It is the policy of Modern Terminals and our subsidiaries to conduct business in a manner consistent with all relevant laws in the jurisdictions where we do business, including the applicable economic sanctions and export controls laws and regulations imposed by Hong Kong, the People's Republic of China, and, when applicable, the United States and the European Union (“Trade Controls”).  

Modern Terminals and our subsidiaries follow a policy of compliance with Trade Controls that are applicable to our business. We pledge to:

• Comply with all Trade Controls applicable to our transactions
• Not knowingly participate in transactions that would expose any of the participants to risks under applicable Trade Controls
• Not participate in transactions designed or intended to evade Trade Controls of jurisdictions in which we do business
• Take steps that we reasonably deem to be necessary to comply with, or mitigate risks from, applicable Trade Controls, including declining to render services to any vessel or counterparty that presents an unreasonable Trade Controls risk