Odfjell has a clearly stated zero-tolerance policy on corruption.

We have an anti-corruption and integrity framework based on the UK Bribery Act Guidance and Norwegian anti-corruption regulation. We conduct an annual risk assessment from which we devise an action plan on anti-corruption work for the company.

We do annual mandatory training and signing of Code of Conduct and anti-corruption policies and procedure for Board Members, all of our employees, consultants and we include relevant integrity clauses in all our contracts.

Odfjell is a member of the Maritime Anti-Corruption Network (MACN), and we have implemented and supported the MACN 'Say No' campaign on all our ships. We also track requests for facilitation globally with mandatory reporting from all port visits. We have established a reporting hotline, available internally and externally, for the reporting of any compliance-related matters.

Odfjell has an Integrity Council that coordinates all actions under the framework from all areas of our business.

All employees sign the Code of Conduct and the Anti-corruption policy , among other corporate policies, in an annual compliance sign-off campaign based in our compliance management system. The Board of Directors has annual training in Anti-Corruption. The Corporate Compliance Officer delivers a status and progress report on an integrity work plan to the Board's Audit Committee. The Board of Directors is involved in the work of Odfjell's integrity risk assessment and integrity work plan.

Odfjell SE, the parent company in the Odfjell Group of companies, is established and registered in Norway and is governed by Norwegian law, including laws and regulations pertaining to companies and securities. For more information please sse our Corporate Governance report.

Number of port calls or net revenue in countries that rank in the bottom of Transparency International's Corruption Perception Index (CPI).

We conduct an annual integrity risk assessment with all units resulting in a corruption risk map from which we devise an action plan on integrity incl. anti-corruption work for the company.

Odfjell has a mandatory reporting system for all port calls, where all request for facilitation are reported.

Odfjell follows MACN's 'Say No' campaign for all ports.

The total monetary value of significant fines and the total number of non-monetary sanctions for non-compliance with laws and/or regulations.

Odfjell has established a new training module and policy on AML and counter-terrorist financing. All relevant employees will have to go through mandatory training and testing of AML risks and policy.

Sanctions are measures imposed by governments and international bodies (such as the United Nations, the United States and the European Union) to restrict dealings with certain countries, entities and individuals.

Odfjell maintain effective measures to ensure compliance with and awareness of our sanctions-related obligations in the due diligence process. The responsibility for sanctions screening lays in the concerned units: Commercial, Finance, Legal & Insurance. Odfjell has established a Sanctions screening process and procedure.

Corporate Strategy and Values, Code of Conduct, Health, Safety and Environmental Policy, Corporate Governance Policy, Anti-corruption Policy, Human Rights Policy, Corporate Supplier Conduct Principles, Sanctions Policy, Antitrust/Competition Policy, Whistleblowing Policy, Security & Contingency Policy, Anti-Money Laundering & Counter-Terrorist Financing Policy, Data Privacy & Protection Policy are main policies among others.

All policies are approved by the Board of Directors. We also conduct or have access to supplier audits incl. ESG and audits of yards.

Odfjell is committed to environmental protections and creates environmental awareness within our organization.

The climate targets have been approved by the Board of Directors. Odfjell has published an impact statement that commits Odfjell to work to achieve the Sustainability Development Goals as a part of the strategy.

We have implemented an environmental management system to ensure we are in compliance with the IMO MARPOL convention.

Odfjell has a fleet transition plan that is audited by a third party, that outlines details on how to achieve climate targets for the fleet.

In addition, ships have the following certifications covering compliance with international environmental rules and policies (not complete list):
   – Document of compliance for the company covering International Safety Management (ISM) certification
   – Document of compliance for the ship covering International Safety Management (ISM) certification
   – IOPP (International Oil Pollution Prevention) Certificate
   – ISPP (International Sewage Pollution Prevention) Certificate
   – IAPP (International Air Pollution Prevention) Certificate.
   – International Anti-Fouling System Certificate
   – International Energy Efficiency Certificate
   – International Ballast Water Management Certificate
   – Certificates of Civil Liability for Oil Pollution

Environmental Management systems are also audited as a part of the TMSA audit, in accordance with OCIMF TMSA-3 Best Practice Gudiance.

The Board of Directors' role in ESG Governance is described under the Climate Risk assessment framework. ESG matters are reported to the Board of Directors' Audit Committee through Corporate Compliance. 

Odfjell has a Security & Contingency Policy in place including emergency response. Odfjell has dedicated teams and procedures for emergency notification and emergency response management teams (ERMT's).

Odfjell conducts frequent emergency drills, with external facilitators.

The emergency response procedures are audited according to ISM Code. Oil majors and hired experts will do the TMSA audit of the Emergency Response in accordance with OCIMF TMSA-3 Best Practice Guidance.

International standardization continues to be a focus across the terminal organization, however not for the shipping sector (please see also Environmental Management System page before).

All terminals are compliant with the international standards ISO 9001, ISO 14001, and Chemical Distribution Institute-Terminals (CDI-T), and are audited by a third party to ensure compliance with these standards. The focus on standardization allows the terminals to have consistent management processes and common systems.

Odfjell has a whistleblowing policy and procedure, which describes the mechanisms for reporting and investigating concerns about unlawful behavior and behavior that contradicts our Code of Conduct. This includes an anonymous reporting hotline, available both internally and externally. The whistleblowing channel secures confidential and anonymous reporting to Odfjell of issues that should be brought to our attention, and where other reporting procedures cannot be used. The whistleblowing reporting system is provided by an external impartial, independent provider to ensure anonymity. The communication channel is encrypted and password protected. The cases are handled by Odfjell Compliance team.

According to our Whistleblowing Policy, all employees shall have access to reliable channels for whistleblowing and protection from retaliations. Potential whistleblowers shall be protected from all forms of retaliation, disadvantage or discrimination at the workplace linked to or resulting from whistleblowing.

Cases are categorized in the following categories Competition law or Antitrust, Corruption, Criminal offences, Environmental issues, Fraud, Harassment or Discrimination, Health & Safety, Human or Labor Rights, Insider trading, IT security or data privacy, Mismanagement, Other serious misconduct to Code of Conduct and Violations of applicable laws, rules, permits or regulations. 89% of the 9 reported
cases are closed in 2023. There were no discrimination cases during 2023. One harassment case was handled during 2023.

Executive pay policy is explained in the declaration in the annual report and separately reported on our webpage in the Report on salary and other remuneration to leading personnel in Odfjell SE, here.

Short-Term Incentive programs are in place for the different parts of the business including incentives for the Executive Management and are approved annually by the Board of Directors. The incentive systems have ESG KPIs linked to safety targets (LTIF), Odfjell’s climate targets (AER Controlled fleet), performance and financial results (EBIT, Net result, ROCE, Share price).

Executive Management has in addition a Long-Term Incentive Program (LTIP). This program’s KPIs are related to Share price, ROCE, and emission reduction (AER).

The shipping activities are operated in several countries and under different tax schemes, including the ordinary tax system in Norway, the Norwegian shipping tax system and the Approved International Shipping system in Singapore. In addition, we operate under local tax systems, most importantly in Brazil. Companies taxed under special shipping tax systems will generally not be taxed on the basis of their net operating profit. A portion of net financial income and other non-shipping activities are normally taxed at the ordinary applicable tax rate. Taxation under shipping tax regimes requires compliance with certain requirements, and breach of such requirements may lead to a forced exit of the regime.

Odfjell commits to responsible tax practices. We report tax in our annual reports in accordance with IFRS and accounting regulations.

Political involvement is regulated by our Code of Conduct. Odfjell will not participate in party political activity and will make no political contributions anywhere in the world.

Odfjell does not make political contributions.

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