Code of Conduct
Our Code of Conduct enforces good ethical behavior in everyday business activities. This applies to all employees, directors, and representatives of the company, irrespective of domicile. Odfjell's Code of Conduct puts great emphasis on transparency, good ethical behavior and compliance with relevant laws and regulations.
Supplier Conduct Principles
Odfjell is committed to the principles in the United Nations (UN) Global Compact. Odfjell, including subsidiaries and activities managed by Odfjell, adheres to high ethical and environmental standards in the way we conduct business.
Anti-corruption and Whistleblowing
Odfjell is firmly opposed to all forms of corruption, ans expects our personnel to adhere to the highest standard of moral and ethical conduct and not engage in any form of corrupt practices, including extortion, fraud, or bribery. Our personnel must at all times comply with relevant anti-corruption and anti-bribery laws, rules, and regulations of Norway and countries where Odfjell operates.
Whistleblowers play an essential role in exposing fraud, corruption, unauthorized use of funds, mismanagement, criminal offenses, dangers to health and the environment, and other wrongdoing that threaten our integrity, both financially and morally.
As part of our integrity culture, we have implemented a whistleblowing procedure to enable employees and third parties to report suspected wrongdoings in the company.
Anti-corruption Policy Whistleblowing Policy Report a concern
Antitrust/Competition Compliance Policy
Odfjell’s policy is to fully comply with the competition rules in all jurisdictions where we operate. Odfjell prohibits any discussion or other communication about the purposes or effects that may be construed as an agreement or understanding, or an attempt to induce others to enter into an agreement or understanding, such as
- Fix prices with competitors
- Allocate markets or customers
- Discuss prices with competitors
- Restrict the supply of products or services to others
The following agreements or understandings with competitors may be illegal:
- Sharing information with a competitor
- Refusals to Supply Competitors or Customers
- Artificially high or low rates
- Exclusive Dealing
- Tying
- Discriminatory Discounting
Odfjell has appointed a Corporate Compliance Officer, responsible for carrying out Odfjell’s Compliance Policy and the training program.
Violations or suspected violations of the competition rules by Odfjell employees shall be reported to your superior or the Compliance Officer according to Whistleblowing Policy.
Any breach of competition law is likely to have serious consequences for Odfjell and those who work for Odfjell, and can result in a criminal prosecution against individuals, severe financial penalties and damage to Odfjell's reputation. Odfjell will therefore take a tough stance against violations of the competition rules and the Compliance Policy. Penalties may include pay reduction, demotion, termination of employment and dismissal.
Whistleblowing Policy Report a concern
Sanctions Policy
Odfjell will comply with all economic sanction laws and regulations, embargoes and other forms of trading restrictions to which it is subject, in all countries where we operate. 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 will maintain effective measures to ensure compliance with and awareness of our sanctions-related obligations. The responsibility for sanctions screening lays in the concerned units: Commercial, Finance, Legal & Insurance.
Odfjell is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists, and will therefore screen against sanctions lists in all jurisdictions in which we operate, including:
- the United States Government
- the United Nations Security Council
- the European Union
- the United Kingdom
- the Flag State
- the People’s Republic of China
- the respective governmental institutions and agencies of any of the foregoing, including without limitation, the Office of Foreign Assets Control (OFAC), the United States Department of State, and Her Majesty's Treasury (HMT)
Sanctions apply to individuals – not just companies – so EU and US nationals operating outside the EU/US must be aware of the specific Sanctions applicable to them in addition to those that apply to their employer.
Odfjell and our subsidiaries must also be aware of sanctions-related obligations in third-party agreements (such as lending and insurance agreements), and ensure that we do not breach the terms of such obligations, particularly where these extend beyond Odfjell’ own legal obligations (e.g. agreements between US banks and EU Odfjell entities).
Failure to comply with sanctions can lead to severe civil and criminal penalties, both for our business and individual employees, officers and directors, as well as significant reputational damage for Odfjell. Non-compliance with this policy is a serious matter that may lead to disciplinary action, up to and including dismissal. Violations of sanctions can also have legal consequences for individuals involved, including severe monetary fines and imprisonment. Employees shall report any suspected violations of this policy to their superior or the Compliance Officer according to Whistleblowing Policy.
Whistleblowing Policy Report a concern
