This document describes what is expected of directors, officers and employees of Seaborn and hired consultants acting on ehalf of Seaborn. Seaborn also includes all subsidiaries. 

Our relationship with the outside world 

  1. We act in a way that ensures Seaborn's neutrality, credibility and integrity 
    It is important for Seaborn that the general public have confidence in us and that our reputation is outstanding. All of our board members, directors, employees and contractors are responsible for contributing to this. 
  2. We comply with laws and regulations 
    We comply with prevailing laws, rules and standards, although it can entail additional costs or delays. It is a personal responsibility to ensure compliance with standards and restrictions set out in legislation. 
  3. We respect and care for environmental and climate considerations   
    Seaborn is an environmentally responsible company. We protect the climate and environment in all our decisions and strive to minimize our own environmental emissions. 
  4. We show deep respect for the UN's human rights and labor rights
    Seaborn respect the UN Declaration of Human Rights and avoids involvement in violations of these. Seaborn ensure workers' rights, including employees' freedom of association and right to collective bargaining, the removal of child labor and the prohibition of discrimination in employment and occupation appointments. Seaborn base their activities on the International Labour Organization’s core conventions and recommendations. We share a responsibility for Seaborn's compliance with these requirements. 
  5. We provide accurate information to our customers, suppliers and partners 
    Information that is sensitive to competition is confidential and shall be handled in accordance with our rules for dealing with such information. We all have a personal responsibility to follow Seaborn's provisions related thereto. 
  6. We communicate clearly and correctly 
    Seaborn communicate openly and precise with all stakeholders and ensure that important information is given at the right time. Communication with the media and the public is in accordance with Seaborn's guidelines and in accordance with applicable authorizations. 

Our approach 

  1. We make our decisions based on professional insight at the right organizational level 
    We make decisions based on professional assessments and thorough analyzes of facts. Any decision is made at the appropriate level of the organization and in accordance with the authority structure in Seaborn. 
  2. We put Seaborn's interests first 
    Seaborn respects the individual employee's right to privacy and private interests, and demands openness and loyalty in relation to Seaborn's interests. We do not put ourselves in a position where we can get in a conflict of interest with Seaborn. We do not use confidential information for personal gain. We clarify directorships and ownership interests in customers, suppliers, stakeholders in the seafood industry and partners with our superiors. We shall not hold positions or holdings where the loyalty of Seaborn might be doubted, or which may put Seaborn's reputation or credibility into question. If partiality occurs, it is our duty to warn the involved parties about the condition. 
  3. We respect that information is confidential 
    Knowledge you have received while you have been working for Seaborn about customers, employees, suppliers or business partners are subject to confidentiality. This includes information about commercial operation, safety issues, personal information and matters of internal and / or confidential nature. The duty of confidentiality applies both internally and in relation to colleagues who do not need the information in their work. We do not provide confidential information to third parties without the written consent of the protected party, or where this is permitted by law or regulation. Professional secrecy is not an obstacle for notification of unacceptable conditions. 
  4. We manage information and IT systems in a responsible manner 
    Seaborn collects, processes and uses information, IT systems and internet services in a responsible and professional manner. Electronic data stored in Seaborn's IT systems is the Group's property, and we accept that Seaborn is entitled to read the electronic information stored on all Seaborn's IT systems. 
  5. We have good internal control of accounting information and quality processes 
    We ensure internal control in the processes we are involved in by implementing control measures according to documented policies.
  6. We protect Seaborn's assets 
    Seaborn's assets are safeguarded and protected in an appropriate manner. We do not use Seaborn's assets for personal purposes unless this is clarified in the employment relationship or is a result of Seaborn's rules and guidelines. 
  7. We have zero tolerance for corruption, bribery and money laundering 
    Seaborn is actively working to combat corruption. This means that we do not offer or receive monetary or other economic benefits for the purpose of obtaining personal or business advantages for ourselves or others. In Seaborn we are cautious about the use of agents and brokers. In Seaborn we reject all forms of money laundering. We ensure that Seaborn's financial transactions are not being used by others to launder money. 
  8. We are cautious with gifts and other benefits 
    We are conservative about receiving or giving gifts or courtesies. We do not accept gifts or other forms of remuneration if there is reason to believe that the purpose is to influence business decisions. Gifts or benefits with a value below the equivalent of NOK 1000 is normally acceptable. Gifts with a value of more than the equivalent of NOK 1000 shall nonetheless be reported and recorded, even though it is considered that it does not affect business decisions. Travel cost and accommodation shall always be paid by Seaborn, and we always confer with our immediate superiors when we are uncertain about gifts and benefits. 


Our working environment 

  1. We take health, safety and environmental concerns seriously 
    Seaborn is a safe workplace. HSE is ensured through preventive measures and effective internal controls. Seaborn endeavors to meet national and international standards for health, safety and environment. We are all responsible for contributing to achieve these objectives. 
  2. We promote equality and diversity 
    Seaborn is a company that is characterized by respect and equal opportunities for all through a professional, positive and inclusive work environment. Seaborn stimulates all employees, regardless of gender, nationality, religion, disability, sexual orientation, age or political standpoint, to professional and personal growth, responsibility and utilization of their own resources. We are all responsible for contributing to the prevent discrimination or sexual harassment by colleagues to take place in Seaborn. 
  3. We have a drug‐free work environment 
    We have a drug‐free work environment. We do not tolerate that our colleagues are intoxicated at work.
  4. We refrain from buying sexual services 
    We have zero tolerance for any kind of purchasing of sexual services on business travels or assignments, or when you are working for or representing Seaborn. 
  5. We have the right and duty to speak up about misconduct in Seaborn 
    Seaborn encourage everyone to report any activity or situation that are not in compliance with our Code of Conduct. Notification should be made to the immediate supervisor, alternatively to human resources manager. Management shall protect the person reporting misconduct, and take active initiative to sort out and stop any unacceptable behavior.