Wilhelmsen Code of Conduct

Purpose and applicability

The purpose of this Code of Conduct is to describe Wilhelmsen Chemicals AS’ group of companies (“WiC”) standards of business ethics. It sets out how WiC will behave towards our suppliers and how WiC expects our suppliers to act. It applies to all suppliers to WiC of goods and services, sub-contractors and sub-agents.

Breaching this Code may result in termination of business activities and in serious cases possible civil action.

  1. Compliance with the law

Suppliers must comply with all laws and regulations applicable to the products or services being supplied to WiC, both in the countries in which they work and all international legislation. Products and packaging must comply with all applicable laws, statutory and regulatory requirements related to the manner in which the products will be transported and distributed.


  1. Fair business conduct

Business is to be conducted in a fair and ethical manner, promoting healthy competition and protecting the interests of our customers and other stakeholders.


  1. Financial offerings and/or gifts

WiC does not offer or accept monetary benefits or gifts to achieve business advantages to which we would not otherwise be entitled. All business activity must be made in compliance with applicable international and national anti-bribery and anti-corruption legislation.


  1. Facilitating payments

In some countries facilitating payments are a normal means of securing routine, low-level action and/or approvals. Such payments are not limited to monetary consideration, but may take other forms such as gifts or general entertainment. They are in some countries legal and in others illegal.  Every effort should therefore be made to eliminate this practice, but it is recognized that such payments are expressly permissible to protect the life, health and liberty of Company personnel and their family members. If not expressly permitted, you must consult with the WiC Corporate Compliance Officer before making any such payments.


  1. Working environment

WiC behaves with respect for the people with whom we work and expects its suppliers to do the same.

Harassment, discrimination or other behaviour that may be perceived as threatening or degrading is not acceptable.

Discrimination against others on the grounds of race, gender, sexual preference or any other grounds is not acceptable.


  1. Confidential information and insider dealing

Confidential or business sensitive information must not be shared with other companies. Suppliers are expected to sign a Non Disclosure Agreement and all contracts will include a confidentiality clause. No information that may affect the


listed price of either parties’ shares on a stock exchange may be used to deal, or influence others to deal, in the shares of either company or other company listed securities.


  1. OFAC compliance

All suppliers must comply with the regulations of the Office of Foreign Assets Control (OFAC) of the United States Dept of Treasury as well as similar regulations of the United Nations and European Union.

WiC will screen potential suppliers for compliance and will not do business with any party on the list of Specially Designated Nationals or Blocked Persons.


  1. Compliance with Child Labour and Human Rights Laws

All suppliers shall comply with the following:

(a). All conventions or guidelines in relation to the prevention of child labour adopted by the International Labour Organisation (or a similar or replacement body) including, without limitation, the Minimum Age Convention; and

(b). The European Convention on Human Rights (or similar conventions for the protection of human rights adopted anywhere in the world).


  1. Environment

All business activities shall be carried out in a manner that considers the environmental implications, while complying with relevant laws and regulations. Suppliers must carry out business in such a way that maximum efforts are made to:

– protect the internal and external environment

– prevent all accidents and injuries

– treat waste safely and systematically

– Understand and manage risk

– Minimize impact on the environment and climate

– Work together with partners to improve sustainability management practices in the industry


  1. Supplier’s representatives

Each supplier shall ensure that its employees, agents, sub-contractors and other representatives shall comply with the provisions of this Code in relation to the supply of products and services to WiC, and provided also that any breach of this Code by any such representative of the supplier shall be deemed to be a breach by the supplier.

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