Corporate Policies

GMS is fully committed to maintaining the highest standards of conduct and ethical behavior, honesty, openness and accountability in all our business activities and to promoting and supporting a culture of corporate compliance and good governance. GMS recognises that its employees and other stakeholders, such as customers, suppliers and other market participants, play an important role in achieving this commitment and this Code of Conduct is the centrepiece of our commitment when conducting business globally with the highest standards of business ethics.

This Code is applicable to all employees and workers, including executive directors, non-executive directors, other corporate officers and staff of GMS and of any subsidiary in which GMS has a controlling interest, as well as any secondees, contractors/sub-contractors, consultants, agents, suppliers, irrespective of their location, function, grade or standing, engaged by GMS or its subsidiaries on its behalf and under its effective control and serves as the overarching guiding principles.

Your Responsibilities:

• You must understand and adhere to ethical responsibilities imposed by this Code. You should seek additional guidance from a department manager or from the Human Resources Manager when in doubt.
• You must participate in any compliance training and certifications required by GMS.
• You must advise fellow employees when their actions appear as a breach of this Code.
• You must cooperate with any investigations into potential misconduct.
• You must avoid situations which could result even in the appearance of wrongdoing or impropriety under this Code.
• You must read and ensure compliance with the GMS Anti-Slavery and Human Trafficking Procedure (T3-HR-PROC-020).

All Directors, Executive Committee members and managers have the responsibility to promote a culture of compliance and integrity and create a positive working environment in which people are treated with utmost respect and dignity. They are expected to:

• Lead by example through upholding the standards of this Code.
• Help the employees they supervise understand and comply with this Code and underlying policies and procedures.
• Support those who raise concerns and protect the employees from retaliation.
• Drive implementation and adherence of the GMS policy on modern slavery and human trafficking.

Compliance with this policy is further explained in our Code of Conduct Procedure (T3-GMS-PROC-024); you may also directly contact the Human Resources Manager.

This Privacy Statement sets out how Gulf Marine Services PLC ("the Group") handles Personal Data (any information identifying a living individual or information relating to a living individual that we can identify from the data or in combination with other identifiers) in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

This Privacy Statement (together with related policies and procedures) is an internal document and should not be shared with third parties, clients or regulators without prior authorisation from the HR Director.

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the Group and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.

Data Protection Principles

We adhere to the principles relating to processing of Personal Data set out in the GDPR which requires Personal Data to be:

1. Processed lawfully, fairly and in a transparent manner;
2. Collected only for specified, explicit and legitimate purposes;
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
4. Accurate and where necessary kept up-to-date;
5. Not kept, in a form which permits identification of data subjects, for longer than is necessary for the purposes for which the data is processed;
6. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage;
7. Not transferred to another country without appropriate safeguards being in place; and
8. Made available to data subjects and data subjects allowed to exercise certain rights in relation to their Personal Data.

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above.

Data Subject's Rights and Requests

Any request by a data subject which may seek to exercise any right in respect of their Personal Data is required to be forwarded immediately to the HR Manager, who is the Data Protection Lead (DPL) for the Group, for consideration and appropriate action. The DPL is required to verify the identity of any individual requesting data in order to ensure that no Personal Data is disclosed without proper authorisation.

Data Breaches

Where appropriate, the Group will notify any breach of Personal Data to the applicable regulator and, in certain instances, the data subject. Should there be any suspected breach of Personal Data, we will notify the appropriate persons where we are legally required to do so. All representatives of the Group are encouraged to raise any concerns or queries regarding the Group’s compliance with the GDPR and any suspected data breach to the Group’s DPL. Any investigation shall be determined by the DPL and all Group representatives are required to preserve any evidence relating to the concern.

Sharing Personal Data

We will not share Personal Data with third parties unless certain safeguards have been put in place. We have taken reasonable steps to ensure that any such third party shall respect the security of the Personal Data and will treat it in accordance with the applicable law(s) which apply to the Group.

This Statement

All our staff have been made aware of our expectations regarding the processing of Personal Data and this has been incorporated into our induction process for new employees. The Group’s DPL, senior management team and line managers are responsible for ensuring that those reporting to them understand and comply with our policies and procedures implemented to comply with the GDPR.

We conduct all of our business in accordance with the letter and spirit of the law and with the overriding ethical standards of accepted business conduct. We therefore take a zero-tolerance approach to bribery and corruption and are committed to acting professionally and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We acknowledge that we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both in the UK and abroad.

Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if the Company is found to have taken part in corruption, we could face an unlimited fine and damage to our reputation. We therefore take our legal responsibilities very seriously and expect our employees to do the same. Any failure to adhere to the terms of this Policy by employees may therefore lead to disciplinary action, up to and including summary dismissal, or for all other employees, termination of our ongoing contractual relationship with them. It may also lead to criminal prosecution.

In order to counter the risk of bribery, we will rigorously enforce this Policy and monitor compliance. All employees will receive training on this Policy. We will regularly review the risk of bribery and take such action as may be necessary to reduce and remove such risk.

Our zero-tolerance approach to bribery and corruption will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter. Employees whose role it is to engage with suppliers, contractors and business partners must take responsibility to ensure the Group’s position has been clearly communicated as part of the tendering relationship.

This Policy applies to all individuals working at all levels within the Group on and offshore including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual employees and agency seafarers and staff, placement students, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located.

Compliance with this policy is further explained in our Anti-Corruption and Bribery Procedure (T3-HR-PROC-023).

Modern slavery is a crime resulting in an abuse of human rights and is constituted in the UK Modern Slavery Act 2015 ('the Act'). Contained within the Act is the requirement for all commercial organisations that provide goods or services, with business or part of a business in the UK, to produce a statement of the steps the organisation has taken during each financial year to ensure that slavery and human trafficking is not taking place in its own business or in its supply chain. This statement has been published by Gulf Marine Services PLC ('GMS', 'the Group') in accordance with the Act for the year ended 31 December 2020.

GMS provides and operates advanced self-propelled self-elevating support vessels to the oil, gas and renewable energy industries and has offices in the United Arab Emirates, Saudi Arabia and Qatar. Further information on the Group's business and organisational structure is available on our website.

We seek to ensure that modern slavery and human trafficking is not taking place in our own business or in our supply chain. Our supply chain comprises various suppliers, contractors and subcontractors that provide the equipment, goods, manpower and services needed to build, maintain and operate our vessels and to perform our corporate activities.

Reasonable and practical steps are undertaken to ensure our suppliers are implementing relevant ethical employment practices. Should a supplier be suspected to be involved in modern slavery and human trafficking, we will consider a series of remedial measures, including consultation and education, and where appropriate, the discontinuation of the supplier's services.

We risk assess all new suppliers and regularly risk assess all existing suppliers in our global supply chain to identify which suppliers could present an increased risk of modern slavery occurring. In particular, we seek to understand the business operations and activities of our crewing and staffing agencies that are located in areas or countries considered to present a higher level of risk.

In 2017 we wrote to all our suppliers to ensure they are aware of our commitment to the prevention of modern slavery and human trafficking summarising the fundamental standards of employment we provide for our own employees and our expectation of them in this matter within their own businesses and supply chains. This communication to all our suppliers will be repeated in 2021. In 2020, 102 new suppliers were added to the GMS supply chain who received this information as part of our ongoing risk assessment and due diligence procedures. Our standard terms and conditions of trade with our suppliers explicitly include our policy on modern slavery. Through our risk assessment, we have identified that the main human rights vulnerability is in the employment of unskilled labour in the supply chain for mobilisation and maintenance works. These workers may be exposed to risks of unconsented retention of travel documents and contract discrepancies by recruitment agents. GMS has issued a letter to relevant vendors stipulating our views on modern slavery and our expectations of our vendors. In addition, as the majority of unskilled work took place at our yards, any inappropriate treatment could be reported directly to GMS staff by the affected workers. During 2020 there were no suppliers identified as in breach of the Act nor were there any reports from contractors.

The Modern Slavery Act has helped us to better understand our suppliers' approach to the prevention of modern slavery and each year we strive to improve our evaluation of our suppliers in line with developments in best practice. In 2018 we refined our supply chain risk assessment criteria to ensure a more robust review across a broader range of our suppliers. The addition of new criteria, for example whether a supplier is certified or has membership of industry-recognised auditing bodies, has also been helpful as we seek to work with suppliers whose values align with our own. Unfortunately, GMS staff members have been unable to visit suppliers head offices in 2020 due to the COVID-19 pandemic. However, GMS staff have continually monitored our most vulnerable suppliers, those being unskilled labour during vessel mobilisations and maintenance works in our yard during 2020. A plan will be put in place to recommence supplier work site and head office visitations in 2021, COVID-19 permitting. We have reviewed our anti-slavery and human trafficking procedures to ensure these continue to be appropriate and in accordance with the requirements of the Act. The procedures, which are incorporated into our formal policies that describe our ethical standards and our expectations of employees and others with whom we work, contain information on how to report any suspected wrongdoing, including the possible abuse of human rights. In order to measure the successful implementation of these procedures we have introduced internal performance targets specifically relating to both our supply chain and our own personnel.

All our staff have been made aware of our policy on modern slavery and human trafficking. On an annual basis, management and onshore staff are required to certify their commitment to the GMS compliance policies and procedures. Our senior management team and line managers are responsible for ensuring those reporting to them understand and comply with our policy on modern slavery and human trafficking and our related procedures.

This statement has been approved by the Board of Directors of Gulf Marine Services PLC.

GMS recognizes its talented and diverse workforce as a key competitive advantage.

Our business success is a reflection of the quality and skill of our people. GMS is committed to seeking out and retaining the calibre human talent to ensure top business growth and performance.

We recognize that each employee brings their own unique capabilities, experiences and characteristics to their work. This benefits individuals, teams, our company as a whole, and our customers. Therefore we are committed to providing a working environment in which all employees are able to realise their full potential and to contribute to business success irrespective of his or her gender, race, nationality or any disability.

It is GMS policy that no employee or prospective employee will receive less favourable treatment or is disadvantaged by any circumstances, conditions or requirements that cannot be justified. In order to create conditions in which this goal can be realised, the Company is committed to identifying and eliminating discriminatory practices, procedures and attitudes throughout the organisation.

What our Employees can expect from the Company

Our employment practises will ensure that no employee is discriminated against either directly or indirectly on grounds of gender, race, colour, nationality, ethnic or racial origins, marital status, religion or disability. This commitment applies to all aspects of employment as outlined below:

• Recruitment and selection, including advertisements, job descriptions, interview and selection
• Training
• Promotion and career development opportunities
• Terms and conditions of employment as required by local legislation
• Grievance handling and the application of disciplinary procedures
• Selection for redundancy

What we expect from our Employees

Employees have a number of responsibilities, many of which are directly related to their jobs, however the following are general instructions that apply to everyone.

• All GMS employees shall comply with measures that are introduced to ensure equality of opportunity and non-discrimination.
• Individuals responsible for employees are not to discriminate when applying process relating to the training, advancement, performance management, transfer, redeployment, discipline, retirement, dismissal or redundancy, benefits, facilities and services
• No employee shall victimise an individual on the grounds that they have made a complaints or provided information about discrimination or harassment.
• No employee shall harass, abuse or intimidate another employee on any grounds.