Date: 18/01/2018

To our stakeholders:

I am pleased to confirm that LSS LTD reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Alexandros Theodosios Kontos Chief Operating Officer of LSS

We affirm that we have a responsibility to respect the human rights of, and fulfil humanitarian responsibilities towards, all those affected by their business activities, including Personnel, Clients, suppliers, shareholders, and the population of the area in which services are provided. We also recognize the importance of respecting the various cultures encountered in their work, as well as the individuals they come into contact with as a result of those activities.

It is the policy of LSS-SAPU to provide third parties with a mechanism to report allegations of improper and/or illegal conduct to designated personnel including such acts or omissions that would violate the principles contained in the International Code of Conduct Association for Private Security Service Providers (IcOcA)2.
LSS-SAPU will investigate allegations promptly, impartially and with due consideration to confidentiality.

LSS have procedures describing the methods that the company use as a basis in
accumulating and analysing the appropriate data, provided that:
• It proves the competence and effectiveness of the Quality & Security
Management System.
• It detects and evaluates the areas where opportunities for
improvement of the Quality & Security Management System arise.

LSS will not, and will require their Personnel not to, engage in
trafficking in persons.
LSS will, and will require their Personnel to,
remain vigilant for all instances of trafficking in persons and, where discovered, report
such instances to Competent Authorities. For the purposes of this Code, human
trafficking is the recruitment, harbouring, transportation, provision, or obtaining of a
person for (1) a commercial sex act induced by force, fraud, or coercion, or in which
the person induced to perform such an act has not attained 18 years of age; or (2)
labour or services, through the use of force, fraud, or coercion for the purpose of
subjection to involuntary servitude, debt bondage, or slavery.

Prohibition of Slavery and Forced Labour
LSS will not use slavery, forced or compulsory labour, or be
complicit in any other entity’s use of such labour.
Prohibition on the Worst Forms of Child Labour

LSS will respect the rights of children (anyone under the age of 18)
to be protected from the worst forms of child labour, including:
a) all forms of slavery or practices similar to slavery, such as the sale and
trafficking of children, debt bondage and serfdom and forced or compulsory
labour, including forced or compulsory recruitment of children for use in
provision of armed services;
b) the use, procuring or offering of a child for prostitution, for the production of
pornography or for pornographic performances;
c) the use, procuring or offering of a child for illicit activities, in particular for the
production and trafficking of drugs;
d) work which, by its nature or the circumstances in which it is carried out, is
likely to harm the health, safety or morals of children.
LSS will, and will require their Personnel to, report any instances of
the activities referenced above that they know of, or have reasonable suspicion of, to
Competent Authorities.

The objective of the Health, Safety and Environmental Protection Policy is
to ensure that the risk exposed to people, property, the environment and
maritime security are reduced to a minimum.
In order to ascertain safe practices in ships operation and establish
safeguards against all identified risks, LSS-SAPU (collectively called
COMPANY) maintains and improves procedures, which are described in the
LSS-SAPU Manuals specific and detailed instructions are given therein,
which comply with the applicable Rules and Regulations while Codes and
Guidelines are taken into account.

In particular, the Company has established this Health, Safety & Environmental Protection Policy aiming at: • Providing Health, Safe, Environmental Protection Practices in ship Operation and a safe working environment. • Preventing damage to the ship, her cargo and the environment. • Assessing all identified risks to ships that safeguards, personnel and the environment. • Preventing loss of human life and personal injury. • Continually improving Health, Safety & Environmental Protection Management skills of personnel ashore and aboard ships, including preparing for emergencies related to Health, Safety and Environmental Protection. • Complying with all Legal Requirements, Mandatory Rules, Regulations and other Requirements, relating to Health, Safety, and Environmental Protection, to which the Company subscribes. • Effectively handling cases of illness and injury of its personnel. The very nature of their work produces a likelihood that from time to time, a security personnel will suffer sickness or injury at work or outside working hours, whether work related or not. Any such event is regrettable and LSS-SAPU has a desire and duty of care to manage each case with all due sympathy and with a degree of efficiency that ensures the casualty is afforded immediate treatment and suitable after-care.Unsuitable, inadequate or untimely treatment, lack of care or lack of sensitivity is undesirable and is damaging to LSS-SAPU reputation. • Taking into account all applicable Codes, Guidelines and Standards recommended by the Organization, Flag Administrations, Classification Societies and Marine Industry Organizations. • Committing for continual review and improvement of Health, Safety Management and Environmental Protection. • Communicating same to all persons working in the Company ashore and on board and be available to the public. • In order to effectively implement its Health, Safety, & Environmental Protection Policy the Company: • Consistently follows all National and International Rules and Regulations governing the Marine Industry. • Takes into account applicable Guidelines, Standards, Codes and publications which are issued by Maritime Organizations and are directed towards creating a Safe and Pollution Free Environment. • Continually monitors all Health, Safety and Environmental Protection aspects of the secured fleet. • Continually improves its Health, Safety, and Quality & Environmental Management System by taking corrective & preventive actions for identified problem areas. • Provides adequate resources to effectively implement this Management System.

The Company's Management is responsible for monitoring and reviewing the Health, Safety & Environmental Protection Policy at regular intervals in order to ensure that it remains relevant and effective.

LSS adhere to the highest standard of moral and ethical conduct, to respect local laws and not engage in any form of corrupt practices, including extortion, fraud, or bribery, at a minimum.

LSS and its personnel will not, consistent with its obligations under the United Nations Convention on Corruption and other international laws, applicable local law and policy, including the Law of Campaign Against Bribery and Official Corruption, , MOI Anti-Corruption Policy, and the Code of Conduct for Civil Servants, promise, offer, receive, solicit or give to any public or private official, directly or indirectly, money or anything of value to a public or private official himself or herself or another person or entity, in order to influence that public or private official to act or refrain from acting in the exercise of his or her official duties in violation of that lawful duty.
Neither LSS nor its personnel will solicit or accept, directly or indirectly, anything of value in exchange for not complying with national and international law or standards. LSS shall report all known violations of this provision to local law enforcement authorities, and any international authorities assisting local authorities, and the Client to the extent they are not the subject of said violations. LSS will cooperate with any resulting investigation authorized under local law.