Concordia Maritime Group Code of Conduct

Reviewed December, 2015

Background

This Code of Conduct applies to all companies in the Concordia Maritime Group: Concordia Maritime AB (publ), Concordia Maritime AG with subsidiaries and Concordia Maritime (Bermuda) Ltd with subsidiaries.

The Concordia Maritime Group creates jobs and provides value by offering competitive sustainable business solutions in tanker shipping. In order to be consistently successful, it is vital that all members of our organization performs their duties in such a way that the Concordia Maritime Group is acknow­led­ged and perceived as economically, socially, ethically and environmentally responsible. Both the Group and every individual must always act in a trans­parent manner that projects credibility and respect for customers, colleagues, business partners, organisations, banks, media, authorities and society. If we act illegally, unethically or immorally, our colleagues, the public and our counterparts cannot trust us and we risk business relationships, losses and other damage.

All members of the Board of Directors and all employees in the Concordia Maritime Group shall follow this Code of Conduct, as well as the applicable legislation, and no one in the organization has the mandate to authorize exceptions from the Code of Conduct. It is our responsibility to ensure that we comply with all applicable laws and local practices. Situations may occur where no specific guidelines exist. In such cases, conduct should be in the spirit of this Code of Conduct.

This Code of Conduct has been adopted by the board of Concordia Maritime AB to underscore the principles by which the Concordia Maritime Group conducts relations with business partners, employees and other stakeholders.

The Concordia Maritime Group commitments

Legal Compliance

  • In every country in which we operate, the Concordia Maritime Group shall comply with the laws and regula­tions in that country.
  • In cases of conflict between mandatory law and the principles in this Code of Conduct, the law shall prevail.
  • In situations where the law does not give guidance, the Concordia Maritime Group applies its own standards based on corporate values and culture as set in this Code of Conduct.

Relations with Business Partners

  • All activities within the Concordia Maritime Group aim at creating value by offering competitive services and products on the national and international markets observing good business practices.
  • We honour open markets and fair competition and we do not enter into discussions or agreements – formal or otherwise - with competitors on pricing, market sharing or any other activities violating rules on fair competition.
  • The Concordia Maritime reputation for honesty and integrity must not be put at risk by the offer of improper payments. We do not accept extortion and we shall not – neither directly nor indirectly – offer, promise, ask for, demand or accept bribery or other improper benefits. We strive to eliminate facilitation payments within our sphere of influence.
  • All employees may, directly or indirectly, accept, promise, seek or give illegal or improper payments and shall reject any personal gifts, entertainment and other kind of reimbursement, from actual or potential business partners, that could affect, or appear to affect, the objectivity in their business transactions.
  • We expect the same high requirements and standards from our suppliers, subcontractors, agents, joint ventures, customers and other business partners as on our own operations. When we evaluate and select business partners we also assess their ability to apply the requirements of our Code of Conduct.
  • Any business partner who does not meet and respect these standards runs a risk of being excluded from our value chain, including possible cancellation of existing contracts.

Stakeholder communication

  • We strive for mutual openness and pro-activeness when communicating with all business partners, employees and other stakeholders, providing transparent, essential, consistent and correct information within the limits of commercial confidentiality.
  • We record all financial transactions in accordance with locally Accepted Accounting Principles. In all Group reporting we follow International Financial Reporting Standards (IFRS) and applicable laws and regulations

Information security

  • Information is a valuable asset. Non-public information that employee’s possess through their work, from whatever source, must be kept confidential to prevent others from copying our work or obstruct relations with our customers. This also applies after the termination of employment.
  • Employees must not release any information that is commercially sensitive or contentious or that may have undesired contractual or legal implications for the Concordia Maritime Group. It is not allowed to discuss, directly or indirectly, confidential matters that could lead to competitive disadvantages in places or situations where such discussions could be overheard. Remember that communication via e-mail, internet and other social media could be regarded as a statement of the Concordia Maritime Group.
  • All employees must be aware of that it is forbidden by law to make investments based on price sensitive information they have but which has not yet been made public, “insider trading”, neither for personal gain nor on behalf of the Concordia Maritime Group. It is also forbidden to transmit any such insider information to a third party regardless of any gain.

Conflicts of interest

  • Employees and members of the Boards of Directors in the Concordia Maritime Group shall conduct their private financial interests, affairs and other external activities in a manner that does not conflict, or appear to conflict, with the interests of the Concordia Maritime Group.
  • Situations in which personal interests, outside activities, financial interests, or relationships conflict with, or appear to conflict with, the interests of the Concordia Maritime Group should be avoided. Conflict of interest may in general arise in the fields of outside employment, business relationships with family members, board memberships outside of the Concordia Maritime Group and significant ownership interests in new and/or competitive business transactions. 
  • Employees who think they may be in a “conflict” must seek written consent from their closest manager.

Human and Labour Rights

  • We shall support and respect the International Labour Organization´s Declaration on Fundamental Principles and Right at Work.
  • We support the International Labour Organization’s International Program on the Elimination of Child Labour (IPEC), with the aim of the abolition of child labour in our sphere of influence.
  • We do not accept any form of forced labour and we do not accept the use of prison labour or illegal labour in the production of goods or services for us or in the operations of our suppliers or any other parties with whom we cooperate. We support and respect the right for all employees to enjoy the freedom of association of their choice and their right to bargain collectively.
  • We believe in fair employment conditions and opportunities for everybody, without distinction or discrimination on the grounds of race, gender, age, national or ethnic origin, pregnancy, disease or disability, religion, sexual orientation, union membership or political affiliation. We encourage workplace diversity at all levels in the Concordia Maritime Group.

Relation to employees

  • We provide a safe and healthy work environment for all employees, contractors, visitors and suppliers and are committed to continual improvement. We do not tolerate employees to be intoxicated at the workplace or to work under the influence of drugs.
  • Our employees shall have access to a workplace free of harassment or abuse. We do not accept any form of violence, threats or destructive behaviour in the work place. We also do not accept any form of political, religious or other propaganda in the workplace.
  • Employees shall get necessary information and training in order always to have the knowledge and skills to perform their work safely and correctly. We strive to give the employees good opportunities to train for job enrichment and wider responsibilities.
  • The Concordia Maritime Group ensures that wages and other related benefits meet at least the legal and industry minimum standard in the country of operation. We also comply with applicable laws and industry standard on working hours in the countries where we operate. Employees should be granted stipulated annual leave, sick leave and parental leave without any negative repercussions.
  • The Concordia Maritime Group ensures that the registration, filing and use of employee data are treated with strict confidentiality and in accordance with local legislation. Employment records will not be released to any person outside the Concordia Maritime Group, unless required by law or with the written consent of the employee concerned.

Environment and Safety

  • In all our operations we continuously strive to reduce climate impact and to conform or surpass the requirements of national and international regulations or agreements concerning the reduction of emissions and discharges to air, land and water.
  • We promote the sustainable and ecologically sound use of resources respecting precautionary principles for the protection of the environment, preventing pollution, enhancing the effective use of energy, minimizing waste and emissions of greenhouse gases.
  • Safe, sustainable and environmentally sound performance is an essential part of our business concept and a cornerstone in the Concordia Maritime brand name. Every employee has the full support from management to break a chain of events that might result in an accident or environmental incident. Complacency is a threat to all our activities and is not accepted.