Dorian Hellas

Company Overview

Code of Ethics

Dorian Hellas confirms its adherence to the following principles:

• The Company Policies will always be in compliance with the applicable National and      International Legislation;
• The Company acknowledges that both it, the Owner and Shippers are conducting business      with a view to a profit.
• The Company shall not accept business for which it does not have the necessary capability or      resources;
• The Company shall allocate its resources so as to render equitable and faithful performance      to each of its Owner clients;
• Subject to all relevant provisions of the Management Agreement the Company shall advise      Owners of any conflicts of interest;
• The Company shall respect the confidentiality of each Owner’s Business and activities;
• The Company’s Policies are emphasizing its commitment to health, safety, protection of the      environment and security and to the safeguarding of Owners and Shippers Properties;
• The Company shall whenever possible advise the Owner of any potentially dangerous or other      unacceptable situations;
• The Company shall not knowingly participate in activities or practices which it knows to be      unsafe or illegal;
• The Company’s Policies will promote a healthy working environment including but not limited      to the provisions of safeguards against drug & alcohol abuse onboard ship;
• The Company shall not continue to commit itself to carry out business for an Owner when the   service to be provided may be used in the furtherance of illegal activities to the actual      knowledge of the Company;
• The Company shall at all times adhere to sound principles with respect to the management of      funds and cash;
• The Company documents and defines its policies and objectives and its general commitment      to Quality;
• The Company establishes policies, procedures and instructions to ensure that its mission   and ethics code are fully understood, implemented and maintained at all levels in its      Organization.