The Board of Directors of Eurobulk Ltd (the "Company") has adopted this Anti-bullying and anti-harassment policy for all of the Company's employees, directors, officers, crew and agents ("Employees").

The Company strictly prohibits all forms of harassment, including any verbal, physical or written harassment, because of sex, race, colour, creed, religion, age, sexual orientation, national origin, disability, marital status, alienage or citizenship status, genetic predisposition or carrier status, or any other classification protected by law. All department heads are held responsible for ensuring that no staff member either ashore or on board regardless of job position, seniority, ranking and professional affiliation is subject to conduct which constitutes harassment in any form.

The Company has a zero tolerance policy with respect to any form of harassment and any violation of this policy will lead to disciplinary action, including dismissal. Eurobulk Ltd treats complaints of harassment and bullying seriously and in strict confidence. Senior officers onboard and personnel manager ashore are responsible to deal with complaints of harassment and bullying. Incidents of this kind should be immediately addressed to each supervisor or the company’s complaint officer directly. Eurobulk Ltd considers any kind of complaint to be a serious issue even if it is cyber bullying or harassment.

Complaints should be raised and nobody should be intimidated to report an incident. In case any person is not feeling comfortable raising a complaint, should address the issue to a friend or colleague in order to do it instead. Eurobulk Ltd is not penalizing anyone for making a complaint as long as it is not vexatious or made maliciously.

It is the victim’s perception of any actions that counts. If somebody feels that has suffered harassment or bullying, the company will look into the issue raised.