EURONAV NV

CODE OF BUSINESS CONDUCT AND ETHICS

Approved by the Supervisory Board on 1 October 2020

employees, members of its Supervisory Board and/or Manageme

The conduct of individuals in these guidelines relate to the relationship with colleagues, customers,
suppliers and government agencies with equal importance. As a starting point, Euronav should
present itself as a professional and responsible organisation. This Code sets out a set of basic
principles to guide Relevant Persons regarding the minimum requirements expected of them.
However, this Code does not provide a detailed description of all Company policies and it does not
cover every issue that may arise. In general, if a Relevant Person is unsure of what to do in any

Counsel.

1. CONFLICT OF INTEREST
A. GENERAL

Every Relevant Person should avoid any conflict between his/her own interests and the interests of
the Company, especially when dealing with suppliers, customers, and other third parties, and in the
conduct of his/her personal affairs, including transactions in securities of the Company.

the Company as a whole. While it is not possible to describe every situation in which a conflict of
interest may arise, Relevant Persons must never use or attempt to use their position with the Company
to obtain improper personal benefits for themselves or for members of their families.

Any Relevant Person who is aware of a conflict of interest, or the appearance of a conflict of interest,
or is concerned that a conflict might develop, should report and discuss the matter with the head of
department or the General Counsel. Any of these shall report to and consult the Chairman of the
Corporate Governance and Nomination Committee immediately in the event of any conflict of interest
apparently arising within the Company.

The Corporate Governance and Nomination Committee shall have the responsibility to determine
whether a conflict of interest exists, and it may establish procedures to arrive at its conclusion and to
approve or reject, or otherwise resolve, a potential conflict of interest.

B. IN RELATION TO A MEMBER OF THE SUPERVISORY BOARD OR MEMBER OF THE

MANAGEMENT BOARD

Board and/or members of the Management Board, shall be resolved according to the applicable
provisions of the Belgian Companies Code, with the assistance of the Corporate Governance and
Nomination Committee where required.

TEPIC SASA
19. 08. 2022.

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 C. BUSINESS RELATIONSHIPS WITH THIRD PARTIES

Business relationships with third parties shall be governed solely by objective criteria. Suppliers shall
be selected only on the basis of price, quality, reliability, technological standard, product suitability,
the potential for (or existence of) a continuing business relationship, ISO or ecological audit
certification, the existence of an anti-corruption policy and the existence of a quality management
system. Furthermore, as described in the Third Party Risk Policy, a compliance validation should be
conducted. In no circumstances shall personal relationships be determining factors in awarding a
contract. Advice or recommendations given by any Relevant Person must not be motivated by the
prospect of a material or non-material advantage to that or another Relevant Person.

The procurement policy of the Company emphasizes the importance of establishing vendor
relationships based on Price Catalogues, Pricing Agreements or Contracts. In general Procurement of
goods and/or services is to be undertaken on the basis of competitive bidding with minimum three
candidates, unless there is a risk related to quality.

2. CORPORATE OPPORTUNITIES
A Relevant Person may not:

i. take for himself or herself opportunities that are discovered through the use of Company
property, information or position;
ii. use Company property, information or position for personal gain; or
iii. compete with the Company.

Relevant Persons owe a duty to the Company to advance its interests.

A corporate opportunity may be described as any business opportunity for the Company which arises
through or outside the activities of a person and which could benefit the Company. In case of dispute,
the Corporate Governance and Nomination Committee has the responsibility to determine whether a
corporate opportunity exists. The Corporate Governance and Nomination Committee may also
establish procedures to arrive at its conclusion and to approve or reject, or otherwise resolve, a
potential usurpation of a corporate opportunity.

3. CONFIDENTIALITY AND PRIVACY

It is important that Relevant Persons protect the confidentiality of Company information.

Relevant Persons may have access to proprietary and confidential information concerning the

obtained in the course of employment, including but not limited to non-public information concerning

Company and any legal proceedings commenced by or against the Company as well as any non-public

Company or its customers.

Relevant Persons are required to keep such information confidential during employment as well as for
at least 5 years thereafter, and not to use, disclose, or communicate such confidential information to
third parties other than in the course of employment with and with proper authority of the Company,
except when disclosure is authorized by the Company or legally mandated.

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The consequences to the Company and the Relevant Person concerned can be severe where there is
unauthorized disclosure of any non-public, privileged or proprietary information. Among other things,
disclosure of material non-public information relating to the Company could violate applicable insider
trading laws and could result in significant civil and criminal penalties for the individual, in addition to
penalties that may be imposed upon the Company and its supervisory personnel, as set out in the
Dealing Code.

suspected leak of confidential information. Based on the information received, the Chief Executive
Officer shall inform the Supervisory Board and shall, together with the Chairman of the Audit and Risk
Committee, the General Counsel determine which
measures to take.

4. HONEST AND FAIR DEALING

Relevant Persons must endeavour to deal honestly, ethically and fairly and with integrity with the

Honest conduct is considered to be conduct that is free from fraud or deception.

Ethical conduct is considered to be conduct conforming to accepted professional standards of conduct.

Fair conduct is considered to be conduct that is free from unilateral advantage through manipulation,
concealment or misrepresentation of material facts, abuse of privileged information or any other
biased-dealing practice.

Integrity refers to the quality of being honest and having strong moral principles.

Relevant Persons are expected to report suspected violations of law or of Company policies in the first
place to the head of department, who will report to the General Counsel, or the Chief Executive Officer
and/or to the Chairman of the Audit and Risk Committee, as appropriate. The Company expects
compliance with its standards of integrity throughout the organisation and will not tolerate any
Relevant Person who achieves results at the cost of violation of laws or who deals unscrupulously.

5. HEALTH, SAFETY AND SOCIAL BEHAVIOUR

A. HEALTH AND SAFETY

The Company strives to provide each Relevant Person with a safe and healthy work environment. Each
Relevant Person has responsibility for maintaining a safe and healthy workplace for all Relevant
Persons by following safety and health rules and practices and reporting accidents, injuries and unsafe
equipment, practices or conditions while sharing vigilance.

B. SOCIAL BEHAVIOUR

Threats or acts of violence and physical intimidation are not permitted. The use of alcohol or illegal
drugs in the workplace will not be tolerated as stipulated in the Employment Standards.

Each Relevant Person must realize that his/her behaviour will be attributed to the Company and can
affect its reputation. The Company therefore expects all Relevant Persons to be polite, objective and
fair.

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Hence, Relevant Persons:

may not unfairly disadvantage, favour, harass or ostracize others because of race,
gender, colour, nationality, descent, religion, biological sex, sexual orientation, age,
physical characteristics or appearance;
have the right to be protected against harassment; and the obligation to allow others
to feel freedom from harassment, regardless of whether one might consider his or her
own behaviour to be normal or acceptable and whether the harassed person has the
opportunity to avoid the harassment;
are entitled to work together with colleagues in an atmosphere of safety, comfort and
trust.

C. COMMUNICATION

Relevant Persons must endeavour to contribute as much as possible of his or her own expertise and of
the expertise drawn on from elsewhere within the Company. Free and open communication between
Relevant Persons is key for decision-making within the Company.

In respect of the abovementioned points, employees are also referred to the Employment standards
and the Staff Handbook.

6. PROTECTION AND PROPER USE OF COMPANY ASSETS

Relevant Persons or their authorized designees. This applies to tangible assets (such as equipment,
office equipment, telephone, copy machines, etc.) and intangible assets (such as trade secrets,
confidential information, inappropriate use of the company internet subscription, company phone, e-
mail and server space). These assets must not be removed from Company premises without the
express permission of the head of department other than for work-related purposes. Data, programs
or documents must be neither copied nor brought onto or removed from Company premises without
permission other than for work-related purposes. Equally, no personal data, programs or documents
not linked with any legitimate business purpose must be copied to or stored on company assets or
within company premises. However, certain exceptions are tolerated in accordance with the IT
acceptable use policy.

ensure their efficient and safe use. Theft, carelessness and waste have a direct impact on the

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7. SECURITY OF FILES AND RECORDS AND ARCHIVING

The documents and data storage media used in the workplace must not come into the possession of
unauthorized persons. Relevant Persons must therefore keep them secure, must secure computer data
through the use and frequent changing of passwords and shall not make copies of business papers or
computer files other than for work-related purposes.

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Relevant Persons do not have the right to access to information not relating to their own field of work
or responsibility and shall not read messages addressed to others, except for work-related reasons.

Relevant Persons must keep all records and files (including electronic records) in such a way as to
permit delegation to a colleague at any time. All significant information should be properly recorded
and archived. Hence, files must be kept in a manner that is complete, orderly and readily
understandable.

8. COMPLIANCE WITH LAWS, RULES AND REGULATIONS

All Relevant Persons are responsible for complying with various laws, rules and regulations of the

is unsure whether a situation violates any applicable law, rule, regulation or Company policy should

9. COOPERATION WITH AUTHORITIES WHILE DEFENDING OUR RIGHTS

The Company will endeavour to be cooperative and open in its dealings with all authorities and

the event of a request for information or questioning outside the ordinary course of business.

10. SECURITIES TRADING; PROHIBITION ON LOANS

The Company is subject to a number of laws concerning the purchase of its shares and other publicly
traded securities. Company policy prohibits Relevant Persons and their family members from trading
securities while in possession of material, non-public information relating to the Company or any other
company, including a customer or supplier.
U.S. securities laws also prohibit the Company from, directly or indirectly (including through
subsidiaries), (i) extending or arranging for the extension of personal loans to the members of its
Supervisory Board and/or members of the Management Board, and (ii) renewing or materially
modifying existing loans to such persons. Members of the Supervisory Board and/or members of the
Management Board shall not seek or facilitate personal loans from the Company in contravention of
the foregoing.

11. MEMBERS OF THE SUPERVISORY BOARD AND MEMBERS OF THE MANAGEMENT

BOARD
The business of the Company is managed under the direction of the Supervisory Board and the various
committees thereof as well as the Management Board. The basic responsibility of the members of
those bodies is to act honestly and in good faith with a view to the best interests of the Company.
In carrying out their duties and responsibilities and setting the general policies pursuant to which the
Company operates, members of the Supervisory Board and members of the Management Board
should endeavour to promote fair dealing by the Company and its employees, officers and agents with
customers, suppliers, competitors and employees.
In carrying out their duties and responsibilities, members of the Supervisory Board and members of
the Management Board should endeavour to comply, and to cause the Company to comply, with
applicable governmental laws, rules and regulations.

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Members of the Supervisory Board and members of the Management Board should endeavour to
cause the Company to proactively promote ethical behaviour and to encourage employees to report
evidence of illegal or unethical behaviour to appropriate Company personnel.

12. OUTSIDE DIRECTORSHIPS AND OTHER OUTSIDE ACTIVITIES

Although activities outside the Company are not necessarily a conflict of interest, a conflict could arise
depending upon a Relevan
the entity involved in such outside activity. Outside activities may also be a conflict of interest if they
cause a Relevant Person, or are perceived to cause a Relevant Person, to choose between that interest
and the interests of the Company. Reference is made in this respect to the Corporate Governance

13. RELATIONSHIPS WITH GOVERNMENT PERSONNEL AND BUSINESS PARTNERS

All Relevant Persons should be aware that practices that may be acceptable in the commercial business
environment (such as providing certain transportation, meals, entertainment and other things of
nominal value) may be entirely unacceptable and even illegal when they relate to government

the relevant laws and regulations governing relations with government employees or others who may

governmental context, in every country where they conduct business. Further reference is made to
the Anti-Corruption Policy.

14. POLITICAL CONTRIBUTIONS

Laws in many jurisdictions may prohibit or limit political contributions by corporations to candidates
or to other political campaigns. In accordance with these laws, the Company does not make
contributions where applicable laws make such contributions illegal. Relevant Persons may make
personal political contributions in accordance with applicable laws, but contributions to candidates or
to other political campaigns by Relevant Persons must not be, or appear to be, made with, or
reimbursed by, Company funds or resources. Company funds and resources include (but are not
limited to) Company facilities, office supplies, letterhead, telephones, servers and multi-purpose
machines. Reference is made to the Anti-Corruption policy.

Relevant Persons who hold or seek to hold political office must do so on their own time, whether
through vacation, unpaid leave, after work hours or on weekends. Additionally, all Relevant Persons
General Counsel prior to running for political office
to ensure that there are no conflicts of interest with Company business.

15. PROCEDURES REGARDING WAIVERS

Because of the importance of the matters involved in this Code, waivers will be granted only in limited
circumstances and where such circumstances would support a waiver. Waivers of the Code may only
be made by the Audit and Risk Committee and may need to be publicly disclosed by the Company.

16. DUTY TO REPORT

Relevant Persons shall take all appropriate actions to stop any known misconduct by fellow Relevant
Persons that violate this Code.

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In case of uncertainty of whether a violation has occurred within the Company, one must seek guidance
eged violations of law or suggestions
for improvements should be made to the relevant departments or the General Counsel.

Alternatively, the reporting can be done anonymously through the whistleblowing hotline, as
described in the Whistleblower Protection Policy of the Company.
Note that the Company will not allow there to be adverse consequences for reports made in good
faith.

17. ENFORCEMENT AND DISCIPLINE

Violations of law will not be tolerated. The Company will offer all the necessary sources of information

Persons will also be afforded guidance in the event of unjustified actions by authorities.
Violations may result in reprimand, claims for damages, termination of employment, or loss of office.
It is not sufficient simply to take note of this Code of Conduct. Relevant Persons are requested to
review their own behaviour in light of the above standards and to determine where improvements are
possible. They must organize their area of responsibility in such a way that violations can be detected
or reports of violations received and take the initiative to regularly monitor subordinates' activities and
actively communicate with them.

18. CONCLUSION
These principles must always form an active part of

willingness to allow those actions to be judged against legal standards. Questions or comments on this
policy must be addressed to the General Counsel.

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