsible for conducting a further review, seeking legal counsel when necessary, and making a final determination regarding the appropriateness of the business relationship.

Engagement with third parties who present unacceptable levels of corruption or reputational risk shall be avoided altogether unless exceptional mitigating measures are approved and enforced. In such rare cases, additional controls may include enhanced monitoring, contractual safeguards, periodic re-assessments, and executive-level approvals.

By enforcing these stringent third-party due diligence procedures, Tide Table Logistics Ltd proactively protects its operations from indirect exposure to bribery and corrupt practices. This not only ensures compliance with global anti-corruption laws but also reinforces the company’s dedication to ethical business conduct. Moreover, it strengthens the integrity and transparency of its global commercial partnerships, providing clients, regulators, and stakeholders with continued confidence in the company’s operations and governance framework.

4. Mandatory Training:Tide Table Logistics Ltd is committed to fostering a culture of integrity and ethical conduct throughout its global operations. To support this commitment, the company mandates comprehensive anti-bribery and anti-corruption training for all relevant personnel. This training is designed to ensure that every employee, agent, contractor, and representative understands their legal and ethical obligations, recognizes potential corruption risks, and is fully aware of the procedures for reporting suspicious activity.

The training program will be conducted at least once annually and will cover, but not be limited to, the following key areas:

• Overview of Anti-Bribery Laws and Regulations: Providing a clear explanation of applicable laws such as the UK Bribery Act 2010, Ghana’s Public Procurement and Anti-Corruption Acts, and relevant international standards.

• Company Policy and Expectations: Detailed guidance on Tide Table Logistics Ltd’s zero-tolerance stance on bribery and corruption, including the prohibitions outlined in this policy and the consequences of non-compliance.

• Identification of Corruption Risks: Practical scenarios and case studies to help personnel recognize common bribery and corruption risks, including facilitation payments, gifts and hospitality abuses, conflicts of interest, and third-party risks.

• Reporting Mechanisms and Whistleblower Protections: Clear instructions on how to report suspected violations confidentially and without fear of retaliation, emphasizing the company’s commitment to protecting whistleblowers.

• Responsibilities of Individuals: Reinforcing the personal accountability of every individual to adhere to the policy and contribute to the company’s compliance culture.

The Compliance Officer will oversee the full lifecycle of the anti-bribery and anti-corruption training program—its development, delivery, and periodic evaluation. This responsibility includes ensuring that the content reflects current legal requirements, industry best practices, and company-specific risk exposures. The training will be tailored to different roles within the organization, with enhanced modules for employees operating in high-risk regions or functions.

Participation in the training program will be mandatory and systematically tracked, with completion records maintained for internal accountability and regulatory inspection purposes. Any personnel who fail to complete the required training within specified timelines will be subject to follow-up and may be temporarily restricted from engaging in certain duties until compliance is met.

To ensure the ongoing relevance and effectiveness of the training, refresher sessions and updates will be delivered as necessary—particularly when there are changes in applicable laws, internal policies, or when risk assessments highlight new areas of concern. Case studies, real-world scenarios, and interactive formats will be used to foster engagement and practical understanding.

Through this structured and continuous approach to training, Tide Table Logistics Ltd reinforces a culture of compliance and accountability. It empowers employees at all levels to act ethically, confidently recognize and report potential violations, and uphold the company’s unwavering commitment to lawful and transparent business conduct across its global operations.

Compliance:

Tide Table Logistics Ltd is firmly committed to ensuring full compliance with all applicable anti-corruption laws and regulatory frameworks that govern its operations across all jurisdictions. This includes, but is not limited to, adherence to the UK Bribery Act 2010, which sets rigorous standards for preventing bribery and corruption in both the public and private sectors, as well as Ghana’s Public Procurement Act and Anti-Corruption Act, which impose strict controls to promote transparency and integrity in business transactions.

The company recognizes that violations of anti-corruption laws can lead to severe legal consequences, including substantial fines, criminal prosecution, and reputational damage that may jeopardize business continuity and stakeholder trust. Therefore, Tide Table Logistics Ltd enforces a zero-tolerance policy towards any form of bribery, kickbacks, or corrupt conduct.

Any employee, agent, contractor, or third party found to be in breach of this policy will be subject to stringent disciplinary measures. These may range from formal warnings and suspension to immediate termination of employment or contracts, depending on the severity and circumstances of the violation. Additionally, the company will cooperate fully with law enforcement and regulatory authorities, reporting violations when required, and supporting any investigations or legal proceedings.

To uphold these compliance standards, Tide Table Logistics Ltd continuously reviews and updates its policies, procedures, and training programs, ensuring alignment with evolving legal requirements and best practices. The company encourages a culture of openness and accountability, urging all personnel to promptly report any suspected misconduct through designated channels without fear of retaliation.

By embedding compliance into its corporate ethos, Tide Table Logistics Ltd aims to safeguard its operations from corruption risks and reinforce its reputation as a responsible, ethical leader in the global logistics industry.

Conclusion

Tide Table Logistics Ltd is unwavering in its commitment to uphold the highest standards of integrity, transparency, and legal compliance across all aspects of its global operations. This comprehensive Anti-Bribery and Anti-Corruption Policy serves as a critical framework to.order prevent, detect, and address any form of bribery, kickbacks, or corrupt practices, ensuring that all business activities are conducted ethically and in full accordance with applicable laws and regulations—including the UK Bribery Act 2010, Ghana’s Public Procurement Act, and Anti-Corruption Act.

The policy applies universally to all employees, agents, vendors, consultants, contractors, and representatives, regardless of location or function. Clear roles and responsibilities have been defined, with all personnel required to remain vigilant, promptly report suspected violations, and adhere to established procedures such as gifts and hospitality declarations, prohibition of facilitation payments, rigorous third-party due diligence, and mandatory ongoing training.

Through the diligent oversight of the Compliance Officer and the implementation of robust control measures, Tide Table Logistics Ltd continuously monitors and enforces adherence to this policy. Non-compliance will not be tolerated and may result in severe disciplinary actions, including termination and legal consequences, thereby reinforcing a culture of accountability and ethical business conduct.

By embedding these principles into its operations, Tide Table Logistics Ltd not only mitigates legal and reputational risks but also fosters sustainable business relationships grounded in trust and responsibility. This commitment positions the company as a leader in ethical trade and compliance within the global logistics and maritime sectors, enabling it to navigate complex regulatory environments effectively while contributing positively to the international community.