Icon Energy Limited Annual Report 2023

Icon Energy Annual Report 2023 15 OTHER KEY POLICIES In addition to the Company’s Code of Conduct and Ethics, Icon has a Whistleblower Policy which contains written guidelines and procedures by which all employees can confidentially report improper conduct for investigation without fear of discrimination and harassment. Icon encourages its staff to speak up on matters or conduct that concerns them. Icon also has an Anti-Bribery and Corruption Policy as it is committed to acting in full compliance with the letter of the law, including regulations with regards to anti-corruption and bribery issues and act ethically, honestly, responsibly, and diligently. This Policy sets out the requirements for the management of gifts and benefits. The Board or/and Audit and Risk Management Committee is/are informed if any material incident reported under the Whistleblower Policy and/or Anti-Bribery and Corruption Policy. Code of Conduct and Ethics, Whistleblower Policy and Anti-Bribery and Corruption Policy can be found in the Corporate Governance Section on the Company’s website. TRADING IN THE COMPANY’S SECURITIES BY DIRECTORS AND EMPLOYEES The Board has a formal policy regarding trading in the securities of the Company by Directors and employees. The Company’s Share Trading Policy provides for specified periods in which share trading is permitted (known as “Trading Windows”) and blackout periods when trading is not permitted. Normally all Icon Energy personnel not in possession of unpublished price-sensitive information may only buy, sell or otherwise deal in Icon Energy’s securities during Trading Windows. Normally a Trading Window is opened for a three week period commencing after: − The announcement of the half yearly financial results; − The announcement of the annual financial results; − The announcement of the Quarterly Reports for the March and September quarters; − The holding of Icon Energy’s Annual General Meeting; − The Company issues a prospectus or a cleansing statement; or − As the Board otherwise determines. Under the Policy, Directors and Employees who wish to trade in the Company’s securities must seek prior clearance in writing from the Chairman (in the case of Directors) and the Managing Director (for the Chairman, Secretary or employees). The provisions of the Corporations Act 2001 and the Listing Rules of the ASX require advice to the ASX of any transactions by the Directors in the securities of the Company. IDENTIFICATION OF SIGNIFICANT BUSINESS RISK The Board receives comprehensive monthly management reports which enables Directors to identify emerging risk factors and monitor management’s response to these risks.