Statement on Sanctions in Press Coverage

In response to recent press enquiries regarding vessels and sanctions, the Board of Maritime
Mutual Insurance Association NZ Ltd (MMIA) believe that there is a need to address inaccuracies
and misunderstandings on these matters. MMIA, a marine liability mutual insurer, plays a key role
in defending both nation state marine safety and supports global maritime trade, whilst operating in
full compliance with its legal obligations.

The Association has maintained a focus on operational excellence to uphold the highest standards
of insurance management and has extensive experience in identifying and managing legal and
regulatory risks related to sanctions, including the risk of vessels violating sanctions. It has a
history of working closely with data intelligence providers to monitor and terminate cover for
any sanctioned vessels or entities from the U.S. Treasury Department’s Office of Foreign Assets
Control and HM Treasury in the United Kingdom amongst others. The Association is committed to
protecting the industry from those who attempt to violate its regulations and laws.

Addressing misconceptions about insurance and sanctioned trade, MMIA, as a third-party liability
P&I insurer, does not insure vessels or cargo but rather the legal liability of ships to third parties
in the event of maritime accidents caused by negligence. It does not serve as a real-time monitor
for the movements and activities of entered vessels but uses tools and processes to ensure
proper vetting and ongoing compliance checks. No payment is made to any party to a claim where
such payment would breach international sanctions and would cause MMIA to breach its legal
obligations.

The Association has a robust compliance program, integrated with leading third-party providers
worldwide, to monitor vessel movements, cargoes, logs, and ownership or management changes.
Insurance applicants are fully vetted through industry-standard databases and sanctions lists, and
the ownership and activities of prospective vessels are investigated. Cover is issued for specific
periods, with absolute and immediate exclusions for illegal or sanctioned trade.
Throughout the insured period, vessels must adhere to cover warranties, undergo periodic
monitoring, and provide attestations should the Club have reason to investigate potentially
sanctioned trade. If evidence arises that a vessel is involved in activities inconsistent with the
Association’s rules, an investigation is initiated. Coverage ceases if a vessel violates sanctions,
including, but not limited to, transporting Iranian or Russian-origin oil and petroleum products (the
latter in violation of the oil price cap regime).

The Association, through its managers, has a dedicated global compliance team led by an English
law solicitor. This team actively monitors both new and renewing business, regularly reviewing
changes in sanctions status and proactively assessing behaviours that may signal suspicious
activity. Supported by an in-house global technology team, working with market-leading vendors,
the Association ensures that all systems are robust and operate with the latest information
providers, enabling swift responses to sanctions issues.

MMIA takes its responsibilities regarding economic sanctions seriously and is committed to
maintaining the highest standards of integrity and regulatory compliance. The Association’s
compliance program ensures adherence with all applicable sanctions regulations across its global
operations, supporting governments, regulators, and law enforcement in preventing economic
crime.

The Board of Directors of Maritime Mutual Insurance Association (NZ) Ltd
25th October 2024