Policies and statements

Our commitment

Sustainability pledge from the Board

The Board of Directors of Stolt-Nielsen Limited recognises that how we conduct business impacts our industry, our people, our external stakeholders, and the environment. The Board therefore commit to make sustainability a key part of our business strategy and day to day operations. This will include the formulation and communication of targets for the reduction in GHG emissions, safety improvements and employee welfare. We further acknowledge that climate change risk poses possible risk for all businesses, and we therefore ensure that the businesses build risk mitigation approaches into their business strategy.

As a signatory to the UN Global Compact, we are committed to continue to align our business approach with all the principles which govern the UNGC and ensure that these are well embedded within the businesses of Stolt-Nielsen. The businesses are developing metrics and goals which will ensure that we continue to make good progress in reducing our environmental footprint in line with the objectives of the UNGC and Sustainability Development Goals which follow from there.

The Board is committed to Stolt-Nielsen embedding these principles together with well-implemented quality management systems, which are critical to providing safe and efficient operations.

The Board pledges its commitment to sustainability at Stolt-Nielsen Limited.

Code of Conduct

Stolt-Nielsen requires that its business objectives are achieved in an ethical, honest and legal manner as outlined in its Code of Conduct (the Code).

The Code 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 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 awareness and visibility of the Code, and to underscore Stolt-Nielsen’s commitment to it, we also:

●Display poster-sized copies of the Code prominently at all of our locations, these are translated into local languages as needed.

●Require all land-based management to complete an annual online Code compliance confirmation.

●Require all main agents of the Company to confirm compliance with the Code periodically.

●Require all joint-venture Boards to confirm compliance with the Code annually.

To promote a culture where employees feel comfortable about raising concerns about potential, suspected or actual breaches of the Code without fear of victimisation, discrimination or disadvantage, Stolt-Nielsen maintains a whistleblower policy and an online ‘Speak Up!’ 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.

Equal opportunities

Stolt-Nielsen is an equal opportunity employer. We promote a diverse, inclusive and safe environment. In line with our Equal Opportunities Policy, we recruit, train and develop employees who are best-suited to the requirements of the job regardless of gender, ethnic origin, age, religion or belief, marriage or civil partnership, pregnancy or maternity, sexual orientation, gender identity or disability. Our commitment to building a diverse and inclusive workforce at all levels of the organisation is based on creating fairness and parity.

Fair treatment and welfare of seafarers

Stolt Tanker’s commitment to the fair treatment and welfare of its seafarers is supported by compliance with mandated standards from several international agreements, conventions and processes. We also provide our seafarers with benefits, resources and support that make service aboard our ships both attractive and valued by our officers and crew. These include:

• medical insurance for all first-degree family members

• exercise equipment or gyms on all ships

• daily internet access for all seafarers

• engagement and development of outstanding cadets for life-long careers at Stolt-Nielsen

• career counselling, guidance and management, emphasising continuous employment to ensure high levels of expertise

• state-of-the-art and focused safety and operational training programmes

• empowerment of Ship Management Teams (SMTs) to drive pride of ownership.

Stolt Tankers’ ships operate with valid International Transport Workers’ Federation Union (ITF) agreements (collective bargaining agreements) for all seafarers onboard. We also operate in conformance with the Seafarers’ Bill of Rights of the Maritime Labour Convention (MLC), the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), the International Convention for the Safety of Life at Sea (SOLAS), and the International Convention for the Prevention of Pollution from Ships (MARPOL). Compliance is verified through Port State Control and Flag State Inspections.

Human rights

We support the principles set out in the UN Universal Declaration of Human Rights, the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and the International Labour Organization Core Conventions. Stolt Tankers is also a member of IMPA ACT, supporting its Code of Conduct relating to labour and human rights.

These commitments extend across the supply chain. Many of the countries we operate in have high risks of human rights, environmental or business ethics abuses. We closely monitor these areas across supply chain partners.

When we recycle our ships, we only select those yards which operate in accordance with the International Maritime Organization’s (IMO’s) 2009 Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships. During recycling, Stolt Tankers maintains one to three surveyors onsite at the yard, to monitor the process first-hand from start to finish. This ensures that workers’ conditions are checked and validated throughout.

Compliance at Sea

Stolt Tankers’ ships operate with valid International Transport Workers’ Federation Union (ITF) agreements (collective bargaining agreements) for all seafarers onboard. We also adhere to the Maritime Labour Convention (MLC) Seafarers’ Bill of Rights; the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW); the International Convention for the Safety of Life at Sea (SOLAS); and the International Convention for the Prevention of Pollution from Ships (MARPOL). Port State Control and Flag State Inspections verify our compliance with these conventions.

We document MLC compliance within our Ship Management System, with additional vetting conducted during routine onboard inspections. This vetting is carried out as part of the Oil Companies International Marine Forum/Chemical Distribution Institute (OCIMF/CDI) Tanker Management and Self-Assessment process and through periodic International Safety Management (ISM) audits. DNV GL, the world’s largest ship classification society, carries out these audits on behalf of the Flag States.