Introduction
Since its founding, Walblue Transport And Maritime Limited. (WALBLUE)’s business practices have been governed by integrity, honesty, fair dealing and full compliance with all applicable laws. WALBLUE employees have upheld and lived this commitment in their everyday responsibilities ever since while maintaining WALBLUE’s reputation, one of the Company’s most important assets today.
The Code of Business Ethics prescribes certain values and principles which WALBLUE has committed to since its inception. This Code of Business Conduct specifies and helps the continued implementation of the Corporate Business Principles by establishing certain non-negotiable minimum standards of behaviour in key areas. The nature of this Code is not meant to cover all possible situations that may occur. It is designed to provide a frame of reference against which to measure any activities. Employees should seek guidance when they are in doubt about the proper course of action in a given situation, as it is the ultimate responsibility of each employee to “do the right thing”, a responsibility that cannot be delegated. Employees should always be guided by the following basic principles:
–avoid any conduct that could damage or risk WALBLUE or its reputation;
–act legally and honestly;
–put the Company’s interests ahead of personal or other interests.
For the purposes of this Code, references to “employees” include employees, associates, officers and directors of WALBLUE and its subsidiaries
PURPOSE AND VALUES
Integrity
Great companies want to do business with other great companies. Integrity is a pillar upon which the Walblue Transport And Maritime Limited name stands, and it is important that we always do the right thing, even when no one is looking. We treat others the way we want to be treated – with honesty, fairness, dignity and respect – and we expect the same in return. We deal ethically in all transactions, because our lasting and most beneficial relationships are built on trust, which comes from doing the right thing with our fellow employees, customers and stakeholders.
- Integrity in action
- We act with honesty and fairness
- We treat all with dignity and respect
- We deal ethically in all transactions
- We speak up to ensure right behavior
Safety
Safety begins and ends with each Walblue Transport And Maritime Limited employee. At Walblue Transport And Maritime Limited we see change as opportunity. We believe that to be truly successful, we must be responsible for the safety of our staff. Due the nature of our work, we surround ourselves and the environment in layers of defense. We wear proper protection, perform safety assessments and continually improve protocol and procedures.
We recognize and correct potential hazards when something is not right. To speak up and fully listen is a vital behavior and everyone has the authority and obligation to stop work if they believe it is not safe. Safeguarding the environment is a key element of this value. With vigilance and commitment, zero harm to people, property and the environment is attainable.
Safety in action
- We take responsibility for our own safety and for those around us
- We recognize and correct potential hazards
- We follow protocols and procedures
- We speak up and stop work if safety is compromised
High Performance
High performance is not only valued, it is expected. WALBLUE people provide extraordinary service. Our knowledge, passion, talent, ingenuity and helpfulness drive business for the company and create customer loyalty. Together as One WALBLUE, One Team we are stronger than a collection of individuals. Our team approach requires everyone to contribute and to be accountable to one self and to each other. Learning and continuous improvement is an expectation of our work.
High Performance in Action
- We deliver on our commitments
- We embrace innovation and continuous process improvement
- We succeed as a team when everyone is accountable and contributes their knowledge, skills and best effort
- We cast a positive shadow to provide leadership at all levels of the organization
COMPLIANCE WITH LAWS, RULES AND REGULATIONS
We respect the law at all times
WALBLUE and its employees are bound by the law. Compliance with all applicable laws and regulations must never be compromised. Additionally, employees shall adhere to internal rules and regulations as they apply in a given situation. Those internal rules are specific to the Company and may go beyond what is required by the law.
CONFLICTS OF INTEREST
We will always act in the best interests of WALBLUE
A Conflict of Interest may arise, for example, when an Employee engages in a business transaction with a third party(including, but not limited to, a freight forwarder, a broker and a non-vessel operator), in which the Employee or family member has a financial or personal interest (for example, as an owner, shareholder, board member, officer, employee or agent).
No Employee should become involved in any activity that would conflict or alter his judgement in performing his duties. Whenever circumstances give rise to such a Conflict of Interest, or even the appearance thereof, such Employee should obtain specific written authorization before participating in business where his impartiality is likely to be questioned.
If the Conflict of Interest relates to a significant value of business for WALBLUE, it must be cleared by the relevant management and, when in doubt, WALBLUE Senior Management.
ANTITRUST AND FAIR DEALING
We believe in the importance of free competition
We believe in the importance of free competition WALBLUE is prepared to compete successfully in today’s business environment and will always do so in full compliance with all applicable antitrust, competition and fair dealing laws. Therefore, employees must at all times adhere to the following rules:
–Commercial policy and prices will be set independently and will never be agreed, formally or informally, with competitors or other non-related parties, whether directly or indirectly;
–Customers, territories or product markets will never be allocated between WALBLUE and its competitors but will always be the result of fair competition;
NON-DISCRIMINATION
We embrace diversity and respect the personal dignity of our fellow employees
The diversity of Employees is one of WALBLUE’s greatest assets hence we are committed to maintaining a workplace free from discrimination and harassment. Therefore, employees must not discriminate on the basis of origin, nationality, religion, race, gender, age or sexual orientation, or engage in any kind of verbal or physical harassment based on any of the above or any other reason.
Employees who feel that their workplace does not comply with the above principles are encouraged to raise their concerns with the HR Department. WALBLUE is firmly committed to support equal employment opportunity and diversity by ensuring that all decisions to recruit and promote are based on merit.
WORKING CONDITIONS
WALBLUE supports and respects internationally recognized human rights in conducting its business relationship and activities worldwide. WALBLUE believes that each person deserves to be treated equally and properly and this responsibility lies also with every Employee.
WALBLUE not only abide by the prohibitions against forced labour and any form of exploitation or slavery as defined by the Forced Labour Convention, but also strive to provide Employees with a good working environment
WALBLUE prohibits the use force labour including prison labour, indentured labour, bonded labour or other forms of forced labour. WALBLUE does employ minors (individuals under the age of completion of compulsory education) in it’s of work.
ENVIRONMENTAL PRACTICES
We maintain the safety and cleanliness of our natural resources. We have a responsibility to conduct our business activities in a manner that protects and preserves our natural resources. In doing so, we will comply with all environmental laws and operate our facilities with the necessary permits, approvals, and controls.
CONFIDENTIAL INFORMATION
All Employees must safeguard all of WALBLUE’s Confidential Information as well as any Confidential Information received from WALBLUE’s customers, suppliers and any other third parties.
Failure to do so could result in a breach of obligations arising under contracts or laws protecting business secrets, data protection, and privacy. Confidential Information must not in any case be disclosed to anyone outside of WALBLUE, including to family and friends, except if legally required.
Confidential Information must not be shared with others inside WALBLUE except on a “need to know” basis. All Employees are obliged to protect Confidential Information, even after employment or business ends.
DATA PROTECTION AND PRIVACY
WALBLUE respects and protects the privacy of its Employees, customers, and business partners, processing the personal information in accordance with the requirements established by applicable data protection laws.
Personal information is processed fairly and lawfully and for specified and legitimate purposes. WALBLUE stores the personal information securely and takes precautions to prevent unauthorized disclosure.
CONTRACTS
Each Employee must obtain all appropriate approvals before executing, modifying, or amending any contract.
Unauthorized contracts or modification of contracts including oral agreements are prohibited and will not be recognized by WALBLUE.
ANTI-BRIBERY AND ANTI-CORRUPTION GUIDELINES
“WALBLUE condemns all forms of bribery and corruption. It promotes its products on the basis of their value, quality, price, competitiveness and sustainability, and not on the basis of improper advantages.”
WALBLUE is committed to undertake business fairly and to uphold all applicable anti-corruption laws. WALBLUE strictly prohibits all Corruption, Passive and Active Bribery, and Facilitation Payments.
Under different legislation, such conduct can lead to imprisonment for individuals and heavy fines for individuals and entities.
WALBLUE reserves the right to take disciplinary action towards any Employee engaged in such conduct. Employees must not engage a third-party agent, consultant or supplier if there is reason to believe that the agent, consultant or supplier may attempt to breach WALBLUE’s anti-bribery policies.
Should Employees be asked to participate in Facilitation Payments they must actively refuse the payment and immediately inform their Compliance Officer. The fact that the payment was first proposed by the other party does not alter the conduct. WALBLUE has a zero-tolerance.
Any Gift and Entertainment received or given by any Employee must be properly reported
Gifts
Gifts offered to third parties (such as customers, distributors, service providers, government officials, or other professionals) be reasonable, modest and appropriate under the circumstances and must not create the appearance of improper influence or illegitimate advantage. Gifts should normally be offered only on customary business and cultural occasions and shall never include cash or cash equivalents.
No gifts of any nature should be offered in the context of a decision affecting WALBLUE by the relevant authority or government official which is pending or imminent.
