1          Purpose

The Connector Subsea Solutions (CSS) Code of Conduct governs the obligations and relationship between the CSS Group and the third parties we work with. These include parties providing goods or services to the CSS Group, such as manufacturers, distributors, sub-contractors, services providers, and other vendors as well as all other third parties the CSS Group work with, such as commercial agents and joint venture/joint bidding partners, hereafter called Business Partners.

CSS’ core values underpin our business activities and support the delivery of a professional, high-quality service to our clients whilst building the trust of our stakeholders. This commitment to our values extends to CSS’ dealings with all our Business Partners to ensure that we are conducting our business in a responsible manner; a commitment CSS expect to be respected and supported by all our Business Partners.

We base our requirements mainly on international agreed standards such as the Universal Declaration of Human Rights, the principles in the UN Global Compact, applicable ILO Conventions as well as national legislations in countries of domicile.

By implementing this Code of Conduct, CSS seek to strengthen the relationship with our Business Partners minimize business risks and support our long-term goals. In order to achieve this, CSS require our Business Partners to adhere to sound legal and ethical business practices.

2          Business Conduct and Ethics

CSS Business Partners shall comply with all laws and regulations applicable within their jurisdiction in which it operates. In addition, CSS Business Partners shall take reasonable measures to make sure that its own suppliers and partners comply with applicable laws and regulations for their relevant jurisdiction, including UN and ILO conventions.

CSS Business partners shall maintain the highest standard of business ethics, respect laws and shall actively promote ethical business practices and undertake reasonable steps to ensure that its own supply chain is free from the acts defined below:

• Neither tolerate nor engage in corruption, either directly or via a third party. This includes promising or giving anything of value to a public official or a private individual in order to obtain or retain business or to gain an improper business advantage. Accepting anything of value which is inappropriately influencing business decisions is likewise forbidden. CSS considers facilitation payments to be a form of corruption and is obliged to, under no circumstances, receive such payments.
  • Not make any payments, loans, gifts for the benefit of any official, employee of government or a political party, directly or indirectly.
  • Avoid an actual or perceived conflict of interest and promptly disclose any conflict of interest or potential conflict of interest which may affect CSS or its business.
  • Compete fairly within the framework of applicable competition laws and shall abstain from unfair trade practices.
  • Keep any entertaining and hospitality with CSS employees appropriate and reasonable in nature.
  • Respect and safeguard CSS’ confidential information, know-how, technical information and intellectual property. All information provided by CSS is only to be used by Business Partners for its agreed or intended purpose and may be shared with third parties only if and to the extent necessary for the proper execution of any task agreed to by CSS.

3          Employment Practices and Human Rights

3.1        Employee rights

CSS Business Partners shall uphold minimum commitments described in the fundamental Core Conventions of the International Labor Organization³. This includes:

• Respect and maintain their employees’ freedom of association.
• Employees throughout the supply chain shall be entitled to collective bargaining in accordance with applicable laws and regulations.  Employees should also have the option of not joining a union or other representative body.
• Suppliers and subcontractors must ensure a safe, secure, and healthy working environment. Risk of accidents, personal injury and exposure to health risks shall be minimised.
• A written employment contract in a language the employee understands must be in place before work can start.
• Working hours must be in accordance with national laws.
• Wages must comply with the national minimum wage regulations.
• Workers must receive appropriate and adequate training.

3.2        Human rights

CSS Business Partners shall respect human rights and commit to respecting the rights, dignity and freedom of all, this includes:

• Not use involuntary-or forced labour. CSS Business Partners shall comply with applicable laws regulating the minimum working age.
• Ensure that its goods and/or services are free from acts constituting modern slavery in any form including servitude, child labour, forced and compulsory labor and human trafficking.
• All employees shall be treated with respect and dignity. No employees shall be subjected to harassment on the basis of sex, sexual orientation, gender or gender orientation.
• All employees shall have the freedom of expression, and the freedom of conscience, religion, thought, belief and opinion.
• Commit to creating a fair working environment and comply with all applicable laws on discrimination in employment processes.
• Equal opportunities shall be based solely on relevant qualifications, skills and experience, regardless of race, skin colour, religion, gender, age, national origin, sexual orientation, marital status or disability.

http://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang–en/index.htm

4          Health, Safety, Security and Environment

CSS Business Partners shall encourage and reinforce sound health, safety, security and environmental practices and awareness throughout its supply chain, including the reporting of incidents, near misses and hazardous conditions or situations, and maintain measures to:

• Adequately identify and manage health, safety, security and environmental risks associated with its operations.
• All operations must be carried out in a way that minimise damage to the environment. CSS Business Partners are encouraged to develop and implement environmental standards in their operations.
• Emissions and protection of the environment must, at a minimum, be in accordance with applicable national rules, regulations, and requirements for the country in question.
• Conduct its business in its manufacturing and supply of Goods and/or Services with a minimum consumption of raw materials, energy and water, the fewest possible undesirable health, safety, and environmental effects.
• Comply with national and international environmental legislation and regulations.
• Not manufacture, use, or trade chemicals and hazardous substances subject to international bans.
• Hazardous chemicals, hazardous waste and other harmful substances shall be handled responsibly.
• Provide appropriate health, safety and environmental information and training for all its employees.
• Ensure that reasonable opportunities for improvement in these fields are identified and implemented.
• CSS encourage all suppliers and partners to become certified to ISO 14001 and ISO 45001 if not so already.

5          Audit Rights

CSS Business Partners compliance with this Code may be audited by or on behalf of CSS to identify gaps between the requirements of this Code of Conduct and the actual practices. If Business Partners does not comply or present unwillingness to take action to correct gaps, this may lead to reduced business and ultimately a termination of business relationships.

CSS Business Partners shall keep accurate books, records and accounts in connection with the services to be performed for – or products to be delivered to – CSS to verify implementation of and compliance with this Code of Conduct.

6          Communication of suspected violations

CSS Business Partners shall promptly notify CSS of any failure to comply with this Code of Conduct. The same applies in case of any illegal or criminal activity that may be suspected or identified, possibly impacting CSS business and/or reputation.

CSS Business Partners shall provide its employees with transparent, fair and confidential reporting procedures. This includes procedures which enable them to report to CSS any suspected violation of this Code of Conduct and encourage them to use the confidential (and – where local laws permit – anonymous) disclosure of information in good faith. Reports to CSS can be made by email or via CSS’ webpage.

7          Variation

The provisions of this Code of Conduct may be amended, supplemented or waived from time to time by CSS. Business Partners is expected to accept any modifications resulting from legal requirements or which may otherwise be reasonably required.

8          Quality

CSS Business Partners shall have a quality assurance (control) management system in place in order to ensure that products and/or services delivered to CSS shall be without defect and shall comply with applicable quality standards and regulations. Quality also means that the products and services are manufactured in a way that is environmentally and socially sustainable.

Document version: 2
Last updated: 03/04/2023