Code of Conduct

1.1 OBT Shipping Group (the “Company”) has adopted this Code of Business Conduct and Ethics (“the Code”).

1.2 The purpose of this Code is to enhance ethical and transparent process in managing the affairs of the companies within the OBT Shipping Group (the companies within the OBT Shipping Group are hereinafter referred to as “the Company” and/or “Companies”). The code is in alignment with Companies vision and values to achieve its mission & objectives.

1.3 It is principally designed to communicate our business values to our employees, so that they may be a positive force within our day-to-day interactions, both internally and externally. In addition, this Code serves as charter to our clients, partners, and other business relations, indicating the Companies commitment to ethical and honourable business practises.

1.4 Violation of this Code may result in putting us or you at risk, any such violation is therefore likely to result in disciplinary action, up to and including suspension and/or termination of employment.

2.1 The Company requires that all Employees comply with all laws, including anti-bribery, environmental, and safety laws, and all rules and regulations applicable to the Company in all jurisdictions where it operates.


2.2 Employees are expected to act with integrity and use good judgment in seeking to comply with all applicable laws, rules, and regulations.

3.1 Our ethical principles commit the businesses and relevant Persons to:


• Provide high-quality products and services,
• Maintain high standards of business ethics and corporate governance
• ensure the safety of employees, customers, suppliers, business associates, and the general public as a whole
• meet the highest standards in discharging our corporate social responsibility commitments
• Behave with courtesy and respect to everyone we encounter within the course of our business
• privacy of others and the confidentiality of information received in the course of business dealings are respected

3.2 In return, we expect our business partners to promote the application of this Code in all dealings and to adhere to similar business ethics.

4.1 We believe that speaking up is always the right thing to do.

4.2 Employees will not be disciplined, discriminated against, or subjected to adverse personnel action or reprisal because of having made a report in good faith regarding a potential violation of this Code or any other of the Company’s policies or for cooperating in any investigation or inquiry regarding such conduct.

4.3 Under no circumstances will the Company tolerate any retaliation against Employees. We consider acts of reprisal or retaliation to be acts of gross misconduct and will investigate any such reports thoroughly. If substantiated, claims of retaliation could result in disciplinary action and even dismissal.

5.1 Corporate Social Responsibility is the concept whereby organizations integrate social and environmental concerns into their business processes and into their dealings with their stakeholders on a voluntary basis. The Companies are dedicated to adopting best practices in this matter.

5.2 We are fully devoted to the principle of CSR and expects CSR to become embedded, where appropriate, in our policies and practices, for the benefit of staff as well as the broader community. We aim to be recognized as an organization that is transparent and ethical in all our dealings, as well as making a constructive impact on the community in which we operate.

5.3 OBT Shipping Group also supports various charitable organizations such as the Red Cross, Mercy Ships, and other deserving causes in both our region (primarily West Africa) and the rest of Africa.

6.1 OBT Shipping Group strongly opposes the use of child labour and any form of forced labour.

6.2 And does not permit to employment of any person under the age of eighteen years.


6.3 OBT Shipping Group shall not use any means that would oblige or force the worker, threaten him with any penalty to work for it, or compel him to undertake work or provide a service against his will.

7.1 OBT Shipping Group is committed to ensuring the health and safety of our employees, our customers’ employees, and the general public. We believe that incidents and injuries are preventable, and that a job is only well done if it is done safely.

7.2 OBT Shipping Group operations and activities are conducted in compliance with applicable health, safety, quality, and environmental laws and regulations, company standards, and best practices. We take all reasonable and practical steps to ensure that we provide a safe, healthy, and clean working environment.

7.3 Every employee is personally responsible for safety, health, and environmental protection at the workplace to the full extent required by his/her duties to the best of his/her knowledge, ability, and experience, while managers have overall responsibility for HSQE.


7.4 We are all encouraged to identify areas for improvement and continuously work towards improved safety and a better environment.

7.5 A copy of the HSQE polices can be found “here”.

8.1 We are committed to conducting our business in an ethically and socially responsible manner, based on our corporate values and in ways that will protect the environment, appropriate to the nature, scale, and environmental impacts of our activities and service.

8.2 Consequently, OBT Shipping Group plans and conducts its operations according to sound environmental principles. i.e., striving to always carry out work in a manner best calculated to minimize any adverse environmental effect, to prevent pollution of any kind, and to actively seek out ways of reducing environmental damage.

8.3 A copy of the HSQE polices can be found “here”.

9.1  In line with our values and commitments, we respect human rights throughout our activities and business relations in every country where we operate, whether high or low risk, conflict-affected or not, our goal is to ensure that we do not have adverse impact on human rights.

10.1 It is the Company’s policy to conduct its business at all times in a fair and honest manner in accordance with the highest ethical standards.

10.2 Employees should endeavour to deal honestly, ethically, and fairly with the Company’s suppliers, customers, competitors, and other employees. Statements regarding the Company’s products and services must not be untrue, misleading, deceptive, or fraudulent. Employees must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.

11.1 The Company is required to keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of Company assets. The books and records requirements apply to all Company transactions. Each Employee is personally accountable for the accuracy of his or her records and reports. Accurate information is essential to the Company’s ability to meet legal and regulatory obligations, and all reports must be made honestly, accurately, and in a reasonable level of detail.

11.2 All Company books, records, and accounts shall be maintained by all applicable regulations and standards and accurately reflect the true nature of the transactions they record. The financial statements of the Company shall conform to generally accepted accounting rules and the Company’s accounting policies and internal controls, including all requirements for internal controls imposed by anti-bribery legislation.

11.3 No undisclosed or unrecorded account or fund shall be established for any purpose. Under any circumstances, no false, misleading, or inaccurate entries shall be made in Company books or records for any reason, and no disbursement of corporate funds or other corporate property shall be made without adequate supporting documentation. Falsifying records or misrepresenting facts can never be justified or excused, and the Company does not tolerate any kind of fraud.

11.4 Records should always be retained or destroyed according to the Company’s established record retention policies.

12.1 The Company is an equal opportunity employer in hiring and promoting practices, benefits, and wages. We will not tolerate discrimination against any person based on race, religion, color, gender, age, marital status, national origin, sexual orientation, citizenship, or any other basis prohibited by law in recruiting, hiring, placement, promotion, or any other condition of employment.

12.2 Company policy strictly prohibits any form of harassment in the workplace, including sexual harassment, bullying or any verbal, physical or psychological violence.


12.3 These principles apply to all aspects of the employment relationship, such as hiring, assignments, promotion, compensation, discipline, and termination.

12.4 If we believe that anybody has been subjected to discrimination or harassment, we should report this misbehaviour.

13.1 As a Company, we remain independent of any political parties. Company funds are never to be offered or contributed to, or used for the benefit of, any political parties or candidates, or to make any charitable contributions on behalf of the Company unless permitted by law and specifically authorized by the Company’s Group Chief Executive Officer in advance.

13.2 No payments of any kind may be made to induce any public officials to take official action or to direct or indirectly obtain or retain business.

14.1 All employees are required to adhere to and comply with the following regulations:

14.2 Employees’ behaviour and obligations

14.2.1 The employees are the most important asset for OBT Shipping Group and they act as ambassadors for the Company wherever they go. Therefore, we expect that they will focus on representing the Company in the best way possible at all times.

14.2.2 Each relevant person must realize that his/her behaviour will be attributed to the Company and can affect its reputation. Therefore, OBT employees are required to be committed to good behaviour and morals while undertaking work and adhering to honesty and professional integrity.

14.2.3 To live up to our values, we have a set of expectations for our employees. They have a key role in maintaining OBT Shipping Group’s positive image. Therefore, we always expect that all employees will:

• act loyally – both professionally and privately
• show pride in the values of the company
• communicate respectfully both internally and externally

14.2.4 The employees shall perform the work by themselves according to the direction and supervision of OBT Shipping or anyone acting on its behalf, and by the contract, and not outsource the work to any worker or any other person.


14.2.5 OBT Shipping employees are also responsible for preserving the operational means and work tools in their custody and maintaining them by taking necessary actions to preserve them in the places designated for them.

14.3 Confidentiality

14.3.1 Employees must maintain the confidentiality of confidential information entrusted to them by the Company or other companies, including the Company’s suppliers and customers, except when disclosure is specially authorized by a Manager or required by law, regulations, or legal proceedings

14.3.2 All employees shall handle confidential data with care and abide by laws and regulations regarding the collection and use of market data relating to suppliers, business partners, and clients.

14.3.3 Any information announced or obtained internally is to be regarded as OBT Shipping Group’s property, and employees shall protect this information. If an employee suspects that confidential information has been leaked, the employee must inform their immediate Manager.

14.4 Conflict of interest

14.4.1 A conflict of interest occurs when an employee’s private interests interfere, or even appear to interfere, with the interests of the Company as a whole (e.g., self-dealing, nepotism, dating a subordinate or employee relationships, insider trading, patronizing the business of friends and family members). While it is not possible to describe every situation in which a conflict of interest may arise, employees must never use or attempt to use their position with the Company to obtain improper personal benefits.

14.4.2 No employee should become involved in any activity that would conflict or alter his judgement in performing his duties. Any employee who is aware of a conflict of interest, or is concerned that a conflict might develop, should discuss the matter with the immediate manager before taking further action.

14.5 Corporate opportunity

14.5.1 Employees are prohibited from:

• Taking for themselves (or directing to third parties) business opportunities that properly belong to the Company or are discovered through the use of Company property, information, or position without the prior consent, unless the Company has already been offered the opportunity and turned it down;
• Using Company property or information for personal gain or benefit; and
• Competing with the Company. Employees owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

14.5.2 Except to the extent disclosed in advance and approved by the Company, Employees should have no significant financial interest in, or dealings with, competitors or persons who do business with the Company.

14.6 Gifts & Benefits

14.6.1 OBT Shipping Group complies with the anti-corruption laws of the countries in which it does business. OBT Shipping Group will not directly or indirectly offer or give anything of value to any government official, including employees of state-owned enterprises, for the purpose of influencing any act or decision to assist the Company in obtaining or retaining business or to direct business to anyone.

14.6.2 Exchanging commercially sensitive information with competitors, for example prices, costs, product launches or business plans, volumes, market share data is illegal and strictly prohibited.

14.6.3 The Companies prosperity is founded on customer satisfaction. OBT Shipping Group expects us to preserve the quality of our customer relations by maintaining business relationships that are based on integrity, fairness, and mutual respect. Only clear, concrete, pertinent and honest information is to be given to customers. We must be careful to avoid making any statement to a customer that could be misinterpreted.

14.6.4 Suppliers of the Company are to be chosen in consideration of objective criteria, based on quality, reliability, price, utility, and performance or service. Suppliers are to be treated justly, fairly, and honestly. Fees and commissions are to be paid to consultants only in the course of ordinary business relations. Any fees must be substantiated by documentation demonstrating that the amount charged is commensurate with the value of the services rendered.

14.6.5 A copy of the policy can be found “here”.

14.7 Accountability to Owners

14.7.1 The activities of OBT Shipping Group are defined by responsibility and transparency to owners. Achieving a sustainable increase in the value of the Company and protecting its corporate assets are objectives of our corporate work.

14.8 Protection and Proper Use of Company Assets

14.8.1 The Company’s assets are only to be used for legitimate business purposes and only by authorized relevant persons or their authorized designees. This applies to tangible assets (such as equipment, office equipment, telephone, copy machines, etc.) and intangible assets (such as trade secrets and confidential information). These assets must not be removed from the Company premises without the express permission of the head of the department, other than for work-related purposes. Data, programs, or documents must be neither copied nor brought onto or removed from Company premises without permission other than for work-related purposes. Relevant persons have a responsibility to protect the company’s assets from theft and loss and to ensure their efficient and safe use. Theft, carelessness, and waste have a direct impact on the Company’s profitability. If a relevant person becomes aware of theft, waste, or misuse of the company’s assets, such relevant person should report this to his or her manager or the management of OBT Shipping Group.

14.9 Reporting and data protection

14.9.1 Employees are responsible for ensuring that the disclosure in the Company’s periodic reports is full, fair, accurate, timely, and understandable. Records must be accurate. The books, records, files, and statements of OBT Shipping Group must faithfully reflect the entirety of OBT Shipping Group’s assets and liabilities, as well as all of its operations, transactions, and any other items related to its business, without omission or concealment of any kind, by applicable standards and regulations. Employees must report to their supervisor any suspected false or misleading statements, documents, or records made by any employees or directors in the company. All such reports will be treated in confidence.

14.9.2 The documents and data storage media used in the workplace must not come into the possession of unauthorized persons. Relevant persons must therefore keep them secure, must secure computer data through the use and frequent changing of passwords and shall not make copies of business papers or computer files other than for work-related purposes.

14.9.3 A copy of the policy can be found “here”.

14.10 Protection and proper use of company assets

14.10.1 Employees must use the Company’s assets and services for legitimate business purposes of the Company. All employees should seek to protect and ensure efficient use of the Company’s assets, which include its physical assets, and proprietary information such as intellectual property information, financial and business plans.

14.10.2 Unauthorized use or distribution of proprietary information is not permitted. Any personal use of Company resources must not result in significant added costs, disruption of business processes, or any other disadvantage to the company. Theft, carelessness, and waste have a direct impact on the Company’s financial performance and should be reported to the immediate manager immediately.

14.11 Money laundering

14.11.1 Money laundering occurs when a person carries out an act that is aimed at frustrating the identification of the origin, the tracing, or the forfeiture of assets which he knows or must assume originate from a crime. Employees are strictly forbidden from participating in or facilitating a money laundering transaction. Employees shall only conduct legitimate business activities and shall not accept or handle cash or other assets that they have reason to suspect are the proceeds of a crime.

14.11.2 A copy of the policy can be found “here”.

14.12 Anti-bribery and corruption

14.12.1 All employees must read and understand the Company’s Anti-Bribery and Corruption Policy and attend any training provided by the Company.

14.12.2 Company business should be given solely on a basis that reflects both the Company’s best business interests and its high ethical standards. Any transactions involving bribery, facilitation payments, kickbacks, or corrupt business dealings are strictly forbidden, and the Company takes a zero-tolerance policy to any such activity. It is illegal to offer, pay, or receive a bribe, whether paid or received directly or indirectly. There is no need for the bribe to be successful to be viewed as corrupt; the offering can be enough to amount to a criminal offense in certain jurisdictions. These principles apply equally in any country in which the Company operates or carries on business.

14.12.3 A copy of the policy can be found here.

14.13 Code of conduct compliance

14.13.1 All Board Members, Managing Directors, executives, and employees are obliged to comply with this Code of Conduct. The executives have responsibility for the communication and implementation of this guidelines. Anyone who is in breach of the Code will be subject to disciplinary action, including termination of employment. In cases of suspected corruption or other criminal offences, a report will be made to the appropriate authorities.

14.13.2 Employees shall take all appropriate action to make management aware of any known misconduct by fellow employees or other Company personnel that violates this Code. Employees shall report any known or suspected misconduct to their manager or the general counsel, or through the Company’s Whistleblower Hotline (whistleblower@obts.dk).

14.13.3 Employees may choose to remain anonymous but even if they identify themselves, their contact with the whistle blower hotline will remain strictly confidential. All reports will be promptly investigated and treated confidentially to the extent reasonably possible.

15.1.1 This Code shall be distributed to all employees, officers, and directors of the Company upon commencement of his or her employment or service to the Company, and on an annual basis thereafter. Each recipient will be asked to sign a copy of Verification of Receipt and Understanding, a form attached to this Code, which will be part of his or her permanent record with the Company to confirm his or her understanding of how this Code applies to him or her and to acknowledge his or her obligation to abide by this Code.

15.1.2 The Company will take all the appropriate actions to ensure that the code is acknowledged to all third parties doing business with us. Relevant reference, where the appropriate, will be included in Company’s written communications with third parties.

15.1.3 The Company reserves the right to amend, alter, or terminate this Code at any time for any reason.