Stolt-Nielsen requires that its business objectives are achieved in an ethical, honest and legal manner.
To enforce this, a Code of Business Conduct is maintained, which is reviewed and approved by the Board annually. The Company does not tolerate any breach of the Code and individuals found to be in breach are subject to disciplinary action, up to and including termination of employment. The Code sets out the business conduct principles and rules that apply to all directors, ofﬁcers, permanent employees, temporary employees, contractors and consultants.
In summary, the Code requires all personnel to comply with all relevant laws, regulations and Company policies at all times and to behave with integrity, maintaining internal and external relationships in a professional manner, avoiding conﬂicts of interest, bribery and corruption.
To ensure constant awareness and visibility of the Code, and to underscore Stolt-Nielsen’s commitment to it, we also undertake the following:
- Poster-sized copies of the Code are prominently displayed at all of our locations worldwide, and translated into local languages as needed.
- All land-based management must complete an online Code compliance conﬁrmation annually.
- All main agents of the Company are required to conﬁrm compliance with the Code periodically.
- All joint-venture boards are required to conﬁrm compliance annually.
In addition, to promote a culture in which employees feel comfortable about raising genuine concerns about potential, suspected or actual breaches of the Code without fear of victimisation, discrimination or disadvantage, Stolt-Nielsen has for many years maintained a whistleblower policy and an online system that enables anyone, internal or external, to report conﬁdentially (anonymous or otherwise) directly to the Chairman of the Audit Committee and our Head of Operational Audit. All reports are taken seriously and investigated appropriately.