Supplier Code of Conduct

1. INTRODUCTION

• 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 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 Counterpart Risk team that evaluates new and existing third parties against several commercial and RBC-related 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 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 RBC related issues including but not limited to issues of human and labour rights, environment, and anti-corruption. The importance of this area has been highlighted by a top-down promotion of RBC and compliance matters from the CEO and the senior management team including but not limited to company policies and training for all employees.
• This approach likewise extends to Western Bulk’s suppliers (“Suppliers”).
• Western Bulk’s Supplier Code of Conduct (the “Supplier Code of Conduct”) establishes clear expectations for all Suppliers to the Group business to manage their adverse impacts on human and labour rights, environment, and anti-corruption.

2. SUPPLIER CODE OF CONDUCT

• The Supplier Code of Conduct establish clear expectations for all Suppliers with regard to good corporate conduct and compliance with applicable laws and regulations. The Supplier Code of Conduct includes requirements and clearly communicates the Group’s expectations related to dealing with third parties and matters of integrity. Western Bulk expects all Suppliers to meet the expectations set out in the Supplier Code of Conduct. Failure to do so may impact Suppliers’ ability to do business with Western Bulk going forwards.
• The terms of the Supplier Code of Conduct apply to all Suppliers to the Group including parent, subsidiary or affiliate entities, as well as all others with whom they do business, including subcontractors and other third parties. It is the Suppliers’ responsibility to ensure processes to manage their adverse impacts on human and labour rights, environment and anti-corruption through their business relationships and operations.

3. EXPECTATIONS

• Western Bulk expects their Suppliers to fully collaborate in improving their systems of managing adverse impacts on human and labour rights, environment, and anti-corruption.
• Western Bulk expects their Suppliers to cooperate in answering questions, in relation to the Supplier Code of Conduct and the Suppliers’ practices, if and when required by Western Bulk.
• Western Bulk expects Suppliers to comply and make their best efforts to remain compliant with any applicable laws, regulations and international principles on human and labour rights, environment, and anti-corruption.
• Western Bulk expects Suppliers to meet these expectations in relation to the following human and labour rights, environment, and anti-corruption principles set out below.

4. HUMAN RIGHTS

• Western Bulk expects Suppliers to support, respect and commit to the principles set out in the UN’s Universal Declaration on Human Rights and to ensure that they are not complicit in human rights abuses, and to manage any adverse impacts on the rights stated in the International Bill of Human Rights which is together made up of the following.

     Universal Declaration of Human Rights

     International Covenant on Economic, Social and Cultural Rights | OHCHR

     International Covenant on Civil and Political Rights | OHCHR

5. LABOUR RIGHTS

• Western Bulk expects Suppliers to support, respect and commit to the principles set out in the ILO’s Declaration on Fundamental Principles and Rights at Work, and manage any adverse impacts on the labour rights.

    ILO’s Declaration on Fundamental Principles and Rights at Work

6. NON-DISCRIMINATION

• Western Bulk expects Suppliers’ policies to prohibit unlawful discrimination on grounds of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, labour union affiliation, social or ethnic origin.
• Suppliers should treat all persons with dignity and respect and support a work environment free from discrimination.

7. COMPENSATION

• Western Bulk expects Suppliers to ensure 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.

8. LABOUR STANDARDS

• Western Bulk expects Suppliers to respect freedom of association and the right to collective bargaining and agreements in all their operations.

9. SAFE WORKING ENVIRONMENT

• Western Bulk expects Suppliers to provide employees with a safe and healthy work environment.

10. SEAFARERS

• Where applicable, Suppliers are expected to maintain standards for seafarers, meeting at least those set by international standards and conventions including but not limited to the Maritime Labour Convention 2006 and the International Convention for the Safety of Life at Sea 1974

     The Maritime Labour Convention 2006

     International Convention for the Safety of Life at Sea 1974

11. ENVIRONMENT

• Western Bulk expects Suppliers to support industry initiatives aimed at making shipping more sustainable, reducing the environmental impact of maritime activities, and furthering the IMO 2030 and 2050 emission reduction targets.
• Western Bulk expects Suppliers to establish processes that cover all impacts on the external environment.
• Western Bulk expects Suppliers to, where applicable, continuously work to optimize their operations to minimize running costs and optimize fuel efficiency which in turn can help reduce overall emissions from their activities and prevent or mitigate potential accidents which may have an adverse environmental impact.
• Western Bulk expects Suppliers to minimise their impact on the environment and maintain awareness of the legislative requirements relevant to their activities.

12. ANTI-CORRUPTION

• Western Bulk conducts its business with integrity and expects Suppliers to do the same. All activities by Suppliers should be done in compliance with all applicable laws and regulations. The Supplier 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). In 2020 Western Bulk completed TRACE certification for Western Bulk Carriers AS and Western Bulk Pte 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.
• Suppliers should likewise establish adequate processes to counter corrupt practices. Such processes should support and be in line with the UN Convention against Corruption.

     UNITED NATIONS CONVENTION AGAINST CORRUPTION

13. COMPLIANCE

• The Supplier Code of Conduct sets out Western Bulk’s minimum expectations of Suppliers. Western Bulk expects Suppliers to adhere to the applicable laws in their areas of operation. Where national laws provide for differing protections, Western Bulk expects the higher standard to apply.
• Western Bulk understands that compliance is an ongoing process. Western Bulk expects Suppliers to endeavour to comply with the principles set out in the Supplier Code of Conduct, and encourage the practices envisaged. For example, through the publication of policy statements and continuous due diligence as to any adverse impact from Suppliers’ operations and activities in relation to these issues.
• If Suppliers discover potential or actual adverse impact in relation to human and labour rights, environment and anti-corruption has taken place, Suppliers should take the necessary and legitimate steps to rectify the adverse impact.
• Where Suppliers did not directly cause nor contribute to an adverse impact, but are linked through the supply chain, Western Bulk expects Suppliers to use their best efforts through leverage and action to make the relevant entity take the necessary and legitimate steps to rectify the adverse impact.