Code of Conduct

We all have a responsibility to familiarise ourselves with the ethical guidelines set out in this document. Since they cannot describe the correct course of action in every possible situation, we must use common sense and good judgement in line with the Code of Conduct’s provisions.

If we are uncertain about anything, we ask for advice. Should we become aware of a breach or a potential breach of the Group’s Code of Conduct or applicable laws or regulations, we must report the matter through the Seashore Group’s whistleblowing channel as soon as possible.

We all have a responsibility to contribute to good collegiality. This means taking responsibility for and contributing to the work of the department and its working environment, and not leaving everything up to the manager.

We must always lead by example, which means that the Group’s ethical guidelines and values are integrated into our personal behaviour and business management practices. We must create a climate of openness and trust in our departments which makes it safe to raise questions and concerns about ethical issues and compliance with our Code of Conduct.

We lead in accordance with the principle be accessible, speak out, look up, build teams and give credit where it is due in order to create a positive social climate in the department and foster good collegiality.

As managers, we must ensure that every employee in our department has completed annual training on our Code of Conduct.

Responsible business practice is the very foundation of our operations. It is a responsibility we take extremely seriously. The Seashore Group shall conduct itself with integrity and to a high ethical standard.

The Bremnes Seashore Group is responsible for ensuring all employees receive training in the Code of Conduct and comply with it, and that employees have an opportunity to engage in ethical reflection on their own work.

We must treat all whistleblowing reports in a thorough, confidential and impartial manner. Information regarding the case will be disclosed only to those investigating it.

The Bremnes Seashore Group aims to create a safe and diverse workplace for all employees, and make itself attractive to all stakeholders.

HSE is a process of continuous improvement, and we all have a personal responsibility to act as good examples in the workplace and participate in preventive endeavours.

In keeping with the duty of worker participation, we contribute to good workplace HSE by being vigilant with respect to hazardous conditions and reporting these before we or our colleagues are injured.

We work in a company where some departments have a heightened risk of accidents and injuries. Here, we are additionally conscious of hazards and risk factors, and make good choices so that we avoid short-cuts and dangerous situations.

“Safely home” is the Group’s philosophy for a safe workplace. We shall work so safely that we return home safely – every day. This means using the correct protective equipment, where this is mandated, and choosing work processes that reduce the potential for hazardous behaviour.

We also have a responsibility to contribute to social cohesion, so that we create a good working environment in our department. This makes working more enjoyable and increases job satisfaction.

The Bremnes Seashore Group is a “clean” workplace. It is unacceptable for employees to come to work under the influence of alcohol or narcotic substances. In social settings, representatives of the Group may consume alcohol in moderation, where this is customary and appropriate. Consumption of alcohol is never accepted as a valid reason to breach the Code of Conduct.

In partnership with the Akan Competence Centre, we work continuously to prevent substance abuse and dependency issues among our employees and help those for whom this is already a problem. Akan helps Norwegian businesses to prevent and handle issues related to addiction in the workplace and assists employees with addiction problems to get help. Through our work with Akan, we wish to establish good systems to prevent problematic use of alcohol, narcotics, prescription medication and gambling, and where necessary intervene at an early stage. We are also working to establish assistance programmes for employees who may need such help.

The Bremnes Seashore Group respects human rights and treats everyone as equal. Our operations must always abide by internationally recognised human rights standards, including labour rights. The Group shall not participate in human rights abuses, and we do not do business with anyone we know has perpetrated such abuses.

We ensure safe working conditions in all parts of our business. We accept no form of forced or compulsory labour and support the effective abolition of child labour. Everyone who works in the Bremnes Seashore Group shall receive fair and equitable compensation, and salaries and working hours shall always comply with national legislation and international industrial standards.

The Group respects freedom of expression, freedom of association and the right to free collective bargaining. This means that all employees in the Group are entitled to form or join a trade union.

The Bremnes Seashore Group does not accept any form of discrimination, since this violates our principle of equality. Discrimination includes the different treatment or exclusion of people based on gender, age, ethnicity, origin, nationality, religion, disability, trade union membership, political affiliation or sexual orientation.

Nor do we accept any form of harassment or behaviour that may be perceived as offensive or threatening – e.g. unwanted sexual advances.

The Bremnes Seashore Group awards sponsorship funds only in accordance with its Code of Conduct and sponsorship guidelines, and our sponsorships are based on legitimate business interests and our corporate social responsibility. Sponsorship funds shall not be used to influence individuals or organisations to behave in a specific way.

We must also pay particular attention when the recipient has close ties to public officials or existing or potential business associates.

The Group has an annual sponsorship budget. An internal committee decides the appropriation of these funds twice a year, on the basis of applications submitted via our website.

The Bremnes Seashore Group aims to be a positive force in the local communities in which we operate. We must therefore have a good dialogue and cooperation with the local community and stakeholders in the vicinity of our sites. Through the provision of jobs, purchasing and sponsorships, we will contribute to vibrant and diverse local communities along the coast.

We always ensure that the reports and other information we submit to the public authorities are truthful and correct.

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 Legal Counsel.

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 Legal Counsel 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 Legal Counsel. 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 Legal Counsel 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 Legal Counsel.

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.

The data protection rules safeguard the integrity and confidentiality of personal information. We protect the privacy of our employees and others with whom we come into contact. We process personal data only when necessary, and the data is processed in compliance with data protection legislation and our internal procedures.

Cyber attacks and other malicious activity are a constant threat, and cyber attacks can have serious consequences for the Group. For this reason, we comply with the requirements set out in our IT policy and are vigilant with respect to attempts by malicious actors to use social manipulation to steal information from our data systems by scamming those with legitimate access.

In the course of our work, we gain access to and produce information that is important for the Group. This information, e.g. prices, customer lists, production data, strategies and working methods, can also be of value to our competitors and others. We therefore have a duty of confidentiality with respect to such information, also after we have left the company’s employ.

In the course of our work, we may obtain information about listed companies that is not publicly available. Such information may be deemed insider information which is liable to influence the company’s share price. We have a duty of confidentiality with respect to any insider information we may obtain information about, and we must not use that information for personal gain. We never trade in the shares of companies about which we have insider information.

The Bremnes Seashore Group owns commercial and business secrets, know-how, patents, trademarks, designs and copyrights. Together, these are called intellectual property rights or intangible assets. Intellectual property rights are of immense value for us, and the Group is therefore keen to protect them.

Seanett via Workvivo is the Bremnes Seashore Group’s internal communications platform.

When we engage in public debate, in political activity or in other activities in keeping with our freedom of expression, we always make it clear that we are expressing ourselves as private individuals. We must not give the impression that we are expressing ourselves on behalf of the Bremnes Seashore Group.

Only those duly authorised may make statements on behalf of the Group. This applies to communication with the media and the public authorities. All those tasked with making a public statement must consult Director Communications and External Relations in advance. If we are approached by the media for comment on matters relating to the Bremnes Seashore Group, we refer them to the CEO or Director Communications and External Relations.

We also ensure that reports and other information supplied to the authorities are correct and true. Financial reports, financial statements and information to partners, suppliers and customers are always correct and provide a correct picture of the financial situation.