Prosafe Production's good reputation creates trust and represents an important competitive advantage. Our shareholders, customers, employees and other stakeholders can be confident that we will maintain the highest ethical standards at all times, fulfil our obligations and behave with full integrity.
Given the global presence of the company and the diversity of backgrounds of our employees, it is not always easy to ensure a uniform standard of behaviour. Therefore, we have adopted a code of conduct which must be observed by all employees at all times. This code is the cornerstone of our commitment to integrity. It provides guidance to our actions and decisions, and reflects the mindset and behaviour expected in our company.
We aim to reach our targets in an ethical manner. We have zero tolerance for corruption and bribery in relation to our business activities, and expect the same conduct from our partners.
The implementation of our code of conduct must be given the highest priority. The code is obligatory, without exception. The presidents of the business units are responsible for making these guidelines known and for promoting and monitoring compliance.
Our reputation, and therefore our future as a company, depends on each of us taking responsibility for the conduct of Prosafe Production's business. By adhering to our code of conduct, we will be able to achieve business excellence, for the benefit of our shareholders, customers, and of course, all of us in Prosafe Production.
- Respect for human rights
The Group operates globally and has employees from many nationalities. We will show respect for all individuals, ensure that our activities are conducted in accordance with basic human rights standards, and require our suppliers and business partners to do the same.
We do not accept any form of discrimination on the basis of gender, religion, race, national or ethnic origin, cultural background, disability, sexual orientation, age or political opinion. We will also ensure that child labour or forced labour does not occur in the Group or in the operations of our suppliers and other business partners.
In addition, basic employee rights such as the entitlement to collective bargaining, to receive minimum wage, and to have regulated working hours are given high priority.
- Conflicts of interest
Our employees must avoid entering into any situation in which their personal or financial interests may conflict with those of the Company. Any conflict of interest must be flagged.
No employee must seek or accept any payment, personal gift or entertainment which might reasonably be believed to influence business transactions or which are not within the bounds of customary business hospitality.
We expect from all employees a sound level of allegiance to the company. This includes adherence to a non-competition policy by persons possessing significant confidential information.
- Confidentiality and protection of assets
Trade secrets and other proprietary information about the company, its business activities, technology, other intellectual property, financial position or personnel, as well as information about our customers, suppliers and partners, must be treated as confidential. Such information may not be disclosed to persons outside the company or to employees without proper authority. The obligation to preserve confidential information continues after employment ends.
- Insider trading
Prosafe Production Public Limited, as a public company, has entered into agreements regarding disclosure of information with the stock exchange on which its shares are listed. Prosafe Production Public Limited has set mandatory policies on trading for insiders. Prosafe Production Public Limited also has strict routines for the dissemination of information that may influence the market valuation of our securities.
- Bribery, corruption, antitrust
No group company or employee may offer or provide undue monetary or other advantage to any person or persons, including public officials or customer employees, in violation of laws and the officials' or employees' legal duties, in order to obtain or retain business.
Agreements with consultants, brokers, sponsors, agents or other intermediaries must not be used to channel payments to any person or persons, including public officials or customer employees and thereby circumvent our policies regarding bribery and corruption.
Contributions to political parties or committees, or to individual politicians, should not be given.
We are committed to fair and open competition in markets around the world. Group companies and employees must under no circumstances engage in any anti-competitive practices such as illegal fixing of prices, sharing of markets or other actions which prevent, restrict or distort competition in violation of applicable antitrust laws.
- Use of IT systems
Use of company owned network and computer systems must be for company business purposes only, and be limited to personnel especially authorised by the company. All use shall be in accordance with legislation and our procedures and codes of conduct.
Company sensitive data and information shall be treated in a secure and confidential manner. User access codes and passwords shall always be kept secret.
Information, data and programmes produced are to be considered company property and must be treated accordingly.
- Practice and follow-up
We will ensure that the code of conduct is made known to all our employees.
The code of conduct will be attached to all employment contracts and consultancy and agency agreements.
Responsibility for following the code of conduct is distributed as follows:
1. Personal responsibility
Every employee (staff or contracted) is responsible for ensuring that he/she is familiar with and performs his/hers duties in accordance with the Company's code of conduct, and relevant laws and regulations.
2. Managerial responsibility
Managers are responsible for communicating the code of conduct and for providing advice with respect to the interpretation and application of the code of conduct. They must ensure that activities within their area of responsibility are carried out in accordance with the requirements set in the code of conduct.
3. Handling cases of doubt and non-conformances
If any individual is in doubt, or comes across breaches of our code of conduct, these concerns must be reported immediately to his/her supervisor, or the next level up.
If the individual feels that the matter cannot be discussed with the line management, the concern must be reported to the ethics committee.
Concerns about possible breaches of code of conduct can be reported to the ethics committee by:
- sending an e-mail to: conduct@prosafeproduction.com
- sending a letter to Prosafe Production Public Limited (mark the envelope with "Ethics committee")
All reports will be treated with confidentiality and the individual may remain anonymous.
4. Ethics committee
Prosafe Production Public Limited has established a corporate ethics committee which shall maintain and further develop the code of conduct.
The corporate ethics committee has the following composition:
- President and CEO
- Exec. VP & CFO
- Exec. VP & COO
The corporate ethics committee will also give recommendations and advice on dealing with ethical dilemmas, and ensure that alleged breaches are investigated thoroughly and fairly.
