Code of Conduct

Introduction
This document of NMT International Shipping B.V. sets out the Code of Conduct observed by all directors and employees of the NMT Group (“NMT”). All directors and employees are expected to perform their day-to-day business activities in compliance with applicable laws, company regulations and social and ethical norms stated in this underlying Code of Conduct. This code of conduct contains four main topics; our legal commitments, the way we do business, our working environment and confidential information.
 
This code of conduct is made available for all directors and employees of NMT.


Our legal commitments

Compliance with applicable laws
We fully comply with all laws and regulations within the applicable regulatory landscape. Hereby we carefully adhere the standards of business conduct relevant to our assignment, profession and position. We will not be prompted by any misguided sense of loyalty or desire for personal gain to violate applicable laws, company principles, policies or policy descriptions. 

Environmental laws
We comply with applicable treaties, laws and regulations related to the environmental law of the countries we do business with. Furthermore, we strive to preserve the environment by taking into consideration our own impact on the environment. Safe, sustainable and environmentally sound performance are essential factors of our business concept and intrinsically linked to the NMT brand name. Every employee can count on full support from management to take action in case of events that might result in an accident or environmental incident. Not taking action is a threat to all our activities and therefore not accepted.

Anti-money laundering and counterterrorism financing laws
We are committed to fully comply with all applicable anti-money laundering and counterterrorism financing laws, and will only accept funds received from legitimate sources. Since NMT is well aware of the risks concerning this subject within the industry its operating, internal measures have been taken to reduce the risk of money laundering and terrorist financing described in the AML, CTF & Sanction Policy.

Trade Sanctions
Various countries and organizations, such as the United Nations, European Union and Office of Foreign Asset Control (OFAC) have imposed trade sanctions against certain countries, organizations and individuals. Many of these trade sanctions apply to transactions beyond the borders of the country which is imposing these sanctions. Some sanctions impose a complete ban on all transactions while others may ban a specific type of transaction, such as trading in specific goods or providing particular services. NMT does not do business with sanctioned countries, organizations or individuals, unless permitted by law. The internal measures taken to reduce the risk of non-compliance with trade sanctions are described in the AML, CTF & Sanction Policy.


The way we do business

Fair business conduct
We conduct our business in a safe, fair and ethical manner. We aspire to reach mutual transparency and pro-activeness of all business partners, employees and other stakeholders. In order to do so we  provide our information in a transparent, essential, consistent and correct manner within the limits of commercial confidentiality.

Facilitation payments
A facilitation payment is defined as a small, unofficial payment to a low-level public official made to speed up or obtain a routine administrative process. Such payments are not limited to monetary consideration, but may take other forms such as gifts or entertainment. We understand that in some countries facilitating payments are still unavoidable means of securing routine, low-level action and/or approvals. Nevertheless, such payments are a type of bribe and in breach with existing laws. Although we recognize that in practical point of view it is a challenge in some countries to eliminate facilitation payments, we are committed to work towards eliminating such practices.

Bribery
We have a zero tolerance policy towards bribery. We define bribery as acceptance, offering, solicitation or promise of benefits (monetary or otherwise) in order to gain business advantages which we were otherwise not entitled to. In case we receive such offerings we will question its origin and question why it is being offered and if anything is expected in return. We ensure that all offerings of any significance are disclosed and approved. We are committed to comply with (global) relevant laws prohibiting bribery. Our Global Anti-Bribery Policy describes the applicable and specific internal measures of NMT to prevent involvement in bribery.  
 
Conflicts of interest
We do not engage in activities or hold or trade in assets that involve, or might appear to involve, a conflict between our personal interests and those of the company. Such conflicts of interest could compromise our ability to make correct business decisions. In case of doubt, we will discuss the situation with our respective office or manager.  


Our working environment

Working conditions
We act with respect towards the people we work with. We do not discriminate on race, gender, sexual preference or any other grounds. We believe that a safe and healthy work environment is a top priority and therefore we ensure to make daily efforts to prevent accidents at work. We also make sure that wages and other related benefits meet at least the legal and industry minimum standard of the country of operation. Within these countries we also comply with applicable laws and industry standards on working hours.

Employees should be granted stipulated annual leave, sick leave and parental leave without any negative repercussions. We ensure that the registration, filing and use of employee data is treated with strict confidentiality and in accordance with local legislation. Employment records will not be shared outside the NMT Group, unless it is required by law or with the written consent of the employee concerned. We want to provide a safe and healthy work environment for all employees, contractors, visitors and suppliers and are committed to continuously improve this within our organization.

Human rights
We support and respect the UN Universal Declaration of Human Rights. We support the International Labour Organisation’s International Program on the Elimination of Child Labour (IPEC), with the aim of the abolition of child labour in our sphere of influence. We do not accept any form of forced labour and we do not accept the use of prison labour or illegal labour in the production of goods or services within our supply chain.

Entertainment
Expenses related to necessary business entertainment will be kept within reasonable limits. We also refer to the bribery paragraph in this code of conduct.

Prohibited substances
Consumption of alcohol in the workplace is not allowed except when it can be considered acceptable, but only in moderate amounts and appropriated with the circumstances, local customs and applicable laws. Possession or use of any substance prohibited by law is not tolerated while on duty or representing the NMT group.

Confidential information
We act with great care regarding sharing confidential or business sensitive information with others. Information is a valuable asset. Non-public information that employees possess through their work, from whatever source, must be kept confidential to prevent others from copying our work or obstruct relations with our customers. This also applies after termination of employment. Employees are not allowed to release any information that is commercially sensitive, contentious or that may have undesired contractual or legal implications for the NMT Group. It is not allowed to discuss, directly or indirectly, confidential matters that could lead to competitive disadvantages in places or situations where such discussions can be overheard. Employees should remember that communication via e-mail, internet and other social media could be regarded as a statement of the NMT Group.

version 2.0 - February 2021