Kewatec Code of Conduct (“code”)

1§ Preamble

Oy Kewatec Aluboat Ab (“Kewatec”) is a trusted and preferred employer, builder of mission-ready solutions for professionals who work at sea and developer of innovative solutions for the maritime sector. We are partners to our suppliers and take our social, environmental and governance (“ESG”) responsibility seriously. This Code serves to declare, commit to and ensure the fundamental human rights and social and legal rights of workers. Kewatec pursues the goal of protecting the environment and reducing the consumption of natural resources and promoting ethical business throughout the supply chain.

These binding principles are aligned with the relevant human rights conventions, the International Labor Organization (ILO) conventions, nationally and internationally applicable laws, regulations, conventions and collective agreements as well as the business principles and values of Kewatec.

Our expectation is that all our contractors, suppliers and business partners (hereinafter: “Suppliers”) share the same desire to adhere to the fundamental principles contained in this Code.  To ensure compliance, all Suppliers are required to contractually commit to this Code or their own code of conduct meeting or exceeding the standards set in this Code before entering into any business relation with Kewatec.

Human rights

  1. Fundamental

We respect and support compliance with national and internationally recognized human rights and standards.

We actively promote equal opportunities, equal treatment and tolerance. We refrain from any form of discrimination and treat people equally regardless of ethnic, national or social origin, colour of skin, age, gender, religion, world view, nationality, health status, disability, sexual orientation, social background, political orientation or other protected characteristics. It is a matter of principle that employees are selected, hired and promoted based on their qualifications and skills.

3§ Workers’ rights

  1. Free choice of employment

We do not tolerate any use or form of forced labour, exploitation or slavery.

We do not accept any form of child labor. The legal minimum age for employment shall be strictly observed in accordance with the respective applicable legislation and the internationally applicable ILO conventions. The prohibitions and immediate measures for the elimination of the worst forms of child labor in accordance with Article 3 of ILO Convention No. 182 of 17 June 1999 must be observed.

We recognize the right of all employees to form and join trade unions and workers’ representative bodies. It is recognized and expected that employees are free to form and join trade unions in accordance with the laws of the place of employment and that there are no negative consequences for them arising from the formation, membership or activity in a trade union.

We ensure that the maximum working hours and breaks according to statutory law in the respective country are respected.

We guarantee the (occupational) protection of workers in the workplace and workplace health protection within the framework of the occupational health and valid safety regulations under the applicable national law. We take all reasonably possible precautions to prevent accidents and train all employees in health and safety.

Appropriate measures for ensuring personal health and occupational safety must be taken to ensure healthy working conditions.

Housing and accommodation for workers deployed must meet at least a minimum standard for adequate living conditions. Housing and accommodation is considered adequate if it complies with the guidelines of relevant local authorities at the least and any applicable laws and regulations of the respective country the work is executed.

We pay our employees at least the fixed minimum wage according to national laws and regulations including any applicable collective agreements.

4§ Environmental obligations

We pay due attention to the environment in all operations and strive to minimize the use of natural resources e.g. electricity, raw materials, water and attempt to minimize our carbon footprint.

We prevent pollution of the environment by all reasonable efforts and comply with international conventions and agreements as well as applicable national legislation on environmental protection, including rules on environmentally sound handling, collection, storage, disposal, and shipment of waste.

We encourage our employees to act in an environmentally conscious manner.

5§ Business ethics

  1. Anti-fraud and anti-bribery

We refrain from all forms of fraudulent behavior, corruption, extortion, and bribery and specifically ensure that payments, gifts or other commitments to customers (including Kewatec employees), government officials and any other party duly comply with the applicable anti­ bribery laws.

We respect fair competition and adhere to existing laws and regulations that uphold and promote competition, in particular prevailing anti-trust laws as well as laws that regulate competition. When dealing with competitors these provisions in particular prohibit collusion and other activities aimed at influencing prices or terms of sales, dividing up sales territories or customers or using prohibitive means to inhibit free and open competition. Furthermore, these provisions prohibit agreements which may inhibit customers from their freedom to autonomously determine their pricing and other conditions when reselling products.

We keep the interests of the company and the private interests of employees strictly separate on both sides. Actions and decisions shall be pursued without regard to deliberations which do not concern the business at hand and which involve personal interests.

We safeguard trade and company secrets. Disclosing confidential information and confidential documents to third parties or providing other forms of access to them is forbidden unless proper authorization has been granted by the owner of the confidential information.

6§  Reporting Violations

Individuals are encouraged to report suspected violations of this Code or applicable laws. Reports may be made to supervisors, human resources representatives, or through established reporting mechanisms. Retaliation against individuals who report violations in good faith is strictly prohibited.

7§ Enforcement

Violations of this Code may result in disciplinary action, up to and including termination of employment or contractual relationship. Kewatec reserves the right to take appropriate legal action when warranted.

8§ Acknowledgment

All individuals covered by this Code are required to acknowledge receipt and understanding of these provisions and agree to comply with all applicable requirements.