Code of Conduct

1. General

Seabed’s business concept is to deliver quality subsea services to its customers as contracted using own competence together with owned or controlled equipment and multipurpose DP support vessel. Employee’s and customers’ trust in the Company’s integrity and professionalism, together with the company’s reputation, is vital for the company’s existence and growth.

Seabed commits to operate with high moral and ethical standards, and seeks through this Code of Conduct to clarify the company’s value base and to develop the company’s ethics and culture according to corporate governance. The company culture of Seabed is based on good business practice, and implementing ethical guidelines will further strengthen this culture. The guidelines will help prevent conflicts of interests and prevent misuse of information by setting a clear standard within the company.

This Code of Conduct for Seabed is not exhaustive. The guidelines are based on all Seabed employees acting loyally and responsibly towards the company and its customers, applying common sense and precaution in their work. Seabed expects that all its representatives will act with high ethical standards. The Code of Conduct is applicable for all employees, employee representatives and members of the board of directors in Seabed AS and its subsidiary companies no matter where the company operates. In addition to the Code of Conduct, the prevailing personnel policy of Seabed will be regulating the business.

The management has a particular responsibility for all employees being familiarized with the Code of Conduct, to mange for and to ensure that all personnel comply with the code. All the same, it is expected that all employees, employee representatives and members of the board are familiar with and comply with the Code of Conduct.

2. Relation to the environment

Seabed will carry on its operations in an environmentally responsible way with as little environmental impact as possible. The company aims to apply solutions with no negative environmental impact and will strive for a continuous improvement of its operations also with respect to the environment. Statutory environmental laws and regulations shall be complied with and if current regulations are unclear, the precautionary principle shall be applied as guidance.

3. Relation to the employees

Seabed wants to have a professional relationship with the employees, based on honesty and trust. Therefore, the conditions of the employment contract will be based on the legislation of the relevant country, in addition to any relevant treaty and/or contract/agreements.

Seabed respects all employees and job seekers, and will not accept any unequal treatment, exclusion or preference on the basis of race, gender, age, disability, sexual orientation, religion, political views, national or ethnic origin or other similar circumstances that result in the setting aside or compromising of the principle of equality.

It is an objective for Seabed to maintain a high and recognized standard of Quality, Health, Safety and Environment and (QHSE). The company’s basic attitude is that all incidents can be prevented and that all employees are entitled to a sound work environment. This is focused in the company’s steering documents and is integrated in the company through practical execution and personnel ownership to the various part of the QHSE-system.

The competence and professional skills of the employees is of crucial importance for the business. Seabed will secure the future and growth through further investment in the development of the company’s main asset – people.  Seabed wishes to make use of local manpower wherever the company’s projects are executed, and through this contribute to local development and value creation.

The guidelines pledge employees, employee representatives and members of the board to secrecy. They are obliged to, both during the employment/engagement and after its discontinuance, to conserve complete secrecy towards third party about trade secrets that have come to their knowledge. Employees and members of the board are obliged to exercise caution with regards to the company’s calculations, drawing, estimates, descriptions, correspondences etc. in order to avoid such information coming astray.

The guidelines assume that employees, employee representatives and members of the board have a duty to inform the company about conditions/circumstances that are essential the company, and shall act loyally towards the company and pass good judgment in any situation.

All employees must realize that he or she may be looked upon as a representative of the company also outside working hours, and should thus strive to act in accordance with the company basic values at all times.

4. Business ethics

Seabed will refrain from using alleged/inappropriate anti-competitive measures. The company does not accept any form of corruption and will not grant any benefits or gifts which have a financial or other utilitarian value, which in an improper way can influence a contracting or potentially contracting party.

Company representatives/employees shall not seek to obtain personal profit or profit to closely related persons or organizations, which make their integrity questionable. Employees must not for themselves or others receive gifts, provisions, services or any other contribution that is, or by the giver intended as, suitable to influence the individuals professional duties.  The decision on whether a contribution should be accepted, or not, depends on a specific evaluation in each case. Whether the contribution can affect the integrity of the recipient or not, or give such a damaging impression for the person concerned or for Seabed, is decisive. Gifts or contributions which are given in relation to matters that have not yet been decided on, or can be considered to be indirectly related to the decision-making process, shall not be received/accepted. If in doubt whether the gift/contribution can be accepted, the case should be submitted to the individual’s line manager for decision. Gifts worth more than USD 300 shall be reported to the Management.

5. Acts, laws and regulations

Seabed respects statutory law and regulations in countries where Seabed operates. Current acts/laws, provisions of the acts/secondary laws, contacts and internal instructions shall be complied with by all employees, employee representatives and members of the board.