STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) Electronic Bills of Lading February 2025 Dear Member Notification to members The Group is pleased to announce that from 20 February 2025, paperless trading systems will be ‘deemed approved’, if they comply with certain requirements. The requirements for ‘deemed approval’ are: i) the system permits ‘compliant’ electronic bills of lading (‘E-bills’) only, meaning E-bills which are subject to a governing law which gives legal recognition to them as equivalent to paper bills of lading; and ii) the system is reliable and is evidenced as such, as set out at paragraph 7 ii) below. To assist members, going forward, any system provider that approaches the Group for approval of their system, and which meets requirements, will be listed on the Group’s website. This applies both to systems that successfully complete the existing Group approval process as referenced in paragraph 8) below, as well as those that are to be ‘deemed approved’. Further guidance in relation to the approval process for all providers, going forward, is set out below. Background Club Rules provide that liabilities arising in respect of the carriage of cargo under paperless trading systems are covered, provided that the system has first been approved by the Group. The Group’s involvement in approvals has been to ensure that systems do not prejudice members’ P&I cover, given the previous lack of widespread recognition in law of E-bills. Since 20 February 2010, the Group has approved thirteen electronic systems. The emergence of new technologies such as distributed ledger technology, and new legislation have acted as a catalyst for the development of E-bill systems. For example, in September 2023, the Group welcomed the UK ‘s Electronic Trade Documents Act (“the Act”), giving legal recognition in English law to electronic trade documents, including E-bills. The Act meets the requirements of the Model Law on Electronic Transferable Records (MLETR), a uniform model law adopted by the UN Commission on International Trade law (UNCITRAL) in 2018. Other countries have adopted, or plan to adopt, similar legislation. The International Chamber of Commerce (‘ICC Digital Standards Initiative’) provides information on legislative updates on a country-by-country basis here. Notification of new process STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) 2 Given the above, the Group reviewed its position in