Compliance

The Bremnes Seashore Group supports the precautionary principle with respect to environmental challenges, and systematically assesses how our operations impact the environment. We identify and handle potential environmental risk and inform relevant stakeholders about the risks.

The Group is steadily increasing the extent to which it takes responsibility for the environment through the development and use of more environment-friendly technologies and procedures. We aim to reduce our environmental impact through sustainable use of natural resources, less food waste and reduced pollution. We place significant emphasis on fish welfare and biodiversity in all parts of our operations.

The Bremnes Seashore Group has zero tolerance for corruption. This means that no employee of the Bremnes Seashore Group shall be involved in corruption, either directly or via an intermediary. 

Corruption is when someone gives, receives, accepts, is offered or demands an improper benefit in connection with a position, job or elected office. 

What constitutes corruption must be defined in each individual case, on the basis of the purpose of the offer or request, the benefit’s value, the recipient’s position and how openly the offer or request is made. As a general rule, an offer or benefit constitutes corruption if it can influence or be perceived to influence the recipient’s ability to make sensible and objective decisions. A good control question is whether the act or situation would withstand public scrutiny. If you are uncertain or feel yourself to be in a grey area with respect to corruption, contact the Group Compliance Manager.

Bribery is when a person or company pays a public official money in return for the award of a public contract or licence. This is a common form of corruption We shall never propose, offer, give or receive bribes or other benefits in the course of our contacts with public authorities or existing or potential business associates.

The Bremnes Seashore Group has zero tolerance for corruption. This also includes indirect corruption and trading in influence.

Indirect corruption is when an intermediary offers bribes on behalf of a third party. An example of indirect corruption is when an agent, exporter or consultant pays a bribe on behalf of a client.

Trading in influence is another form of corruption. It occurs when someone engages an intermediary to exercise influence on behalf of a third party. This may occur, for example, when a firm pays an employee of another firm to influence one of that employee’s co-workers without the co-worker being aware of the situation.

To avoid the risk of indirect corruption, the Bremnes Seashore Group will carefully assess and follow up our business associates and partners. We shall also avoid all forms of trading in influence. We will use professional lobbyists, etc, only with the approval of the Group Compliance Manager and always with full openness about the fact that those individuals are working on behalf of the Bremnes Seashore Group.

To ensure that we comply with anti-corruption legislation, we have strict rules on what the Bremnes Seashore Group can give and receive in the way of gifts or hospitality in our dealings with business associates.

Depending on the circumstances, gifts, hospitality and paid expenses may be benefits that could be counted as corruption. The term “hospitality” includes, for example, entertainment, restaurant meals, travel and accommodation. Moderate catering in connection with meetings is not included in the term “hospitality”. 

Bremnes Seashore Group employees shall be cautious with respect to the giving and receiving of gifts. Gifts from the Bremnes Seashore Group must be approved in advance by the Group Compliance Manager. Any gifts that we receive must be of moderate value – worth no more than NOK 500. This cap applies to the value of all gifts from the same giver in the course of a year. The giving or acceptance of cash is always forbidden. The timing of the gift must be appropriate

Bremnes Seashore Group employees may provide hospitality to or accept hospitality from business associates only when there are clear and legitimate business grounds to do so, and where the hospitality is moderate in terms of its frequency and cost. The place and time must also be appropriate. 

As a general rule, the Bremnes Seashore Group pays for travel, accommodation and associated expenses for all those who work for the Group, in line with our internal procedures and travel expense regulations. Our business associates similarly pay the expenses of their own employees.

Interaction with public officials requires particular prudence. Bremnes Seashore Group employees shall therefore never give any type of gift or hospitality to public officials without the approval of the Group Compliance Manager in each individual case.

We define a “public official” as a person who is appointed or elected to a legislative, administrative or judicial office, a person who works in the civil service or a public body or company (such as state-owned companies), or who represents an international public organisation. We set corresponding standards for inspectors and auditors representing classification societies, certification schemes and customers.

A conflict of interest may arise when someone has a personal interest that could affect their professional behaviour. Bremnes Seashore Group employees have a responsibility to notify their manager immediately in the event of a potential conflict of interest.

The Bremnes Seashore Group must then assess whether the potential conflict of interest could influence the employee’s loyalty to the Group. Because it can be difficult to assess one’s own situation, employees must therefore leave it to their manager to assess the conflict of interest. We have this rule to protect both the employee and the Group. If we become aware of conflicts of interest, we can also use the Group’s whistleblowing channel. 

The term money laundering covers a variety of different actions intended to conceal the origins of illegally obtained income, typically by means of transactions involving financial institutions or legitimate businesses. The proceeds of money laundering may be anything of value, such as money, products, assets or real property, and may arise in many forms and transactions.

Money laundering is illegal and unethical. Bremnes Seashore Group employees must not participate in any form of direct or indirect money laundering. We must, however, be vigilant with respect to unusual payments, invoices or bank details that could indicate attempted money laundering.

We work on the principle of free and fair competition. Decisions about who we do business with and the prices we set for our products and services are taken by the Bremnes Seashore Group alone. We must not attempt to influence our competitors or participate in alliances that restrict competition and could violate competition law. Nor do we participate in discussions for the purpose of dividing up markets or geographic areas between ourselves and our competitors. 

We limit our communications with competitors and potential competitors, and do not share commercially sensitive information. No employee of the Bremnes Seashore Group shall participate in any discussion or interaction with a competitor that could constitute a violation of competition law. Prohibited discussions include, for example, discussions on prices, strategies and business tactics.

If we are contacted for the purpose of discussing topics that could violate competition law, we must not respond, but immediately report the matter to the Group Compliance Manager. 

States normally have legislation that regulates the export of goods, services, people and technology. Export restrictions may be imposed due to Norwegian or international sanctions on another country or on individuals. 

The Bremnes Seashore Group must always comply with all prevailing sanctions and export control laws. In consequence, we always examine export restriction lists before we sign agreements with new customers. A procedure has been established for export controls and sanctions, which will ensure that we act in compliance with legislation in this area.

Fraud means obtaining for one’s self or others an illegitimate benefit by either tricking someone into doing something or failing to do something that causes them to incur a loss or risk of loss, or wrongfully influencing the outcome of an automated data processing event. Fraud can, for example, include manipulation of computer systems or financial accounts (or other information).

The Bremnes Seashore Group has zero tolerance for fraud against the Group, its employees or third-party stakeholders.

To ensure our operations comply with the principles set out in our Code of Conduct, we also require our business associates to operate ethically and comply with laws and regulations. We therefore perform an integrity due diligence assessment on business associates, which provides more detailed guidance.