Due Diligence Report - Noatum Maritime · Due Diligence Summary Marmedsa USA LLC TRACEcertification ID: TC4182-7425 Due diligence is not a guarantee against past or potential wrongdoing

* * * * T R A C E B o o k m a r k : C o v e r

Due DiligenceReport

TRA C E Inc . and TRA C E InternationalSuite 300151 Wes t StreetA nnapolis , MD 21401

info@TRA C E international.org+1 410 .990 .0076

TRA C Ecertif ication Due DiligenceReport

mailto:[email protected]

It means that an individual or company has completed a comprehensive due diligence process administered by TRACE, the world’s leading anti-bribery standard setting organization. Certification by TRACE signifies that an entity has completed internationally accepted due diligence procedures and has been forthcoming and cooperative during the review process. The successful completion of TRACEcertification demonstrates a commitment to commercial transparency, allowing the certified entity to serve as a valued business partner to multinational companies.

TRACEcertification Report at a Glance

› Detailed company information, including information on subsidiaries and affiliated entities.

› Business registrations, as applicable.

› Corporate literature or a company description.

› Beneficial ownership (except for shareholders owning less than 5% of publicly-traded companies).

› Identification of directors and key employees.

› Additional ownerships, directorships and employment of all owners, directors and key employees.

› Current government employment of owners, directors and key employees.

› Contact information for three business references.

› One financial reference or audited financial statement.

› Media and litigation searches dating back seven years in a comprehensive international database.

› Denied party screening and two negative media searches.

› Evidence of anti-bribery code of conduct and training.

TRACEcertification is not a guarantee against past or potential wrongdoing by the certified entity or a guarantee against potential liability. A summary of any “red flags” identified during the TRACEcertification review will be included in the report, but not all red flags preclude TRACEcertification.

About TRACETRACE International and TRACE Incorporated are two distinct entities with a common mission to advance commercial transparency worldwide by supporting the compliance efforts of multinational companies and their third party intermediaries. TRACE International is a non-profit business association that pools resources to provide members with anti-bribery compliance support while TRACE Incorporated offers both members and non-members customizable risk-based due diligence, anti-bribery training and advisory services. Working alongside one another, TRACE International and TRACE Incorporated offer an end-to-end, cost-effective and innovative solution for anti-bribery and third party compliance.

For more information, visit www.TRACEinternational.org. Follow TRACE:

› Gain a valuable compliance credential that differentiates you from competitors and is widely recognized in the international business community.

› Receive a copy of your verified due diligence report to share with an unlimited number of existing and prospective business partners.

› Include your name, or company’s name, in the TRACE Intermediary Directory, a publicly searchable database of potential business partners for multinational companies.

› Train up to 40 employees using TRACE’s multilingual online training modules including: Anti-Bribery Compliance, Avoiding Trafficked Labor, Conflicts of Interest and Conflict Minerals.

› Display the TRACE logo in your marketing materials and on your website to showcase your commitment to transparency and supply chain integrity.

› Attend TRACE Anti-Bribery Workshops at no cost.

Advantages of being TRACE Certified

What Does it Mean to be TRACE Certified?

* * * * T R A C E B o o k m a r k : T a b l e _ o f _ C o n t e n t s

* * * * T a b l e o f C o n t e n t s

Table of Contents

Due Diligence Summary 1

Business Information 4

Registration Information 7

Ownership Information & Board of Directors 15

Personnel 17

Name Confirmation Document 19

Resumes/CVs 21

Associated Offices & Entities 26

Other Engagements 34

Enforcement Information 36

Literature 39

Financials 67

Business References 69

Compliance Information 71

Reputational Screening 75

Additional Documents 77

Anti-Bribery Training 91

Marmedsa USA LLC certifies that the information provided in the following report is, to the best of itsknowledge and belief, accurate, current and complete.

Marmedsa USA LLC certifies that to the best of its knowledge, neither Marmedsa USA LLC nor any of itsemployees or third parties acting on its behalf have offered or given anything of value to a governmentofficial in order to obtain or retain business or receive an improper business advantage.

Marmedsa USA LLC agrees to notify TRACE promptly of any material changes to the information providedherein.

The person whose electronic signature appears below is authorized to certify on behalf of Marmedsa USALLC that the information is true and correct.

Name: BORIS KOSDate: 27 July 2018

* * * * T R A C E B o o k m a r k : D u e _ D i l i g e n c e _ S u m m a r y | D u e D i l i g e n c e S u m m a r y

Due DiligenceSummary

The TRACE due diligence review of commercial intermediaries is thorough. The review may nevertheless fail to uncoverinformation which, if available, would have discouraged or prevented companies from entering into a business relationship withthe intermediary. Companies requesting TRACE Reports agree that in no event shall TRACE be liable for any damages incurredas a result of relying on TRACE Reports or as a result of any omission or misrepresentation by an intermediary reviewed byTRACE.

This report contains personal information about individuals that is subject to strict legal protections under applicable dataprotection laws. You may only review this report or such personal information if you are appropriately authorized and have aneed to know, to access or to otherwise process such information. You must exercise due care in safeguarding this informationand take all necessary steps to prevent any loss, theft, corruption or release of this information to unauthorized persons. If youhave any questions or concerns regarding these obligations, contact TRACE at [email protected].

Page 1 of 92

mailto:[email protected]

1 August 2018 - 31 July 2019

Due Diligence Summary

Marmedsa USA LLCTRACEcertification ID: TC4182-7425

Due diligence is not a guarantee against past or potential wrongdoing or against potentialliability.

Depending on the nature, size, scope and location of the proposed project with anintermediary, more extensive due diligence may be warranted.

The following "red flags" or significant areas of concern were identified during the due diligencereview:

Disclosed intention to work with a third party intermediaryWorks with numerous third parties. See Associated Offices & Entities.

Due diligence undertaken by TRACE International or TRACE Inc. shall not be used to support orpromote business in Iran or other sanctioned countries.

Page 2 of 92

©2017 TRACE International, Inc. All rights reserved. www.TRACEinternational.org

United States of AmericaOverall Risk Score: 17

Level: very low

This score is a composite of the four domain scores discussed below.

The bar chart below shows the United States of America’s total risk scores in 4 domains: (1) Business Interactions with

Government, (2) Anti-Bribery Laws and Enforcement, (3) Government and Civil Service Transparency and (4) Capacity for

Civil Society Oversight. The four domain scores are weighted and combined and a risk penalty is added for individual

domain scores that exceed the overall country risk score. Each country is given a score from 1 to 100 for each domain,

and for the total bribery risk. A higher score indicates a higher risk of business bribery.

1. Business Interactions with Government: The United States of America receives a low score of 22 in this domain, based on a low degree of government interaction, low expectation of bribes, and a very low regulatory burden.

2. Anti-Bribery Laws and Enforcement: The United States of America receives a low score of 23 in this domain, based on a high quality of anti-bribery laws and a high quality of anti-bribery enforcement.

3. Government and Civil Services Transparency: The United States of America receives a very low score of 8 in this domain, based on very good governmental transparency and very good transparency of financial interests.

4. Capacity for Civil Society Oversight: The United States of America receives a very low score of 14 in this domain, based on a very high degree of media freedom/quality and a very high degree of social development.

Domain Risk Score

Overall Bribery Risk to Business 17

1. Business Interactions withGovernment

22

2. Anti-Bribery Laws andEnforcement

23

3. Government and CivilService Transparency

8

4. Capacity for Civil SocietyOversight

14

Snapshot

Size: 3,537,438 square km

2016 GDP: USD 56,496 per capita

Population: 328,677,531

Page 3 of 92

* * * * T R A C E B o o k m a r k : B u s i n e s s _ I n f o r m a t i o n | Q u e s t i o n S e c t i o n 1

BusinessInformation

Page 4 of 92

Business Information

Company's Full Legal Name: Marmedsa USA LLC

Doing Business As Name orTrade/Marketing Name:

"Marmedsa Oil & Gas Noatum Maritime" and "Marmedsa Oil & Gas"

Address of Headquarters/Principal Place of Business:

5656 N Sam Houston PKWY E,. Ste 150

City: Houston

State/Province: TX

Country: United States of America

Postal Code: 77032

Telephone: 281-247-0357

Website: www.noatummaritime.com

Contact Person: Boris Kos

Work E-mail Address: [email protected]

Job Title/Position: Managing Director

Contact Person: Khaysy Murasaki


Job Title/Position: Director Compliance and Corporate Broker

Contact Person: Yalonda Henderson


Job Title/Position: Director of Operations

Contact Person: Natasha D Rozario


Job Title/Position: Director, Commercial

Primary Industry: Consulting, Logistics / Freight Forwarding

Types of services: Consultant, Other: Customs Brokerage, Marine Agency, Project Management,Warehousing & Storage

Marmedsa USA LLC provides services in the following countries: Algeria, Brazil, Chile, China, France,Germany, Morocco, Netherlands, Portugal, Russia, Spain, Sweden, Turkey, United Arab Emirates,United States of America

Marmedsa USA LLC asks to be paid, and makes payments from: United States of America

Method(s) by which Marmedsa USA LLC prefers to receive payments: Wire Transfer

Page 5 of 92

Brief description of the types of services that Marmedsa USA LLC provides: Once all requiredLicenses have been obtained such as FMC, TSA, IATA, Customs Bond, Customs Broker License,Permits, etc., Marmedsa USA LLC will cover main parts of the Logistics chain, such as Customsbrokerage, freight forwarding, warehousing & Storage, and containers.

Specific services to the Oil & Gas Industry included are Rig & Maritime, Supply Base Logistics,Supply Chain Management, & Project Management. Trade Compliance Consulting as needed forTrade Exporters and Importers.

Additional Information: Marmedsa USA LLC provides services globally through our network of ownedoffices and others through strategic partner alliances after the completion of vendor processapproval.

The website provided above belongs to our parent company which contains the link to the USAlocation for "Marmedsa USA LLC." http://www.noatummaritime.com/localizacion-y-contacto/usa/

Page 6 of 92

* * * * T R A C E B o o k m a r k : R e g i s t r a t i o n _ I n f o r m a t i o n | Q u e s t i o n S e c t i o n 1 1

RegistrationInformation

Page 7 of 92

Registration Information

Marmedsa USA LLC was established on: 26 February 2018

Additional Information: The Effective date on the Certificate of Filing is 2.26.2018. The amendmentdate 4.2.2018 is due to clerical entity error "Marmedsa US LLC" has been accepted.

Tax Identification Number of Marmedsa USA LLC: 82-4596935

Marmedsa USA LLC is registered as a legal entity and holds the following registrations, licenses orcertifications:

Registration Number: 802946759

Registration Date: 26 February 2018

This registration does not expire.

Office/Entity/Agency: Office of the Secretary of State

City: Austin


Copy of this registration:

Page 8 of 92

Page 9 of 92

Page 10 of 92

Page 11 of 92

Page 12 of 92

Page 13 of 92

Additional Information: Registration with Harris County, Houston, Texas Completed for businessoperation 3.8.2018

Page 14 of 92

* * * * T R A C E B o o k m a r k : O w n e r s h i p _ I n f o r m a t i o n _ & _ B o a r d _ o f _ D i r e c t o r s | Q u e s t i o n S e c t i o n 2

OwnershipInformation &Board ofDirectors

Page 15 of 92

Ownership Information & Board of Directors

Marmedsa USA LLC is a Private Company.

No individuals have an ownership interest in Marmedsa USA LLC.

The following corporations/other legal entities have an ownership interest in Marmedsa USA LLC:

Entity Name: Noatum Maritime Services, S.L.U.

Name in locallanguage/characters:

Noatum Maritime Services, S.L.U.

Country of Incorporation: Spain

Ownership Percent: 100

Ownership Information: Noatum Maritime Services, S.L.U. is owned 100 % by "NoatumMaritime Services, S.L.U. Calle Luxemburgo, 3 (C.T.C) - 28821Coslada (Spain).

Noatum Maritime Services, S.L.U. Calle Luxemburgo, 3 (C.T.C) -28821 Coslada (Spain)" is owned 100 % by Turia Port ManagementInvestments (Holding) C.V.

Turia Port Management Investments (Holding) C.V. is a privatecompany registered in the Netherlands. Ownership of Turia PortManagement Investments (Holding) C.V.: Morgan Stanley IndiaInvestment Fund, Inc. (IIF) - 100%.

Morgan Stanley India Investment Fund, Inc. (IIF) is a publiccompany listed on the New York Stock Exchange. Shareholders ofMorgan Stanley India Investment Fund, Inc. (IIF) holding 5% orgreater shares: City of London Investment Management Co.Limited, the London Stock Exchange - 16.02%.

The following individuals are the members of the Board of Directors of Marmedsa USA LLC:

Name: Boris Kos


Name: Yalonda Henderson


Name: Khaysy Murasaki


Name: Natasha D Rozario


Additional Information: Boris Kos is the Initial Manager. Khaysy Murasaki (LCB), Yalonda Henderson,and Natasha D Rozario are the Initial Officers of the Company.

Page 16 of 92

* * * * T R A C E B o o k m a r k : P e r s o n n e l | Q u e s t i o n S e c t i o n 4

Personnel

Page 17 of 92

Personnel

Marmedsa USA LLC’s total number of personnel (including managers and directors): 4

The following personnel of Marmedsa USA LLC are authorized to make binding decisions forMarmedsa USA LLC and enter into contracts with clients:

Name: Boris Kos








The following personnel of Marmedsa USA LLC market or sell products/services to customers:

Name: Boris Kos








The following personnel of Marmedsa USA LLC may interact with a government official or governmententity:

Name: Boris Kos








Additional Information: Khaysy Murasaki is a Licensed Customs Broker (license # 30730), willinteract with Customs and Border Protection (CBP), U.S Customs Officials as needed and whenrequired.

Boris Kos, Yalonda Henderson, and Natasha D Rozario will interact with Transportation SecurityAdministration (TSA) as needed and when required for Audits.

Page 18 of 92

* * * * T R A C E B o o k m a r k : N a m e _ C o n f i r m a t i o n _ D o c u m e n t | Q u e s t i o n S e c t i o n 1 5

NameConfirmationDocument

Page 19 of 92

Name Confirmation Document

Name Providedto TRACE

Given/FirstName

Middle Name(s) /Patronymic

Family/LastName(s)

Name(s) CommonlyUsed in Business

Boris Kos Boris Kos Boris Kos

YalondaHenderson

Yalonda Renee Henderson Yalonda Henderson

Khaysy Murasaki Khaysy Murasaki Khaysy Murasaki

Natasha DRozario

Natasha Smita D Rozario Natasha D'Rozario-Frey

Page 20 of 92

* * * * T R A C E B o o k m a r k : R e s u m e s / C V s | Q u e s t i o n S e c t i o n 1 9

Resumes/CVs

Page 21 of 92

Resumes/CVs

Company/Entity Position BeginningDate

Does Boris Koscurrently hold thisposition?

EndingDate

Marmedsa USALLC

Managing Director March2018

Boris Kos currentlyholds this position.

KA InternationalSourcing GroupLLC

Managing Member, ManagingDirector

January2013

No March2018

EnscoInternational Inc

Director, Supply Chain -Global Logistics & TradeCompliance

June 2011 No September2016

PRIDEInternational Inc

Senior Manager, Supply Chain- Global Logistics & Trade

January2007

No May 2011

Name: Boris Kos

Citizenship: United States of America

Boris Kos is involved in the day-to-day operations of Marmedsa USA LLC.

Boris Kos holds the following positions or ownership interests in entities other than Marmedsa USALLC:

Company: KA International Sourcing Group LLC

Position: Owner

Boris Kos has not held or worked in a government or military position in the last seven years.

Boris Kos does not currently hold any position with a political party or political campaign and is notcurrently a candidate any political office.

No family members of Boris Kos currently hold any government positions.

Page 22 of 92


Does Yalonda Hendersoncurrently hold this position?

EndingDate

Marmedsa USALLC

Director Operations March2018

Yalonda Henderson currently holdsthis position.

Inchcape ShippingServices

General ManagerService Center

September2017

No March2018

GAC NorthAmerica

Project Manager April 2010 No August2017

Kuehne-Nagel Inc Seafreight ImportManager

November2006

No April2010



Yalonda Henderson is involved in the day-to-day operations of Marmedsa USA LLC.

Yalonda Henderson does not hold a position or ownership interest in any entity other than MarmedsaUSA LLC.

Yalonda Henderson has not held or worked in a government or military position in the last sevenyears.

Yalonda Henderson does not currently hold any position with a political party or political campaign andis not currently a candidate any political office.

No family members of Yalonda Henderson currently hold any government positions.

Page 23 of 92


Does Khaysy Murasakicurrently hold thisposition?

EndingDate

Marmedsa USA LLC Director Complianceand Corporate Broker

March2018

Khaysy Murasaki currentlyholds this position.

KA InternationalSourcing GroupLLC

Trade ComplianceConsultant

November2017

No February2018

Star Pipe Products International TradeCompliance Manager

April 2017 No October2017

Ensco Inc Supervisor - TradeCompliance

September2011

No April 2017

Kuehne - Nagel Inc Supervisor - Oil & Gas June 2006 No September2011



Khaysy Murasaki is involved in the day-to-day operations of Marmedsa USA LLC.

Khaysy Murasaki does not hold a position or ownership interest in any entity other than MarmedsaUSA LLC.

Khaysy Murasaki has not held or worked in a government or military position in the last seven years.

Khaysy Murasaki does not currently hold any position with a political party or political campaign and isnot currently a candidate any political office.

No family members of Khaysy Murasaki currently hold any government positions.

Page 24 of 92


Does Natasha D Rozariocurrently hold thisposition?

EndingDate

Marmedsa USA LLC Director, Commercial March2018

Natasha D Rozario currentlyholds this position.

GAC Energy &Marine ServicesLLC

National PricingManager

January2015

No November2017

MoveOne Inc(Dubai, UAE)

Commercial &Insurance Manager

September2012

No November2013

GAC Group (Dubai,UAE)

Group CommercialData Administrator

October2003

No August2012



Natasha D Rozario is involved in the day-to-day operations of Marmedsa USA LLC.

Explanation of any gaps in employment (1 year or more): Nov 30, 2013 – January 01, 2015: Plannedtime off due to maternity and relocation from Dubai to USA.

Natasha D Rozario does not hold a position or ownership interest in any entity other than MarmedsaUSA LLC.

Natasha D Rozario has not held or worked in a government or military position in the last sevenyears.

Natasha D Rozario does not currently hold any position with a political party or political campaign andis not currently a candidate any political office.

No family members of Natasha D Rozario currently hold any government positions.

Page 25 of 92

* * * * T R A C E B o o k m a r k : A s s o c i a t e d _ O f f i c e s _ & _ E n t i t i e s | Q u e s t i o n S e c t i o n 1 2

AssociatedOffices & Entities

Page 26 of 92

Associated Offices & Entities

Marmedsa USA LLC does not have any subsidiary organizations or joint ventures.

Marmedsa USA LLC has the following branch offices:

Name: Marmedsa USA LLC

City: Houston


Marmedsa USA LLC is part of a group companies:

Name of the Group: Noatum Maritime Services, S.L.U

Marmedsa USA LLC’s Relationship to the Group: Noatum Maritime Services, S.L.U is theparent company.

This group is a Marketing Name.

Numerous companies are part of this group, listed on the following page:

Page 27 of 92

Group of Companies Listed in Noatum Maritime Services, S.L.U.

1. Universal Global Logistics SAU 2. Combalia Agencia Marrítima, S.A 3. Marmedsa Bemarine 4. Samskip Multimodal Container 5. Viajes Cosmos 6. Marmedsa Turkey 7. Noatum Codemar Tarragona 8. Marmedsa, S.A.R.L. 9. Universal Marítima 10. Marmedsa Group Portugal 11. Frigoríficos Castellon 12. Marmedsa Marroc 13. Marmedsa Chartering 14. Progeco España 15. Marmedsa Noatum Chile 16. Noatum Terminal Castellon 17. Montañesa de Consignaciones 18. Lematrans Castellón 19. Elite Spain 20. Marmedsa Noatum Shipping Agency 21. Universal Maritima Noatum Shipping Agency 22. Marmedsa Logistica Noatum Shipping Agency 23. Marmedsa Bemarine Noaatum Shipping Agency & Logistics 24. Marmedsa chartering Noatum Maritime 25. Marmedsa oil & gas Noatum Maritime 26. Combalia Noatum Shipping Agency 27. ERHARDT Mediterraneo 28. Martima Consiflet 29. Lematrans Agencia De Transportes 30. Noatum Logistics by Universal global Logistics 31. Universal Forwarding Noatum Logistics 32. Komet Noatum Logistics 33. Actanis Project Cargo 34. Atlas Forwarding 35. Atlas Mediterraneo 36. C. Steinweg Iberia, S.L 37. TANDEM Global Logistics 38. Noatum Terminal Tarragona 39. Noatum Terminal Castellon 40. Noatum Terminal Nalaga 41. Noatum Terminal Santander 42. Leatransa Castellon 43. S.L.P. Bilbao 44. TMC Estibadores Portuarios

Page 28 of 92

45. Quality Depot Progeco Barcelona 46. Progeco Vigo 47. TMGA A coruna – Ferrol 48. G & T Port Castellon 49. Vigo Fresh Port 50. Fricasa, Noatum Reefer Terminal Castellon 51. Noatum Terminal Sagunto 52. Noatum UECC Terminal Pasaies 53. Autoterminal Barcelona 54. Progeco Bilbao 55. Marforwd Noatum Shipping Agency

Page 29 of 92

The following group companies will be involved in transactions for, or provide services to,Marmedsa USA LLC’s clients/vendors/suppliers:

Name: Universal Global Logistics SAU

Provides services in the following manner: International Freight Forwarding, Seafreight, Airfreight & Logistics

Name: Combalia Agencia Marrítima, S.A

Provides services in the following manner: Subsidiaries in the group of companies mayprovide third party services if needed.

Name: Marmedsa Bemarine


Name: Samskip Multimodal Container


Name: Viajes Cosmos


Name: Marmedsa Turkey


Name: Noatum Codemar Tarragona


Name: Marmedsa, S.A.R.L.


Name: Universal Marítima


Name: Marmedsa Group Portugal


Name: Frigoríficos Castellon


Name: Marmedsa Marroc


Name: Marmedsa Chartering


Name: Progeco España


Name: Marmedsa Noatum Chile

Page 30 of 92


Name: Noatum Terminal Castellon


Name: Montañesa de Consignaciones


Name: Lematrans Castellón


Name: Elite Spain


Name: Marmedsa Noatum Shipping Agency


Name: Universal Maritima Noatum Shipping Agency


Name: Marmedsa Logistica Noatum Shipping Agency


Name: Marmedsa Bemarine Noaatum Shipping Agency & Logistics


Name: Marmedsa chartering Noatum Maritime


Name: Marmedsa oil & gas Noatum Maritime


Name: Combalia Noatum Shipping Agency


Name: ERHARDT Mediterraneo


Name: Martima Consiflet


Name: Lematrans Agencia De Transportes


Name: Noatum Logistics by Universal global Logistics

Page 31 of 92


Name: Universal Forwarding Noatum Logistics


Name: Komet Noatum Logistics


Name: Actanis Project Cargo


Name: Atlas Forwarding


Name: Atlas Mediterraneo


Name: C. Steinweg Iberia, S.L


Name: TANDEM Global Logistics


Name: Noatum Terminal Tarragona


Name: Noatum Terminal Castellon


Name: Noatum Terminal Nalaga


Name: Noatum Terminal Santander


Name: Leatransa Castellon


Name: S.L.P. Bilbao


Name: TMC Estibadores Portuarios


Name: Quality Depot Progeco Barcelona

Page 32 of 92


Name: Progeco Vigo


Name: TMGA A coruna - Ferrol


Name: G & T Port Castellon


Name: Vigo Fresh Port


Name: Fricasa, Noatum Reefer Terminal Castellon


Name: Noatum Terminal Sagunto


Name: Noatum UECC Terminal Pasaies


Name: Autoterminal Barcelona


Name: Progeco Bilbao


Name: Marforwd Noatum Shipping Agency


Marmedsa USA LLC uses the following individuals or entities to provide services or to perform part ofMarmedsa USA LLC's activities.

Name: Gulf Freight Management, LLC

Provides services in the following manner: GFM currently provides freight logistics via air, sea,land on Marmedsa USA LLC behalf.

Marmedsa USA LLC has not been a party to any mergers or acquisitions over the past 5 years.

No other person, entity, government or government entity has any management right or financialinterest in Marmedsa USA LLC.

Additional Information: Noatum Maritime Services, S.L.U and Universal Global Logistics, S.A.U. arethe main companies working on oil and gas projects.We confirmed that Noatum Maritime Services, S.L.U Group does not have any additional companieswhich must be listed under the group.

Page 33 of 92

* * * * T R A C E B o o k m a r k : O t h e r _ E n g a g e m e n t s | Q u e s t i o n S e c t i o n 6

OtherEngagements

Page 34 of 92

Other Engagements

Marmedsa USA LLC will not market products or services to any government, government-controlled,or military entity, including state-owned enterprises.

Marmedsa USA LLC does not have any contracts with, or provide services directly to, anygovernment, government-controlled or military entity, including any state-owned enterprises.

No people listed in this report directly have any contracts with, or provide services directly to, anygovernment, government-controlled or military entity, including any state-owned enterprises.

Page 35 of 92

* * * * T R A C E B o o k m a r k : E n f o r c e m e n t _ I n f o r m a t i o n | Q u e s t i o n S e c t i o n 1 3

EnforcementInformation

Page 36 of 92

Enforcement Information

No person or company associated with Marmedsa USA LLC has ever been convicted of violating anyrules or regulations governing the purchase or sale of goods or services to or by any government.

No person or company associated with Marmedsa USA LLC has ever been interviewed, deposed orsubpoenaed in connection with any litigation or investigation involving any government regulations.

No person or company associated with Marmedsa USA LLC has ever been found guilty of violatingany law governing donations, contributions, honoraria or any other form of remuneration to anygovernment official or any individual working for a commercial enterprise.

No person or company associated with Marmedsa USA LLC has ever been interviewed, deposed orsubpoenaed in connection with any litigation or investigation involving any law governing donations,contributions, honoraria or any other form of remuneration to any government official or anyindividual working for a commercial enterprise.

No person or company associated with Marmedsa USA LLC has ever been interviewed, subpoenaed orasked to testify before any legislative body concerning fraud or abuse with regard to anygovernmental procurements.

No person or company associated with Marmedsa USA LLC has ever been found guilty of anyviolations of securities or commodities trading laws.

No person or company associated with Marmedsa USA LLC has ever been interviewed, deposed orsubpoenaed in connection with any litigation or investigation involving any violations of securities orcommodities trading laws.

No person or company associated with Marmedsa USA LLC has ever been found guilty of anyviolation of any laws governing the regulation of antitrust practices.

No person or company associated with Marmedsa USA LLC has ever been the subject of, ormentioned by name in, any newspaper or magazine article in an adverse manner.

No person or company associated with Marmedsa USA LLC has ever been charged, interviewed orfound guilty concerning income tax evasion.

No person or company associated with Marmedsa USA LLC has ever been convicted of a felony orother criminal act for any matter not listed above.

Excluding traffic charges, no person associated with Marmedsa USA LLC has ever been arrested,charged, cited or held by law enforcement authorities regardless of whether the charge was dropped,dismissed or a verdict of not guilty was entered.

No person or company associated with Marmedsa USA LLC has ever been debarred from competingfor World Bank contracts.

No person or company associated with Marmedsa USA LLC has ever been debarred from competingfor government contracts in any country.

No person or company associated with Marmedsa USA LLC has ever had a security clearance deniedor revoked.

No person associated with Marmedsa USA LLC has ever been discharged from any Armed Forces withother than an honorable discharge.

Page 37 of 92

No person or company associated with Marmedsa USA LLC has ever been the subject of anyvoluntary or involuntary bankruptcy or other similar proceeding.

No person or company associated with Marmedsa USA LLC is named on any regulatory orgovernment watch lists.

No person or company associated with Marmedsa USA LLC has ever admitted guilt for, beenconvicted of, or is currently under investigation for Trade Control violations (such as violations ofexport controls, sanctions, and anti-boycott laws or regulations).

No person or company associated with Marmedsa USA LLC has ever been placed on any restrictedparties lists.

No person or company associated with Marmedsa USA LLC has any offices or other operations inCuba, Iran, North Korea, the Republic of Sudan or Syria.

No person or company associated with Marmedsa USA LLC has ever donated, sold, exported, re-exported or otherwise transferred, purchased or imported, directly or indirectly through thirdcountries or parties, equipment, products, funds or services to or from Cuba, Iran, North Korea, theRepublic of Sudan or Syria or otherwise serviced (or requested services in relation to) productslocated in these countries without the requisite license in place.

Page 38 of 92

* * * * T R A C E B o o k m a r k : L i t e r a t u r e | Q u e s t i o n S e c t i o n 1 7

Literature

Page 39 of 92

Literature

Marmedsa USA LLC provided the following company brochure or other literature:

Page 40 of 92

Page 41 of 92

Page 42 of 92

Page 43 of 92

Excellence in maritime services2018

Page 44 of 92

About Noatum MaritimePRESENTATIONAT A GLANCEINTEGRATED MANAGEMENT SYSTEMNETWORK OF OFFICESCOMPANIESACTIVITIESMAIN FIGURES 2016

Page 45 of 92

NOATUM MARITIME - PRESENTATION 3

Noatum Maritime was founded in 1963 as Marítima del Mediterráneo (Marmedsa), initially dedicated to being a shipping agency.

Today, it is renowned for the excellence of its service and for its specialised and reliable staff who have made the company a benchmark in the sector.

9COUNTRIES

73COMPANIES

60PRESENCE IN PORTS

+1100EMPLOYEES

12TERMINALS

5DEPOTS

Page 46 of 92

NOATUM MARITIME AT A GLANCE - YEAR 2016 4

+10,200SHIP CALLS

+1,2MVEHICLES

+11,8MTONNES BULK &

GENERAL CARGO

+584KTEUs

Page 47 of 92

NOATUM MARITIME - INTEGRATED MANAGEMENT SYSTEM, CERTIFICATIONS & MEMBERSHIP 5NOATUM MARITIME - INTEGRA

HEALTHAND SAFETY OHSAS 18001

ENVIRONMENTISO 14001

QUALITYISO 9001

TIMS

EIS

+

CERTIFICATIONS

AEO – Customssimplification - Security

CODEX Alimentarius

Referenciales Puertos del Estado

Good ManufacturingPractices (GMP+)

Good DistributionPractices (GDP)

Achilles (FPAL, REPRO y DOCUPLUS)

Legal Compliance (TRACE)

Marca de Garantía (Valencia)

Efficiency Network (Barcelona)

+

MEMBERSHIP

+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++Associate Member Active Level

Page 48 of 92

NOATUM MARITIME - NETWORK OF OFFICES (64 LOCATIONS) 6

CHILE

SPAIN• Barcelona• Tarragona• Castellón• Sagunto• Valencia• Alicante• Cartagena• Málaga

22• Bilbao• Pasajes• Madrid• Palma • Tenerife• Las Palmas

• Algeciras• Cádiz• Huelva• Vigo• A Coruña• Ferrol• Gijón• Santander

PORTUGAL• Viana do Castelo• Porto

• Setúbal• Sines

6• Aveiro• Lisboa

MOROCCO• Tangier• Casablanca

• Agadir5

• Jorf Lasfar• Safi

ALGERIA• Ghazaouet• Oran• Arzew• Mostaganem

• Djendjen• Skikda• Annaba

10• Ténès• Algiers• Bejaia

TURKEY• Istanbul• Gaziantep

• Mersin4

• Izmir

CHILE• Santiago

1

FRANCE• Marseille• Fos-Lavera

• Bordeaux5

• La Pallice• Le Havre

CHINA• Beijing • Dalian • Guangzhou• Hong Kong•

• Shenzhen• Tianjin• Xiamen

10• Ningbo • Qingdao • Shanghai

NOATUM MARITIME COMPANIES INVESTEE COMPANIES

USA• Huston

1

Page 49 of 92

NOATUM MARITIME - COMPANIES 7

BILBAO

CASTELLÓN CARTAGENA A CORUÑA - FERROL

BARCELONA

Page 50 of 92

NOATUM MARITIME - ACTIVITIES 8

PROJECT CARGO

WAREHOUSING & DISTRIBUTION

CUSTOMS

ONLINE SERVICE

IT INTEGRATIONS WITH CUSTOMER

INSURANCES

TRAMP AGENCY

REEFER CARGOES

DRY CARGO CHARTERING

OUTSOURCING

LIQUID BULK

LAND TRANSPORT & DISTRIBUTION OF CONTAINERS

AUTOMOTIVE LOGISTICS

REGULAR LINE

OUTSOURCE / IMPLANTS

MULTIPURPOSE TERMINALS DEPOTSREEFER TERMINALS

RO-RO TERMINALSBULK TERMINALS

OIL & GAS

CONTAINER TERMINALS

FREIGHT FORWARDING

SUPPLY CHAIN MANAGEMENT

CONSULTANCYTRAMP AGENCYTRAMP AGENCY

MULTIPURPOSE TERMIN

FREIGHT FORWARD

Page 51 of 92

NOATUM MARITIME - SECTORIAL SOLUTIONS 9

Each industry has its specific needs and characteristics, and therefore requires different transportation and logistics solutions tailored to its own conditions.

At Noatum Maritime, we know your specific operating needs and we offer the most suitable solution for each industrial sector.

AUTOMOTIVE

CONSTRUCTION

CRUISES

FOODHOTEL INDUSTRY

OIL & GAS

PHARMACEUTICAL

INDUSTRY

FASHION

PHARMA IRON & STEEL REEFER

ENERGY

SPORT EVENTS

Page 52 of 92

NOATUM MARITIME - FIGURES 2016 10

226,000

860,000

715,000

55,000

99,000

141,000

278,000

9,900

99,000

217,000

10,703,000 TON

6COUNTRIES

47PRESENCE IN PORTS

+590EMPLOYEES

7COUNTRIES

39OFFICES

+400EMPLOYEES

1COUNTRY

12TERMINALS

+185EMPLOYEES

10,200

10,703,000 TONNES

43,000 PALLETS(reefer)

365,800 CONTAINERS(handled in depots)

1,226,000 RO-RO

5DEPOTS

SHIP CALLS ATTENDED

TEUs (EX/IM)

TONNES

VEHICLES

CUSTOMS CLEARANCES

TRANSPORT OPERATIONS

TEUs (EX/IM)

SEAFREIGHT TONNES

AIRFREIGHT TONNES

CBM LCL

TEUs (EX/IM)

Page 53 of 92

Marmedsa Oil & GasPRESENTATIONSPECIFIC SERVICES TO THE OIL & GAS INDUSTRYADDED-VALUE SERVICESTERMINALS LOCATION

Page 54 of 92

MARMEDSA OIL & GAS

Our international branches and facilities are in constant expansion and renewal to maintain and improve our standards of excellence in each business area throughout every process and project. Our goal in business is to meet your individual requirements by providing dedicated support in each area. From upstream supply for explorations through to OOS upgrades with all operational onsite services.

By the integration of our related specialized business areas, Port, Logistics and Maritime Services, we have the capabilities to support and meet the demands arising within the O&G industry.

We have branches within the main Spanish ports as in other countries. Our key areas for operations span from: Canary Islands (Las Palmas & Tenerife); Mainland Spain (with terminals/logistics bases in Malaga, Cartagena, Barcelona, Tarragona and A Coruña), Portugal, Turkey, Morocco, Algeria and Chile.

Rely on us during your stay in any of our ports where we shall, in an efficient, cost effective and professional manner, do our utmost to exceed your expectations. Allow us to take care of you!

12

PRESENTATION

Page 55 of 92

MARMEDSA OIL & GAS 13

SPECIFIC SERVICES TO THE OIL & GAS INDUSTRY

By merging our expert services provided within the related specialized business areas of Noatum Maritime (Port, Logistics and Maritime) we can offer our Offshore clients the desired “Shipyard in a Box” for each project be it OOS Upgrading, Warm & Cold Stacking, Gas & Oil Exploration, Bunkering or Scrap:• 24/7 attendance - Our Shipping Agency will attend to your offshore requirements

• Project assistance with professional qualified personnel.

• Crew change/Immigration/Visas/Accommodation & Transfers (by sea, land or air).

• All Customs compliance formalities.• Complete Logistic services throughout.• Financial Services Cost Control (weekly).• Onsite offices set-up/Internet/Fresh Water/supply vessels/ Catering Services/Waste residues collection, Supply of materials (edibles/technical, etc.)

Page 56 of 92


We can coordinate all the necessary upgrade services through competent companies to accomplish & maintain excellence in your standards. For example:

• Sub Sea Engineering (Thrusters/Drilling Pipe removals, etc.)

• Electrical & Mechanical engineers

• Operational support services for shore based requirements.

• Health & Safety support & compliance.

• Marine Insurance Liability is covered by Allianz.

• Divers (For inspections, etc.)

• Blasting and Painting.• Piping• Refurbishment, etc.

SPECIFIC SERVICES TO THE OIL & GAS INDUSTRY

Page 57 of 92


ADDED-VALUE SERVICES

Understanding the capital importance of deliveries and the economical repercussions for the owners, we offer a complete ‘door to deck’ delivery service. As IATA agents, ship agents and authorized custom broker, we provide:• Outdoor and indoor warehouses/storage areas inside the Port Area for use prior to/during and after vessels arrival or departure.

• Various global line carriers to support the shipment of spare-parts and materials.

• Through the forwarding and logistics companies of our group, we ensure our personal & undivided attention through transport to delivery, chartering aircraft where and when required.

• Liaise with customs to obtain Free Zone Areas for the handling of spares at a logistics base.

Page 58 of 92

MARMEDSA OIL & GAS - TERMINALS LOCATION 16

,

A CORUÑA

TARRAGONA

CARTAGENA

MÁLAGA

TERMINALES MARÍTIMOS DE GALÍCIA (TMGA)A CORUÑA

Surface 121,000 sqmBerth 4,157 mStorage Area 43,000 sqmDepth 16,5-22 m

,

TERMINAL MARÍTIMA DE CARTAGENA (TMC)CARTAGENA

Surface 100,000 sqmBerth 800 mStorage Area 6,000 sqmDepth 11 m

,

NOATUM TERMINAL MÁLAGAMÁLAGA

Surface 365,000 sqmBerth 175-723 mStorage Area 80,000 sqmDepth 16 m

,

NOATUM TERMINAL TARRAGONATARRAGONA

Surface 77,000 sqmBerth 5,000 mStorage Area 57,000 sqmDepth 12-16 m

FRANCE

ALGERIAMOROCCO

POR

TUG

AL

SPAIN

Page 59 of 92

www.noatummaritime.com

Page 60 of 92

Page 61 of 92

Page 62 of 92

Page 63 of 92

Page 64 of 92

Page 65 of 92

Marmedsa USA LLC was not able to provide pictures of offices, facilities and equipment relevant toproviding services.

Page 66 of 92

* * * * T R A C E B o o k m a r k : F i n a n c i a l s | Q u e s t i o n S e c t i o n 1 0

Financials

Page 67 of 92

Financials

Financial References:

TRACE received the following response on: 9 May 2018

Marmedsa USA LLC does not have a recent audited financial statement prepared by an externalauditor.

Type: Bank

Company/InstitutionName:

BBVA Compass

Contact Name: Bibiana Grajales

Job Title: International Commercial Banking

Email Address: [email protected]

Address: 901 Via Piemonte, Suite 140

City: Ontario

State/Province: CA

Postal Code: 91764


Telephone: 909-285-3946

How long has your firm had a business relationship with Marmedsa USA LLC?: Two months

Is Marmedsa USA LLC's account maintained satisfactorily?: Yes

Electronic Signature Name:

Alex Amaya

Job Title/Position: Vice President, International Commercial Banking

Company: BBVA Compass Bank

Date: 9 May 2018

Marmedsa USA LLC has stated that its books and records are maintained in accordance with generallyaccepted accounting practices.

Marmedsa USA LLC has certified that it is adequately financed and has sufficient resources to conductbusiness.

Additional Information: Marmedsa USA LLC is a newly established USA entity as of Feb. 26, 2018.The parent company is Noatum Maritime Services, SLU, located in Spain.ADP handles our Small Business Payroll and Human Resource.

Page 68 of 92

* * * * T R A C E B o o k m a r k : B u s i n e s s _ R e f e r e n c e s | Q u e s t i o n S e c t i o n 9

BusinessReferences

Page 69 of 92

Business References

Business References:

Company Name: BBC Chartering

Contact Name: Peter Basler

Job Title: Charter Sales Manager/ Business Development


Address: 6565 West Loop South, Suite 200

City: Bellaire

State/Province: TX

Postal Code: 77401


Telephone: 713-504-0654

This is a personal reference about a specific owner, director, or key employee.

Person Whom theReference is About:

Boris Kos

Company Name: Dan-Bunkering

Contact Name: Jim Jensen

Job Title: Managing Director


Address: 840 Gessner, Suite 210

City: Houston

State/Province: TX

Postal Code: 77024


Telephone: 281-833-5811

This is a personal reference about a specific owner, director, or key employee.

Person Whom theReference is About:

Boris Kos

Company Name: Gulf Freight Management, LLC

Contact Name: Michael Higgins

Job Title: President


City: Houston

State/Province: TX

Postal Code: 77015


Telephone: +1 281 214 7718

Page 70 of 92

* * * * T R A C E B o o k m a r k : C o m p l i a n c e _ I n f o r m a t i o n | Q u e s t i o n S e c t i o n 1 4

ComplianceInformation

Page 71 of 92

Compliance Information

TRACE Code of Conduct

Marmedsa USA LLC hereby adopts the following Code of Conduct with respect to all commercialtransactions, whether local or international:

LOCAL AND FOREIGN LAWS: Neither Marmedsa USA LLC, nor anyone acting on behalf ofMarmedsa USA LLC, may, directly or indirectly, break or seek to evade the laws or regulations of anycountry in, through, or with which Marmedsa USA LLC seeks to do business. That an illegal act is a“customary business practice” in any country is not sufficient justification for violation of thisprovision.

BRIBERY AND FACILITATING PAYMENTS: Neither Marmedsa USA LLC, nor anyone acting onbehalf of Marmedsa USA LLC, may, directly or indirectly, offer or provide a bribe, and all demands forbribes must be expressly rejected.

Bribery includes any offer, promise, or gift of any pecuniary or other advantage, whether directly orthrough intermediaries, to a public official, political party, political candidate or party official or anyprivate sector employee, in order that the official or employee act or refrain from acting in relation tothe performance of their duties, in order to obtain or retain business or other business advantage.

Neither Marmedsa USA LLC, nor anyone acting on behalf of Marmedsa USA LLC, shall offer or makefacilitating payments to government officials in order to encourage them to expedite a routinegovernmental task that they are otherwise required to undertake. Marmedsa USA LLC, or anyoneacting on behalf of Marmedsa USA LLC, shall have discretion to deviate from this prohibition if he/shebelieves that there is an immediate threat to his/her or another’s health or safety. The circumstancesof such payment must be reported as soon as possible after the event and the payment properlyrecorded. Marmedsa USA LLC recognizes that extortion is widespread and that participation by thebusiness community increases demand for facilitating payments.

KICK-BACKS: Neither Marmedsa USA LLC, nor anyone acting on behalf of Marmedsa USA LLC, mayoffer or accept a “kick-back” of any portion of a contract payment to employees of other parties to acontract or use other vehicles such as subcontracts, purchase orders or consulting agreements tochannel payments to government officials, political candidates, employees of other parties to acontract, their relatives or business associates.

A “kickback” is a particular form of bribe which takes place when a person entrusted by an employeror public function has some responsibility for the granting of a benefit and does so in a way thatsecures a return (kickback) of some of the value of that transaction or benefit for that personwithout the knowledge or authorization of the employer or public body to which the person isaccountable.

CONFLICTS OF INTEREST: Marmedsa USA LLC, and anyone acting on behalf of Marmedsa USALLC, shall avoid any relationship or activity that might impair, or appear to impair, the ability to renderobjective and appropriate business decisions in the performance of our jobs.

POLITICAL CONTRIBUTIONS: Neither Marmedsa USA LLC, nor anyone acting on behalf ofMarmedsa USA LLC, may make a political contribution in order to obtain an unlawful businessadvantage. Marmedsa USA LLC shall comply with all public disclosure requirements.

PHILANTHROPIC CONTRIBUTIONS: Marmedsa USA LLC, and anyone acting on behalf ofMarmedsa USA LLC, may make contributions only for bona fide charitable purposes and only wherepermitted by the laws of the country in which the contribution is made. Contributions made in orderto obtain an unlawful business advantage are prohibited.

Page 72 of 92

EXTORTION: Marmedsa USA LLC, and anyone acting on behalf of Marmedsa USA LLC, shall rejectany direct or indirect request by a public official, political party, party official, or private sectoremployee for undue pecuniary or other advantage, to act or refrain from acting in relation to his orher duties.

GIFTS, HOSPITALITY AND ENTERTAINMENT: Marmedsa USA LLC, and anyone acting on behalfof Marmedsa USA LLC, shall avoid the offer or receipt of gifts, meals, entertainment, hospitality orpayment of expenses whenever these could materially affect the outcome of business transactions,are not reasonable and bona fide expenditures, or are in violation of the laws of the country of therecipient.

REPORTING REQUIREMENT: All officers and employees of Marmedsa USA LLC and anyone actingon behalf of Marmedsa USA LLC shall promptly report any actual or potential violation of this Code ofConduct, including any instance in which he/she is subjected to any form of extortion or is asked toparticipate in any way in a bribery scheme, to Marmedsa USA LLC senior corporate management,without fear that his/her business relationship or employment will be adversely affected. Reports shallbe treated confidentially to the extent possible, consistent with the need to conduct a thoroughinvestigation.

COMPANY RESPONSE: No employee will suffer demotion, penalty or other adverse consequencesfor not paying bribes even when Marmedsa USA LLC may lose business as a result of the employee’srefusal to do so. Employees are required to report alleged violations of this Code of Conduct tosenior management and no employee will suffer demotion, penalty or adverse consequences forreporting.

Marmedsa USA LLC shall, where appropriate, sanction employees, suppliers or other businesspartners for violations of this Code of Conduct.

ACCOUNTS: Marmedsa USA LLC shall maintain complete and accurate financial records, ensuringthat all transactions are properly, accurately and fairly recorded in a single set of books.

COMMUNICATIONS AND TRAINING: Marmedsa USA LLC agrees to participate in anti-corruptiontraining provided by TRACE, or by a comparable organization, and to make annual training availablefor all principals and for all key employees involved in sales, marketing, and procurement.

The person whose signature appears below is duly authorized to adopt this Code of Conduct onbehalf of Marmedsa USA LLC and, if signing on behalf of a company, agrees that this Code shall applyto all officers, employees and representatives of Marmedsa USA LLC.

I hereby adopt and agree to comply with the TRACE Code of Conduct as outlined above.

I understand that violation of the Code of Conduct will be grounds for immediate revocation ofTRACE Certification, if applicable.

Electronic Signature: Khaysy Murasaki

Title: Director Compliance and Corporate Broker

Date: 1 May 2018

Page 73 of 92

Marmedsa USA LLC will distribute this anti-bribery policy to its employees.

Marmedsa USA LLC will require its subsidiaries, affiliates, joint-venture partners, suppliers,subcontractors and other third parties to comply with this anti-bribery policy.

Marmedsa USA LLC has a written compliance policy.

The compliance policy is distributed to employees.

Marmedsa USA LLC requires its subsidiaries, affiliates, joint-venture partners, suppliers,subcontractors and other third parties to comply with its compliance policy.

Marmedsa USA LLC has a system that allows its employees to ask questions or report concernsregarding compliance and anti-bribery matters.

Marmedsa USA LLC does not conduct periodic assessments of compliance and anti-bribery risks.

Additional Information: Marmedsa USA LLC will conduct periodic assessments of compliance andanti-bribery risks at the time of onboarding new employees as well as online compliance trainingonce a year. At the current environment Marmedsa USA LLC is obtaining all the required licensesand approval to operate.

Marmedsa USA LLC has a policy addressing human rights awareness, education and training.

Marmedsa USA LLC has a DUNS number: 08-115-8307

Additional Information: Marmedsa USA LLC adheres to the parent company Noatum MaritimeService S.L.U written compliance policy.Marmedsa USA LLC team is working on creating Vendor Registration packet for oursuppliers/vendors and the TRACE code of conduct will be included with the completed packet.The internal intranet is utilize as a system that allows employees to ask questions or report concernsregarding compliance and anti-bribery matters.

Page 74 of 92

* * * * T R A C E B o o k m a r k : R e p u t a t i o n a l _ S c r e e n i n g | R e p u t a t i o n a l S c r e e n i n g

ReputationalScreening

Page 75 of 92

Reputational Screening Results Summary for

Marmedsa USA LLC 24 May 2018 No results were found.

Page 76 of 92

* * * * T R A C E B o o k m a r k : A d d i t i o n a l _ D o c u m e n t s | A d d i t i o n a l D o c u m e n t s

AdditionalDocuments

Page 77 of 92

Limited Liability Company Agreement (Marmedsa)

Page 78 of 92

Page 79 of 92

Page 80 of 92

Page 81 of 92

Page 82 of 92

Page 83 of 92

Page 84 of 92

Page 85 of 92

Page 86 of 92

Page 87 of 92

Page 88 of 92

Page 89 of 92

Page 90 of 92

* * * * T R A C E B o o k m a r k : A n t i - B r i b e r y _ T r a i n i n g | A n t i B r i b e r y T r a i n i n g

Anti-BriberyTraining

Page 91 of 92

This is to certify that on21 May 2018

Boris Kos

has successfully completed the coursework and theexamination for the TRACE Anti-Bribery Course and has

thereby earned this certificate.

TRACE Anti-Bribery Course

www.TRACEinternational.org

Page 92 of 92

* * * * T R A C E B o o k m a r k : B a c k _ C o v e r

DubaiHoustonManila

New YorkParis

EMAIL:[email protected]

WEBSITE:www.TRACEinternational.org

TEL: +1 410.990.0076

FAX: +1 410.990.0707

TRACE INC. AND TRACE INTERNATIONALSuite 300151 West StreetAnnapolis, MD 21401 (HQ)

WORLDWIDE OFFICES: