ABOUT THE THORCO PROJECTS CODE OF CONDUCT It is the policy of the company to conduct our business in accordance with all applicable laws and regulations in a ethically responsible manner. The Code of Conduct applies to all our staff and enables the Company to continue to operate ethically, honestly and to comply with the law as applicable. The Code of Conduct sets out minimum required standards and it is a line management responsibility to communicate and implement the Code of Conduct as associated with the Thorco Projects Policies. This does not remove individuals responsibility to inform themselves of the appropriate requirements. Links to further information and other documents can be found in this document. What happens if the law in the country where we operate is different from the Code of Conduct – if local laws sets higher standards than the Code of Conduct then the local law shall be followed. However if local law sets a lower standard, the Code of Conduct`s higher standards applies. In particular the Company requires compliance with the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Does the Code of Conduct apply to the group`s business partners – The Company expects its business partners, including clients, suppliers and business partners (joint venture), directors, managers, officers and employees to comply with the Code of Conduct or an equivalent Code of Conduct. Compliance with the Code of Conduct – If you believe there may have been a violation of the Code of Conduct and you do not feel comfortable in approaching your line manager or other members of the Company, then you may make a confidential report via the Company`s Safety System (IQSMS). The IQSMS system for confidential reporting is available 24 hours a day, 7 days a week. Anyone who violates the Code of Conduct associated policies or applicable laws – whether knowingly or not, could be subject to personal legal liability and disciplinary action(s). If you have any questions or want to find out more information regarding the Code of Conduct or Company policies you can contact our Global HSEQ Manager or a member of the Legal Department. Health, Safety, Security, Quality and Environmental (HSSEQ) – Protection of Health, security and safety and the prevention of pollution to the environment are primary goals of the Company. Safety starts with you and me. All of our people must conduct their duties and responsibilities in the compliance with the Company`s HSEQ Policy Statement available from the Company Management System, applicable law(s) and industry standards relating to health, security and safety in the workplace and prevention of pollution to the environment. WWW.THORCOPROJECTS.COM PAGE 4 OF 9
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