Wallenius Wilhelmsen Logistics Code of Conduct Wallenius Wilhelmsen Logistics Code of Conduct 1 Our core asset is the people in our organisation
2 Wallenius Wilhelmsen Logistics Code of Conduct Dear Fellow WWL Employee, The Code of Conduct is an essential document for Wallenius Wilhelmsen Logistics. Its most important success factor is that all employees take personal responsibility to live up to the expectations set forth in the Code of Conduct provisions. As employees, all of us are the face of the company for our customers, our business partners, our suppliers and, equally important, to the local communities in which we operate. All of us, no matter what role you have, represent the company through behaviour and actions, and I encourage you to support our reputation as a good and respectable corporate citizen. Together we can continue developing our company and our position as a contributing member of society and a frontrunner in our industry. It is your responsibility to read and familiarize yourself with this Code of Conduct and to perform your role and responsibilities in accordance with the requirements set out here. With best regards, Christopher J. Connor, President & Chief Executive Officer General The WWL Code of Conduct provides a framework for what WWL considers responsible business conduct, but it is not exhaustive. This Code of Conduct, together with the WWL values, constitutes the basis and framework for our performance culture and our governing policies, such as the Compliance Policy. The Code of Conduct guides both the development of our policies and processes, as documented in our Quality Management System, as well as how we execute these in our business practice and personal conduct in delivering value to our customers and the society around us. The Code of Conduct is a complement to the laws and cultures in the countries we operate and addresses core values in the areas of human rights, labour standards, the environment and anticorruption, and as such it is an important pillar of our commitment to corporate social responsibility and our commitment to the UN Global Compact.
Wallenius Wilhelmsen Logistics Code of Conduct 3 Scope and responsibility This Code of Conduct is applicable to all employees (permanent and temporary) and consultants in WWL, its subsidiaries (including subsidiaries more than 50% owned by WWL), and joint ventures that are majority owned or controlled by WWL. It is your responsibility to read and familiarize yourself with this Code of Conduct and to perform your role and responsibilities in accordance with the requirements set out here. Suppliers, subcontractors, agents, and other business partners of WWL, (including companies in which WWL has a minority stake, acting on behalf of WWL), are expected to adhere to standards which are consistent with WWL s Code of Conduct. WWL will promote and strive for such adherence. If you have questions regarding the content or interpretation of this Code of Conduct, or if you are in doubt with respect to what would be the appropriate way of handling a potential unethical situation, please consult your manager, Human Resources, Legal or a representative of the Compliance Committee. Violation of the Code of Conduct or any applicable law may result in internal disciplinary action in accordance with relevant legislation, termination of employment as well as legal proceedings.
4 Wallenius Wilhelmsen Logistics Code of Conduct Wallenius Wilhelmsen Logistics values The company values are the foundation for all actions within the organisation. These values define the basis for employee behaviour and all employees in the organisation are expected to be familiar with and understand the company values. Our Code of Conduct is based on the company s values. Empowerment Engage & Take Responsibility Innovation Challenge & Improve Customer Centred Understand & Deliver Teaming & Collaboration Share & Contribute Stewardship Care & Respect
Wallenius Wilhelmsen Logistics Code of Conduct 5 Employees WWL s core asset is the people in the organisation. WWL s competitiveness and brand value are dependent on responsive, competent and motivated people with a good understanding of the total business environment. WWL expects employees to give their best efforts and learn from their successes and failures in order to improve their performance. Each employee is expected to act with the highest sense of integrity on behalf of the company. We are known as a company that takes the initiative to learn about our customers and their needs. All employees should aim to deliver the best services and contribute to our customer s satisfaction while working in the best interest of WWL. We should deliver solutions that represent value for the customer and are profitable for us. We should strive to create a positive atmosphere characterized by tolerance and respect towards one another. WWL has a unique environment of employees from different cultures, which gives us the opportunity to learn about one another and create new values through collaboration. As a partner in the UN Global Compact, WWL is committed to contributing to social responsibility on a global level.
6 Wallenius Wilhelmsen Logistics Code of Conduct Equal opportunity and diversity in employment WWL does not discriminate on the basis of race, colour, religion, gender, age, nationality, sexual orientation, disability or any status protected by law. All employment must be in compliance with all applicable laws, including regulations on working hours, protection of health, equal opportunity, compensation and human rights. WWL strives to have women and minorities represented throughout the company. We provide equal opportunity for employment and advancement to everyone. Anti-harassment and discrimination policy WWL prohibits any harassment or discrimination based on age, nationality, gender, race, sexual orientation, religion or colour. All employees shall be protected from all types of harassment (including sexual harassment) in the workplace and are encouraged to bring complaints forth in good faith. (See Discrimination, Harassment and Bullying Explanatory Note on the Global Intranet.) Protection of health and safety In WWL, all employees should work in a healthy and safe workplace. We strive to create a clean and orderly working environment in full compliance with the standards mandated by law. Working hours and compensation WWL complies with all applicable laws and regulations relating to working hours. We always provide reasonable pay for services performed and never lower than the minimum wage in the local job market. Equal pay for work of equal value WWL has a performance-based management system. Compensation is based upon the achievement of results, experience and knowledge, education and local market conditions. WWL has non-discriminatory payment practices and accepts the principle of equal pay for work of equal value. Human rights WWL supports and works in compliance with the internationally recognised UN Universal Declaration of Human Rights.
Wallenius Wilhelmsen Logistics Code of Conduct 7 Forced, exploitative and child labour WWL condemns all forms of forced labour and all exploitative working conditions and does not employ, or cooperate, with entities that employ persons under the legal working age. Is it legal? Freedom of association Subject to the applicable laws and regulations, we cooperate with employee representatives with the aim to achieve balance between the interests of the company and interests of the employee. Fair competition Competition and anti-trust law promotes free enterprise and prohibits behaviour that restricts fair competition and applies to all business areas. It combats illegal practices such as price fixing, allocation of customers or markets, or any abuse of a dominant market position. WWL is committed to fair competition and does not tolerate violation of competition and anti-trust laws and regulations. Is it in accordance with our ethical principles? ETHICS LAW IDENTITY Is it in accordance with our values? Conflict of interest Activities that create conflict between personal interests and the interests of WWL should be avoided by all employees. Is it profitable? ECONOMY MORALITY Is it right? REPUTATION Does it affect our goodwill?
8 Wallenius Wilhelmsen Logistics Code of Conduct Bribes and facilitation payments WWL is committed to prevent the occurrence of bribery in all activities under our effective control. Any offering or accepting of bribes in any form to any person, whether private or public, direct or indirect, through third parties, is prohibited. WWL recognizes that facilitation payments are bribes, and as such WWL is committed to work to identify and eliminate them. If a facilitation payment is demanded of you in order to avert an immediate threat to life or health of any person, such payments are not prohibited, but must be immediately reported to Legal & Compliance. Further guidance with regard to WWL s stance on bribery can be found in our Anti-Bribery & Anti-Corruption Policy. Gifts and favours WWL employees, or members of their families, must not allow gifts and hospitality to influence their objectivity and independence, or cause others to perceive an influence. Reversely, no WWL employee shall offer gifts or hospitality when it could affect, or be perceived to affect, the outcome of a business transaction. Even gifts of moderate value should only be offered or accepted where it is an acceptable business practice. Gifts or benefits received or given with a retail value of more than USD 200 must be recorded in WWL s Gifts and Gratitude Register, and declared to immediate managers.
Wallenius Wilhelmsen Logistics Code of Conduct 9 External information/insider trading WWL strictly prohibits the disclosure of any business-sensitive information about the company or customers that is not in the public domain, such as sharing information about the names of customers externally. Any inside information that can have value to others should be handled appropriately and under no circumstances be provided to other parties. Protection of company information Company information should be managed in a secure manner. This includes preventing unauthorised disclosure of company information to any other person or organisation as well as copying or removing the company information in whatever form from the company s premises without due authorisation. Each employee s obligation to safeguard company information continues even if employment with WWL has been terminated. Environment WWL is dedicated to reducing the negative impact of our operations on the environment. While we are committed to complying with all applicable environmental regulations, our ambition is to always be that vital step ahead of existing and emerging requirements by implementing environmental procedures and technologies that we believe will lead the way in our industry. We expect and encourage our employees to support and participate in activities promoting the reduction of pollution, conservation of resources and other means of environment protection. We also offer, on a discretionary basis, support to community initiatives that demonstrate commitment to environmental responsibility.
10 Wallenius Wilhelmsen Logistics Code of Conduct Proper accounting and record keeping WWL maintains the highest standards in our accounting and financial information. Our records have to be accurate, complete and processed in a timely manner. All employees involved in accounting and reporting are responsible for the accuracy and validity of all the company s financial records. Quality Management WWL uses ISO 9001 to drive quality standards in the business. We are continuously developing and improving our quality management system to ensure customer satisfaction by meeting, and where possible exceeding our customer s requirements. All employees should know our Quality Policy. WWL s processes, policies, procedures and instructions can be found in the Quality Management System. Each employee is responsible for knowing and following the documents relevant to the area in which they work. This ensures that we deliver high quality to our customers, work according to best practice as well as contribute to continuous improvement. Declaration of compliance As an employee in WWL, you will be requested on an annual basis (in connection with the Performance Dialogue), to confirm that you have read and familiarized yourself with this Code of Conduct and performed your responsibilities in accordance with the requirements set forth here. Suppliers, subcontractors, agents and other business partners are expected to sign declarations confirming compliance with standards which are consistent with the Code of Conduct of WWL.
Wallenius Wilhelmsen Logistics Code of Conduct 11 Questions about the Code of Conduct If you have questions regarding the content or interpretation of this Code of Conduct, you are strongly encouraged to contact your manager, Human Resources, Legal or a representative of the Compliance Committee. Contact channels for concerns regarding ethical business conduct If you are aware of unethical conduct, you should immediately report this to your manager or another WWL manager you trust, Human Resources, Legal, or a representative of the Compliance Committee. Your willingness to come forward with concerns is important to us. You can report unethical behaviour and policy violations securely and confidentially by using the Ethics Alert Line either via the web or by telephone. Details can be found on the Global Intranet. WWL ensures that there will be no retaliation against you for reporting possible violations in good faith. Any employee knowingly making a false report with the purpose of harming another individual will be subject to disciplinary action. For any questions please contact the Global Head of Human Resources.
12 Wallenius Wilhelmsen Logistics Code of Conduct Responsible logistics from factory to dealer Wallenius Wilhelmsen Logistics delivers innovative and sustainable global shipping and logistics solutions for manufacturers of cars, trucks, heavy equipment and specialised cargo. The company has a strong environmental focus and is an industry leader in developing innovative solutions to reduce its operational impacts on the environment. Our company history goes back centuries, and we plan to continue to contribute to the global logistics industry for centuries to come. We have a responsibility towards our customers, towards the communities in which we live, and towards one another in the company. Responsible logistics is about having a long term view in customer relations, with regards to the environment, on social responsibility and governance. It s about doing our job with the next generation in mind. www.2wglobal.com