Code of Conduct

Message from Leadership

Whether you are an employee, officer, contractor, or business partner, you are expected to follow this Code. Ethical behavior is not only about compliance. It is also about fostering trust, protecting our reputation, and supporting BlackSea's long-term success.

If you see something, say something. Reporting concerns in good faith protects BlackSea and strengthens our culture of integrity. Retaliation against anyone who raises a concern in good faith will not be tolerated.

Together, we will continue to navigate challenges responsibly and ensure that BlackSea remains a leader in our industry.

Our Core Values: The BlackSea Standard

Our actions and decisions are guided by six fundamental values.

These values keep BlackSea steady and help ensure that we operate responsibly and successfully in a competitive environment.

Understanding the Code

This Code of Conduct provides a framework for ethical decision-making. It cannot address every situation, but it establishes principles that guide us in acting lawfully, responsibly, and in BlackSea's best interests.

Who Must Follow the Code?

This Code applies to all employees, contractors, officers, and business partners working with or on behalf of BlackSea.

Our Responsibilities

Everyone covered by this Code is expected to:

• Understand and follow this Code, BlackSea policies, and applicable laws.
• Report concerns involving unethical behavior, policy violations, or noncompliance.
• Support a workplace culture in which employees feel comfortable raising concerns.

Leadership's Role

BlackSea leaders are expected to:

• Set the tone for ethical behavior.
• Lead by example in daily decisions and operations.
• Encourage open communication and a speak-up culture.
• Help ensure compliance with applicable laws and company policies.

Ethical Business Practices

Anti-Bribery and Corruption

BlackSea's success is built on trust and integrity, never bribery or corruption. We:

• Never offer or accept bribes, kickbacks, or anything of value to improperly gain or influence business.
• Follow applicable anti-corruption laws, including the Foreign Corrupt Practices Act.
• Accurately record transactions and maintain transparent financial records.
• Work with businesses that share our commitment to ethical conduct.

Fair Competition and Antitrust Compliance

BlackSea competes based on merit, not manipulation. We:

• Do not engage in collusion, price-fixing, bid-rigging, or other anticompetitive conduct.
• Gather competitive intelligence legally and ethically.
• Comply with applicable antitrust and fair-trade regulations in every market where we operate.

Avoiding Conflicts of Interest

Conflicts of interest can compromise objective decision-making and damage credibility. To prevent them, we:

• Disclose potential conflicts to management.
• Do not use BlackSea resources for personal gain.
• Avoid gifts, favors, financial interests, or relationships that could improperly influence business decisions.

Accurate Records and Financial Integrity

Maintaining complete and truthful records is essential to accountability. We:

• Document all transactions accurately.
• Follow applicable accounting and reporting policies.
• Never create off-the-books accounts or misrepresent financial data.

Global Trade Compliance

BlackSea follows applicable international trade laws, including:

• Export and import regulations.
• United States anti-boycott laws.
• Applicable sanctions and embargo requirements.

Respecting People and the Workplace

Harassment-Free Workplace

Harassment, intimidation, and discrimination are not tolerated at BlackSea. We:

• Do not engage in offensive, degrading, threatening, or hostile behavior.
• Encourage employees to report concerns without fear of retaliation.
• Investigate complaints fairly and as confidentially as circumstances permit.

Equal Opportunity and Respect

BlackSea values diverse perspectives and experiences. We:

• Prohibit discrimination based on legally protected characteristics.
• Make hiring and promotion decisions based on merit.
• Provide reasonable accommodations when required.

Health and Safety

Safety is a core responsibility for everyone at BlackSea. We:

• Follow applicable safety regulations and procedures.
• Report hazards or unsafe conditions promptly.
• Maintain a drug-free and violence-free workplace.

Human Rights and Fair Labor Practices

BlackSea supports human rights and ethical labor practices. We:

• Prohibit child labor, forced labor, and human trafficking.
• Support fair wages and safe working conditions.
• Expect suppliers and business partners to uphold comparable standards.

Protecting BlackSea and Its Assets

Confidentiality and Intellectual Property

BlackSea safeguards its intellectual property and confidential information. Employees and other covered individuals must:

• Share proprietary or confidential information only with authorized individuals.
• Respect third-party intellectual property rights.
• Use BlackSea information and assets only for legitimate business purposes.

Data Privacy and Cybersecurity

Protecting sensitive data is critical. We:

• Limit data collection and use to legitimate business purposes.
• Follow applicable cybersecurity and privacy laws and policies.
• Expect third-party vendors to meet BlackSea's applicable security standards.
• Report suspected data breaches promptly.

Insider Trading

Using material nonpublic information for personal financial gain is illegal. Employees and other covered individuals must:

• Never trade stocks or securities based on confidential information obtained through work at BlackSea.
• Never improperly share inside information with another person.

Corporate Citizenship and Responsibility

Environmental Responsibility

BlackSea is committed to responsible practices. We:

• Comply with applicable environmental laws and regulations.
• Seek to reduce waste and unnecessary energy consumption.
• Expect suppliers to follow applicable environmental standards.

Engaging in the Political Process

Employees may participate in personal political activities, but they must:

• Not use BlackSea resources for personal political contributions or activities.
• Make clear that personal political views are not being expressed on behalf of BlackSea.
• Ensure that lobbying activities conducted on behalf of BlackSea comply with applicable legal requirements.

Reporting Concerns and Enforcement

Raising Concerns

Employees are encouraged to report ethical concerns, policy violations, suspected illegal activity, or other potential misconduct through:

No Retaliation

BlackSea strictly prohibits retaliation against anyone who raises a concern in good faith. Retaliation may result in disciplinary action, up to and including termination.

Investigations and Consequences

When a potential violation is reported, BlackSea will:

• Investigate the matter fairly and as confidentially as circumstances permit.
• Take appropriate corrective action, which may include training, warnings, or termination.
• Report suspected illegal activity to the appropriate authorities when required.