Responsible business conduct

Adhering to high standards in Responsible Business Conduct (“RBC”) within the Group’s businesses has positive impacts on results and makes Western Bulk competitively stronger in a sector where customers are increasingly driven by such factors when choosing their business partners.

Western Bulk’s Code of Conduct and related internal policies establish clear expectations for all parts of the Group’s business with regard to good corporate conduct and compliance with applicable laws and regulations. The Code of Conduct includes requirements and clearly communicates the Group’s expectations related to dealing with third parties and matters of integrity. 

Western Bulk has a compliance program that is aimed at addressing the risks relevant to the Group’s business. This program has explicit and visible support from senior management to emphasise the important role of compliance for the Group. 

Western Bulk has a whistle-blower policy and a reporting channel. Employees are expected and encouraged to report matters that may not comply with the principles set forth in the Code of Conduct or other policies. 

Western Bulk has a Supplier Code of Conduct which communicates our expectations to our external suppliers beyond the contractual obligations in individual contracts. The Supplier Code of Conduct establish clear expectations for all suppliers with regard to good corporate conduct and compliance with applicable laws and regulations.

Western Bulk has a Counterpart Risk team that evaluates new and existing third parties against several risk criteria. This process is risk based and the extent of the vetting process therefore varies with the special risk of each trade, including e.g. the industry or the region. The Group uses external databases and sources to improve the quality of the findings related to each third party. 

Western Bulk employees have a strong awareness of responsible business conduct related issues, in particular related to the handling of corruption and sanctions risks. The importance of this area has been highlighted by a top-down promotion of responsible business conduct and compliance matters from the CEO and the senior management team. 

The Western Bulk group’s commitments in the RBC sphere are:

Human Rights

Western Bulk shall support, respect and commit to the principles set out in UN’s Universal declaration on Human Rights and ensure that we are not complicit in human rights abuses.

Labour Rights

Non-Discrimination

Western Bulk’s policies prohibit unlawful discrimination on grounds of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, labour union affiliation, social or ethnic origin. 

Western Bulk treats all persons with dignity and respect. All employees support a work environment free from discrimination.

Compensation

Wages paid to employees and hired labour are considered fair and meet any national legal standards on minimum wage. Working hours are not excessive and as a minimum complies with applicable local laws or agreements.

Labour standards

Freedom of association and the right to collective bargaining and agreements are respected in all operations of the Group.

Safe working environment

All employees are provided with a safe and healthy work environment.

Seafarers

Owners of tonnage chartered by the Group are required to maintain standards for seafarers meeting at least those set by international standards and conventions. 

Environment

Western Bulk supports the maritime industry’s commitment to net zero emissions by 2050, and to a 50% reduction in emissions by 2030, compared to the 2008 baseline. As an operator, our contribution to this effort will largely come from operational measures such as performance monitoring, voyage optimisation and speed adjustments, as well as a structured approach to regular hull and propeller cleaning. In addition, it will be important to work with both vessel owners and customers to identify opportunities for increased co-operation. There is significant emission reduction potential in contractual structures that incentivise reduced carbon intensity through speed reduction, just-in-time-arrival, information-sharing and similar.

During 2023, we have invested significant resources to prepare ourselves for the introduction of shipping into the EU ETS from January 2024. We are set up to purchase and hold EUAs and EUA futures, and made our first EUA purchase in July 2023. We have also invested in systems and resources to manage the administrative complexities of EUA accounting and transfers towards vessel and cargo owners. EU ETS gives rise to new challenges and uncertainties for owners and clients, and with our expertise and set-up, we have the ability to help our partners in this respect.

Western Bulk monitors the carbon intensity of our operations primarily through EEOI. EEOI measures the relative relationship between CO2 emissions from bunker fuel consumption and transport work (tonne-nautical miles). This is represented as gCO2 / tonne-nautical miles. We measure per vessel segment as EEOI generally decreases with vessel size. Since the composition of our fleet varies from year to year, average EEOI per year will not only depend on carbon intensity of our operation, but also on the relative share of vessel types in the fleet. 

The table below portrays the development in EEOI per vessel size from 2022 to 2023. As a result of our focus on fleet performance, the EEOI for every vessel type but Panamax has been significantly reduced during 2023. In the Panamax vessel segment, congestion issues on the East Coast USA and challenging weather conditions entailed higher CO2 emissions compared to transport work.

Since testing biofuel deliveries and carbon offsets in 2021, the Group has made carbon offset an option for customers wishing to reduce the impact of cargo shipments. 

Competition

Western Bulk operates in a highly competitive industry. The Group competes in a fair and ethical manner in relation to competitors as well as to customers and suppliers. Western Bulk will under no circumstances cause or be part of any breach of general or special competition regulations or any other behaviour that is in breach of applicable competition (anti-trust) legislation.

Taxation

Western Bulk Chartering AS is domiciled in Norway and controls legal and operational entities in Norway, Singapore, the United States of America, the United Arab Emirates, Chile, Sweden, Denmark and Morocco. Western Bulk complies with tax laws, regulations and filing requirements in the jurisdictions where the Group is located. Western Bulk follows the arm’s length principle and complies with the recommendations set out in the OECD Transfer Pricing Guidelines for internal transactions between group companies.

For further details about Western Bulk’s taxation, please also refer to the explanatory notes in the Group’s financial statements.

Anti Corruption

Western Bulk conducts its business with integrity. All activities within the Group are done in compliance with all applicable laws and regulations. Our Code of Conduct prohibits engagement in corrupt or illegal practices directly or indirectly.

Western Bulk continues to participate in the Maritime Anti-Corruption Network (www.maritime-acn.org). Established in 2011, MACN is an industry group of over 130 industry participants including ship owners and operators, cargo owners and service providers working towards a vision of a maritime industry free of corruption. As part of MACN, Western Bulk supports the efforts of collective industry action to improve the compliance environment and integrity in the sector. 

In 2020 Western Bulk completed TRACE certification for Western Bulk Carriers AS and Western Bulk Lte Ltd. TRACE certification means that the companies have completed a comprehensive and internationally recognised due diligence process administered by TRACE, the world’s leading anti-bribery standard setting organization. The successful completion of TRACE certification demonstrates a commitment to commercial transparency.

Our operating companies Western Bulk Carriers AS and Western Bulk Pt Ltd have also completed Tcertification. Tcertification is a custom-built diligence review. Tcertified companies are pre-vetted business partners for multinational companies seeking to do business with suppliers, agents and consultants who share their commitment to commercial transparency.