Anti-Corruption and Anti-Bribery Policy

INTRODUCTION

This Anti-Corruption and Anti-Bribery Policy (the “Policy”) concerns Maxton Shipping Inc. DBA Skypaceand its subsidiaries (collectively, the “Company”) and applies to all employees, officers, directors, legalentities of the Company and third parties representing the Company, without exception.

Full adherence to Anti-Corruption and Anti-Bribery Laws, regulations, and policies is mandatory: nobribes, kickbacks, or other corrupt payments may be offered or received by any of Company Personnelor third parties working on behalf of the Company.

PURPOSE & OBJECTIVE

The purpose of this Policy is to provide clear guidance and establish a set of conduct rules for allemployees, officers, directors, legal entities of the Company, and third parties representing theCompany. Through this Policy, we aim to ensure that all individuals:

Understand their ethical obligations and embrace the highest level of personal and professionalintegrity.

Maintain strict compliance with Anti-Corruption and Anti-Bribery Laws, adhering to them consistently. Refrain from engaging in any corrupt practices or behaviors that undermine our ethical standards.Actively identify and promptly report any concerns related to bribery and corruption.

By upholding this Policy, we demonstrate our firm commitment to conducting business with unwaveringhonesty, integrity, and ethical values. Our dedication to fairness, transparency, and accountabilityremains steadfast at all times.

FORMS OF BRIBERY AND CORRUPTION

For purposes of this Policy, each of the examples below is referred to as a "bribery offence".

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial,contractual, regulatory or business or personal advantage.

An inducement is something which helps to bring about an action or desired result.

A business advantage means that Ascendant is placed in a better position (financially, economically,or reputationally, or in any other way which is beneficial) either than its competitors or than it wouldotherwise have been had the bribery or corruption not taken place.

Kickbacks are payment of any portion of a contract made to employees of another contracting partyor the utilization of other techniques, such as subcontracts, purchase orders or consulting agreements,to channel payment to public officials, political parties, party officials or political candidates, toemployees of another contracting party, or their relatives or business associates.

Extortion means to directly or indirectly demand or accept a bribe, facilitation payment or kickback.

Facilitating payments are unofficial payments of limited value made to a Government / Public Officialwith the intention of expediting and facilitating the execution of an ordinary, routine and non-discretionary activity or one that is required as part of the duties of the Government / Public Official (forexample, payments to expedite customs operations, obtaining documents, issuing visas, etc.).Facilitating payments do not include payments that may be required under applicable local legislation(e.g. payments required to be able to enjoy priority treatment).

RULES OF CONDUCT

Any form of bribery and any kind of corrupt practice is strictly prohibited: bribery offences, unlawfulfavors, collusive behavior, solicitation, directly and/or through third parties, as regards personal andcareer benefits for oneself or for others. It is prohibited to obtain, promise or offer objects of value toany person, including public officials, to obtain or maintain a business deal in an improper manner or toobtain an undue advantage in conducting business. In particular, making payments to obtain newcontracts, retain old contracts, to speed up the processing of all official documents or to unduly influenceany person, is strictly prohibited.

It is forbidden for a Company Personnel or a third party working on behalf of the Company to:

• Offer, give, solicit or accept anything of value, either directly or indirectly through a third party, to/from a Government / Public official, commercial entity, or any individual, with the intent of influencing a business decision to obtain or retain an improper business advantage or in order to speed up services already due by the parties it has dealings with (“facilitation payments”).;
• Solicit or accept a bribe, kickback, corrupt payment or any other improper business advantage;
• Engage in any corrupt practice or activity in violation of anti-corruption laws and regulations;
• Authorize or condone any corrupt practice, behavior or activity performed by any Company Personnel or third party representing the Company;
• Undertake any action or conduct that may create the appearance of impropriety or corruption (even the perception of a corrupt act could result in the damage of our reputation);
• Intentionally alter, omit, or falsify books or records of the Company.

GIFT POLITICS

To build goodwill with potential and existing customers and other business partners, or to recognizeand appreciate a positive and long-standing business relationship, offering and receiving gifts andbusiness courtesies may be an accepted business practice.

However, Company must ensure that any gift, gratuity or business courtesy is not a bribe or corrupt

payment meant to improperly influence a business decision. Even the perception of a corrupt practicemay harm our reputation.
Company Personnel may not request, solicit or accept money, gifts or benefits for themselves or forothers, except for gifts of a modest value that may occasionally be offered as a normal courtesy.

Presents, courtesies and hospitality for government representatives, public officials and publicadministration employees may be allowed only if they are of a modest value and in any case if they donot compromise the integrity or the reputation of one of the parties and may not be interpreted, by animpartial observer, as being intended to obtain advantages in an improper manner”.

It is the responsibility of Company to be aware of the prohibitions or limitations of the organization to which the receiver belongs, before offering donations, gifts, sponsorships, presents and hospitality.

CHARITABLE CONTRIBUTIONS

The Company believes in contributing to the communities in which it does business and permits donations to community projects, local and foreign charities and other recipients. Before making a contribution, the Company needs to be certain that donations to foreign-based charities and otherrecipients are not disguised illegal payments to foreign officials in violation of Anti-Corruption and Anti-Bribery Laws.

CONFLICTS OF INTEREST

A conflict of interest is defined as any instance in which personal interest or the activity of an individual interferes, or even appears to interfere, with the interests of the Company. A situation of conflict arises when Company Personnel performs an action or is susceptible to interests that interfere with their capacity to carry out their duties in an impartial and effective way.

Company employees must act in the best interest of the company and avoid engaging in any activities that compromise or could reasonably be perceived to compromise their professional judgment.

Company employees are expected to disclose any actual or potential conflicts of interest to their immediate supervisor or the designated authority.

In cases where a conflict of interest is identified, Company will assess the situation and take appropriate measures to mitigate or eliminate the conflict.

By way of example, but not exclusively, conflicts of interest occur in the following situations:

• when Company Personnel and/or their spouse, relatives and relatives by marriage to the second degree, de facto cohabiting partners and persons to whom they have an emotional attachment, have economic and financial interests in the business of suppliers, clients and competitors;
• when they use their position in the company or use information acquired in their job in a way that could create conflict between their own interests and the company’s interests;
• when Company Personnel who are connected by hierarchical relationships are related (by the spouse,relatives and relatives by marriage to the second degree, de facto cohabiting partners and persons to whom they have an emotional attachment);
• when performing work of any type for clients, suppliers, competitors, etc.;
• when accepting money, favours or benefits from people or companies that have, or who intend toenter into, business relations with the Company.

THIRD PARTIES

It is essential that Company business partners and third parties working on behalf of the Companyunderstand and are fully aligned with Company’s zero tolerance for bribery and corruption. Anti-Corruption and Anti-Bribery Laws may hold Company accountable for a third party’s bribe or corruptbehaviour when the third party is representing or acting on behalf of the Company or in connection toa Company transaction.

To reduce the risk associated with engaging third parties, Company undertakes appropriate, risk-basedanti-corruption due diligence to ensure these third parties comply with Anti-Corruption and Anti-BriberyLaws and Company’s standard of ethical behavior.

Also due diligence may include consideration of factors such as the third party’s reputation andqualifications, the manner and reasonableness of compensation, and the relationship, if any, betweenthe owners and employees of the third party and a Government Official.

All Company Personnel is responsible for, and must closely monitor, the relationships they have withour commercial entities, government entities, vendors, customers, and all other third parties.

MONITORING AND REVIEWING

Company compliance manager is responsible for monitoring the effectiveness of this policy and willreview the implementation of it on a regular basis. They will assess its suitability, adequacy, andeffectiveness.

Internal control systems and procedures designed to prevent bribery and corruption are subject toregular audits to ensure that they are effective in practice.

Any need for improvements will be applied as soon as possible. Company Personnel is encouraged tooffer their feedback on this policy if they have any suggestions for how it may be improved. Feedbackof this nature should be addressed to the compliance manager.

VIOLATIONS

Failing to comply with Anti-Corruption and Anti-Bribery Laws can have serious consequences for theCompany including steep fines, criminal prosecution, and reputational damage. Individuals involved in the conduct may be subject to criminal prosecution, criminal fines, and imprisonment. CompanyPersonnel involved in a violation of anti-corruption laws, this Policy, or other related Company policie sand procedures will be subject to appropriate discipline, up to and including termination. Violations may result in a loss of incentive compensation, bonuses, or other awards, to the extent permitted by law.