Hesnes Group – Code of Conduct

Code of conduct for employees, Board of Directors and others working for the Hesnes Group

Tenvik, June 2023
Rev: 2

The company culture of Hesnes Holding AS and its daughter and associated companies (“Hesnes Group”) is based on our vision and core values and thus describe our business ethics standards. Hence, this Code of Conduct establishes the general policies and procedures with which all employees must comply with in order to ensure that their behavior meets our requirements to act honestly, ethically, lawfully and with integrity in all situations. This includes speaking up if we come across a situation that conflicts with the Code or our Values. It applies to all our employees, our Board of Directors, and others working with or for the group, including third parties such as suppliers. The Hesnes Group has also a specific Supplier Code of Conduct which is made known to suppliers.

In accordance with the Norwegian Transparency Act 2022, Hesnes Group has also resolved guidelines to ensure compliance with the Transparency Act. These guidelines must also be adhered to by all employees.

Compliance with applicable law

In all business dealings we will comply with fundamental human rights and decent working conditions, as well as the applicable laws and government regulations in the countries in which we work. We are obliged to strive for the highest standards when conducting our business, and will keep in mind our assignment, profession and position when conducting such business. We will not conduct any business for personal gain or act disloyal or breach any applicable law or regulation in any way. All employees shall comply with our internal policies and procedures set out in the Employee Handbook and the HSE Handbook.

Corruption and Bribery

We will neither grant nor offer illegal or unauthorized benefits, such as payments, gifts, accommodation, travel arrangements or other benefits we would not otherwise be entitled to. If we are in fact offered such benefits our policy is to check with the responsible manager if the offer is acceptable or not. Corruption and bribery are illegal and all Hesnes Group employees are committed to comply with relevant laws and customs in all countries in which they operate.

Sustainable development and environment

We are conscious of a sustainable utilization of resources, and seek to minimize waste, climate emissions and other pollution.

Ethical guidelines

We always behave respectfully towards others. All employees shall refrain from bullying, discrimination, harassment and other behaviour that may be perceived as hostile towards others. We do not discriminate on the grounds of gender, politics, race, or sexual preference. All employees are expected to act ethically in all aspects, and each manager and leader has the responsibility of leading by example and to be positive role models and to inspire others.

Drugs and alcohol

Possession, selling or use of illegal drugs is prohibited by law and is thus not tolerated by the Hesnes Group. This applies both at work and when representing our company. In addition, working under the influence of alcohol is not allowed, except where it is acceptable – such as dinners – in moderate amounts and in accordance with local laws and customs.

Conflict of interest

Hesnes Group expects all employees to avoid engaging in any activity, such as other paid employment, hold or trade in assets or investing in competitive companies, that might lead to a conflict of interest between personal interests and those of the Hesnes Group company. Such conflict of interest may compromise our ability to make the best possible business decision. If an employee ever is faced with such an issue, the employee has an obligation to inform and discuss the matter with his or her manager.

Confidentiality

As a professional partner we are always committed to protect sensitive and confidential information, and we show great care before sharing business information with others. Our employees have therefore signed a declaration of confidentiality that will always keep our company and our clients’ interest at heart.

Fair competition

Hesnes Group want to be a trusted partner to our customers, shareholders, colleagues, business partners and the communities where we operate. Our business depends on this trust and we are committed to conducting our business in a responsible, ethical and lawful manner. Fair competition is important to society and creates long lasting business opportunities for the Hesnes Group both domestically and abroad. Creating or benefiting from an unfair advantage will harm our reputation with our customers, business partners and the public. Anti-competitive agreements or practices are against our principles, and against the law. We are committed to fair and open competition and to not engaging in any activities that involve unlawfully obtaining, receiving, using or sharing non-public competitively or commercially sensitive information.

Contact details

Any concern of breach of this Code of Conduct or applicable law should be reported to the responsible manager:

Hesnes Group
Pia K. Harneshaug, CEO
pkh@hesnes.no

Norwegian Energy Trading AS
Benny Clausen, Commercial Manager
bc@norwegianenergytrading.com

Hesnes Shipping AS
Morten Gjølstad, Chairman
mgjol@hesnes.no