1 FJELD CONSULTANT - BUSINESS PHILOSOPHY AND ETHICAL  PRINCIPLES

1.1 Company Profile

Fjeld Consultant is an internationally renowned transport and logistics group with headquarters in Bergen, Norway. We handle a wide range of goods within the bulk, breakbulk and project  industry.

Since the beginning, Fjeld Consultant has built a comprehensive international network through partnership and collaboration with some of the industry's most respected and professional actors.

Fjeld Consultant's business philosophy evolves around quality and flexibility.

Fjeld Consultant's ambition is to become a strategic and preferred logistics partner for our customers by establishing itself as the foremost player in the global logistics solutions market.

The key to Fjeld Consultant's success is the ability to develop innovative services and logistics concepts based on high expertise and advanced information technology.

1.2 Value of principles

Fjeld Consultant conduct themselves to the following value of principles:

  • Safety/confidence
  • Problem solver
  • Flexibility
  • Speed
  • Information
  • Accessible
  • Innovative
  • Not only price

1.3 Commitments

Fjeld Consultant aims to establish a standard of ethics and integrity, in accordance with the law. Fjeld Consultant's own program for compliance with legal requirements and code of conduct are implemented completely internally and externally.

All employees, agents, vendors, and public authorities involved in our operations are required to abide by applicable laws and regulations, and execute their duties in compliance with the standards set out in these documents, thereby helping to safeguard our reputation and reduce risk to both the company and individual.

1.4 Principles

  • Fjeld Consultant aims to maintain a high ethical standard and is reliable and committed to the company’s goals and visions.
  • Fjeld Consultant places unequivocal demands on the honesty and the integrity in relation to activities carried out on behalf of the company.
  • Fjeld Consultant focus on security in all activities and will never compromise on security regarding  employees, clients and agents.
  • Fjeld Consultant aims to maintain responsibility, ethical and healthy commercial activities throughout the group. This includes strict requirements on us, our impact on the environment and what is expected from the society in general.
  • Fjeld Consultant is an informal organization based on respect for each other, openness and involvement. Fjeld Consultant aim for a culture supporting our empolyees growth and working conditions.
  • Fjeld Consultant aims for equality and diversity in its organization. Discrimination and harassment is not tolerated.
  • Fjeld Consultant insists on integrity, honesty and fairness in all aspects of our local and global business, and we seek the same from those with whom we do regular business, directly and indirectly.
  • Fjeld Consultant strive to be an attractive, trustworthy and long-term partner.

1.5 Corruption and facilitation payments

Corruption is to bribe or receive bribes, in the form of money, gifts or services, in order for a person in power to give another person benefits beyond the rules. Corruption occurs when a person in a trusted position or office, privately or publicly, puts the responsibility and obligations attached to the position aside and abuse the power in the post or office and thereby achieves either a private benefit or reward, or improperly strives for an advantage to your own organization or company. This is the definition of corruption laid down by the Confederation of Norwegian Enterprise (NHO).

Fjeld Consultant recognize the value of networking is an important part of our activities, and our ethical standards are established to draw the lines between constructive working and bribery / corruption.

Facilitation payments refer to relatively small payments or rewards made in order to expedite, or ensure the provision of services that would, or should, in any case be provided in the normal course of events.  There is a very thin line between what may be a “facilitation payment” and what may be a bribe, and great care must be taken in deciding whether or not such payment is legal, necessary and justifiable.

Fjeld Consultant is against making these payments, and expressly forbids them if they are illegal.

Fjeld Consultant will work to reduce and ultimately eliminate these forms for payments. Any employee who is uncertain and feeling that they are on the borderline, shall avoid such payments. If in doubt, the nearest manager shall be contacted to make sure that the Fjeld Consultant's ethical guidelines are in place.

1.6 Gifts

The value of gifts shall be within the limits set under relevant tax rules. In some cases it will be appropriate to accept larger gifts / prizes, but only on behalf of the company. Gifts of significant value shall be handed over to the company at the first opportunity. Openness is important, and gifts / prizes / dinners offered or given, have to be formally reported to the management of the respective company.

Bribes are treated as a deliberate attempt to put the organization or an individual in a situation where the individual / persons have no choice, and where reciprocal benefits are demanded. It is not allowed to accept bribes. No kind of bonus or gift that can be interpreted as a bribe may be accepted or offered.

1.7 Human Rights

Fjeld Consultant:

Oppose all forms of modern slavery, forced labor and child labor abuse.

Uphold freedom from discrimination and harassment, including but not limited to gender, race, color, religion, political views, union affiliation, ethnic background, disability, sexual orientation or marital status.

Uphold the principles of freedom of association and collective bargaining, including respect for each employee’s right to make an informed decision, free of coercion, about membership in associations or labor unions.

Uphold decent working conditions at a minimum according to applicable laws and industry standards, including for working hours, terms of employment, leave of absence and compensation.

We aim to uphold wages and benefits to cover basic needs and some discretionary income, as well as a family-friendly workplace. Uphold the right to health and safety for our employees and suppliers’ employees, at a minimum according to applicable legal workplace safety and industrial hygiene standards, and for communities, including environmental, climate and security impacts relating to human rights.

Uphold the right to privacy of those who entrust us with their personal information.

Will be attentive to the rights of vulnerable individuals and groups. These include:

  • Indigenous and tribal peoples, as well as traditional communities, and their rights to self-determination, to lands which they traditionally occupy, to their customs, traditions and institutions, and to their free, prior and informed consent (FPIC).
  • Women
  • Children and young people
  • Migrant workers
  • Minorities
  • Human rights, worker rights and environment defenders and their rights to freedom of expression, association, and peaceful assembly and protest against our business and operations.

Have zero harm to personnel and to the environment  as our main focus. Peak Group, mother company of Fjeld Consultant, will only order vessels with zero emission technology from 2030. Peak Group will have a climate neutral fleet from 2050.

Have zero tolerance of corruption within our organization or conducted by our partners, suppliers or others conducting business on our behalf.

1.8 Relation with business partners

Fjeld Consultant expects the same commitment to legal and ethical conduct of subcontractors as Fjeld Consultant requires from its board members, managers and employees.

A part of this compliance program includes evaluation and assessment our regular suppliers / agents with respect to compliance. This “due diligence process” requires specific information about our subcontractors, and the subcontractors may be asked to reply on questions regarding ethical guidelines as a part of this data collection.

2 GUIDELINES FOR BRIBERY AND CORRUPTION

Fjeld Consultant is committed to comply with laws designed to combat bribery of officials and corruption. As part its contractual commitment to our clients, Fjeld Consultant introduces the following policies and procedures to govern all aspects of work or services.

2.1 What are bribery and corruption?

Corruption (derived from corrupting, Latin corrumpere) is to bribe or receive bribes, in the form of money, gifts or services, in order for a person in a power to give another person benefits beyond the rules. Corruption occurs when a person in a trusted position or office, privately or publicly, puts the responsibility and obligations attached to the post or aside and abuse the power in the post or office and thereby achieves either a private benefit or reward, or improperly strives for an advantage to own organization or company. This is the definition of corruption laid down by Confederation of Norwegian Enterprise (NHO).

2.2 Basic conduct

Fjeld Consultant and/or their owners, directors, board members and employees are subject to local and international laws and regulations that forbid and punish bribery and corruption, and all Fjeld Consultant employees are expected to comply with all applicable laws and guidelines.

Any Fjeld Consultant employee who violate any applicable laws or this policy will immediately be reported to the respective management, which comes to an appropriate discipline, which may also include termination.

2.3 No improper payments

Owners, directors, officers, employees and any other parties acting for or on behalf of Fjeld Consultant will not support any offering, paying, promising or authorizing any bribe, or other thing of value to any government official, government employee, customer, or business associate, directly or indirectly through a third party, to secure any contract, concession or other favorable treatment for Fjeld Consultant or our clients. Any such action may be considered to be a bribe and may result in violation of applicable law.

Accordingly, Fjeld Consultant personnel shall comply to the Company's policies on the provision of and reimbursement for gifts, representation, meals and travel expenses, and with the Company's relevant provisions on accounting and retention of documents to ensure that such expenses are properly documented.

2.4 Who is a government official?

Laws prohibiting the bribery of "officials" typically define "official” broadly to include any appointed, elected, or honorary official or any career employee of a government, of a government owned or controlled company or enterprise, or of a public international organization, or any person acting in any official capacity. The definition encompasses officials in all branches of government: executive, legislative and judicial. It also includes political parties, party officials and candidates for political office.

2.5 Gifts, representation, meals and travel expenses

Fjeld Consultant employees shall not give inducements, including gifts, representation, meals or travel expenses, to holders of public offices, customers or business associates on a scale that might be perceived as creating an unreasonable obligation on that recipient or that violates any applicable law or government policy against bribery or corruption.

Gifts, representations, meals or coverage of travel expenses provided to holders of public offices, customers or business associates must be approved by the respective manager after review for compliance with applicable laws value. When considering the reasonableness of the expense, Fjeld Consultant employees should consider the frequency with which such expenses are incurred for a particular recipient (such as regular gifts or dinners). Modest costs may amount to lavish and potentially improper payments when aggregated.

  • Must not be greater in amount than the legitimate and customary expenditure for such activities and not exceed the normal business practice in the country, and must not fund improper entertainment activities.
  • Must be connected to a legitimate business promotional activity or the performance of an existing contract, permitted under local law, and otherwise consistent with company business practices.
  • Must comply with all applicable laws and tax regulations, including any applicable code of conductor or rules governing the receipt of benefits by government officials.
  • Must be entered accurately in the accounting book and records of the Fjeld Consultant.

2.6 Engagement of third parties

Companies can be held liable for payment made by a third party, such as a sales representative, subcontractor, consultant, agent or partner, of anything of value to a holder of a public office, even if the third party is not subject to the law and even if the company actually do not know of the payment. Company personnel may be liable if they give, pay, promise or authorize such payment when the company knows or willfully ignorant of the risk that the amount paid will be used in whole or in part for payment to a public official. To protect Fjeld Consultant and any company that Fjeld Consultant offers shipments or services, from this risk, Fjeld Consultant employees must screen diligently monitor contractual or investment relationships with any third parties with who Fjeld Consultant is doing business.

When a third party is engaged, the Fjeld Consultant must ensure that:

  • The third party engaged only for bona fide and legitimate purposes and services.
  • Adequate due diligence regarding the third party’s reputation, ethics and qualifications is completed before a regular business relationship is established.
  • Any "red flag" indicating a risk that the third party might make improper payment or otherwise violate applicable laws are addressed both before and during the engagement.
  • Third party confirms Fjeld Consultant’s code of conduct.  
  • Third party is aware of and commits to avoid conflicts of interest.
  • Any compensation paid to a third party is appropriate and justifiable remuneration for the legitimate service rendered.
  • Third party is adequately monitored during its provision of services, and any unusual charges by third party that could conceal improper benefits to government officials or other improper recipients are queried.

Common "red flags" that may indicate potential corruption include:

  • Payment to shell companies
  • Payment to offshore bank accounts
  • «Donations» to individuals
  • Cash transactions
  • Doing business with people or entities that are known to engage in bribery or who are suspected of engaging in bribery.

If Fjeld Consultant personnel become aware of any of these situations or others that suggest the possibility of improper payments, they should report to their manager for compliance with legal requirements at Fjeld Consultant.

2.7 Political and charitable contribution

All contributions by Fjeld Consultant to political campaigns or organizations or to charitable organizations:

  • Must be approved by the top manager of the respective company
  • Must comply with all applicable laws and policies in Norway
  • Must not use company funds made in the name of individuals
  • Must not be in return for any improper official action by any government official
  • Must be properly recorded in the company’s books and records.

2.8. Documents and internal audits

Fjeld Consultant shall make and keep reasonably detailed books, records, and accounts that confirm with prevailing  professional  standards of accounting and that in reasonable detail reflects all transactions, including all expenditures, invoices, expense reports, receipts,  disbursements, vouchers, and other disposition of monies or assets, all in according with Norwegian accounting rules.

Records of gifts, entertainment, meals and travel expenses shall include expense dates, the names and business association of all in attendance, and the reason for the expenditure. Valid and detailed third party receipts or invoices will support all records of such payments and expenses.

Fjeld Consultant will maintain a system of internal controls sufficient to reflect with reasonable accuracy of all transactions  and the disposition of Fjeld Consultant assets. Relevant personnel shall be trained in the operation of such controls. The internal controls will be sufficient to provide reasonable assurance that:

Transactions are executed in accordance with management’s specific or general authorizations. Access to assets is permitted in accordance with management’s specific or general authorizations.

3 ANTI-MONEY LAUDERING AND ANTI-TERRORISM  LAWS AND REGULATIONS

Fjeld Consultant personnel must comply with all applicable anti-money laundering and anti-terrorism laws and regulations. Fjeld Consultant personnel shall not engage in financial transactions that, directly or indirectly, promotes or result from any criminal activity prohibited by the laws in any country.

Fjeld Consultant personnel and suppliers of Fjeld Consultant should be alert to the money flow in every transaction and to question any payment methodology outside the norm. Such transactions should be screened for any of the following red flags:

  • Purchases inappropriate to a counterpart’s business.
  • Large cash transactions
  • Large volumes of wire transfers to and from offshore banks/businesses, especially when there is no connection to a counterpart’s business is obvious.
  • Loans secured by obligations to offshore banks
  • Counterparts is reluctant to provide adequate identification information
  • Businesses whose financial statements are inconsistent with similar businesses and (especially for large businesses) whose financial statements are not prepared by an auditor.
  • Transactions that appear to be structured to evade reporting requirements (for example, a series of transactions below 10,000 USD).

Fjeld Consultant personnel shall not engage in or support any transactions, or otherwise facilitate, any activities by any terrorist person, activity, organization.

4 COMPLIANCE WITH ECONOMIC SANCTIONS

Fjeld Consultant shall comply with all applicable laws imposing economic and trade sanctions against certain countries designated nationals.

Fjeld Consultant shall consult with any business partner regarding assistance with compliance of all economic sanctions laws applicable to such business partner.

5 COMPLIANCE WITH APPLICABLE ANTI-BOYCOTT LAWS

Fjeld Consultant shall comply with all applicable laws with regard country boycotts.

Fjeld Consultant shall consult with any business partner regarding assistance with compliance of all anti-boycott laws applicable to such business partner.

6 COMPLIANCE WITH EXPORT CONTROL LAWS AND REGULATIONS

Fjeld Consultant shall comply with all applicable laws regarding controls over the exports of goods and services, including applicable laws and regulations covering re-exports.

Fjeld Consultant shall consult with any business partner regarding assistance with compliance of all export control laws comply with and regulations applicable to such business partner.

Fjeld Consultant's ethical code of conduct is intended to foster a search for continuous improvements in all aspects of our performance. It will therefore be reviewed annually and will be referred to in Fjeld Consultant’s annual report and published on our website as part of our ongoing improvement program. Fjeld Consultant's ethical code of conduct is communicated to colleagues and collaboration partners.

Fjeld Consultant intend to maintain a focus on ethics when evaluating existing and potential collaboration partners.