Whistleblowing Policy

About this Policy

Sea1 OFFSHORE INC. and its subsidiaries (the "Sea1 OFFSHORE GROUP" or "Group") are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible, hence the adoption of this policy. This policy is adopted effective 9 September 2024.

The policy applies to the Group, its directors, employees and contractors. This policy is also relevant to any person who is associated with the Group who performs a service for, or on behalf of, the Group. This policy does not form part of any employee's contract of employment.

This policy will be monitored and reviewed and may be subject to change as and when a need is identified, or if required by legislation.

What is Whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.

How to raise a concern

We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact the Whistleblowing Officers. Contact details are at the end of this policy.

We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

Confidentiality

We hope that staff will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

External Dissclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases, you should not find it necessary to alert anyone externally. However, various legislations recognise that in some circumstances it may be appropriate for you to report your concerns to an external body, such as public authorities. We encourage you to seek advice before reporting a concern externally.

Protection and support for Whistleblowers

We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken. Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform the Whistleblowing Officers - COO and a member of the Board immediately.

Whistleblowers shall not be threatened or retaliated in any way. Anyone involved in such conduct may be subject to disciplinary action.

If we conclude that a whistleblower has made false allegations, the whistleblower may be subject to disciplinary action.