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Item 16B. Code of Ethics

We have adopted a code of conduct that applies to our directors, officers, employees and certain persons performing similar functions. A copy of our code of conduct has been filed as an exhibit to this annual report and is also available on our website at https://heidmar.com. The information included on or accessible through our website is not incorporated by reference into this annual report. The Company will provide to any person without charge, upon request, a copy of such code of ethics by request to: c/o Heidmar Maritime Holdings Corp., attention Corporate Secretary, 89 Akti Miaouli, Piraeus 18538, Greece.

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