Supplier Code of Conduct

Approved by Marinetek Group Oy’s Board of Directors on December 21, 2023

1. Intention and Scope

The intention of this Supplier Code of Conduct is to establish basic principles and ethical standards of business behaviour through the implementation of the same responsible operating principles throughout the supply chain of Marinetek and to help Marinetek create long-term cooperative relationships with the suppliers to share the same values and responsible operating methods.

Marinetek refers to Marinetek Group Oy acting as a parent company of Marinetek Group, and its subsidiary companies or participating interest companies, where Marinetek Group Oy’s ownership is at least 25% either directly or indirectly.

High ethics is one of Marinetek’s core values and Marinetek’s Code of Conduct and are also reflected in this Supplier Code of Conduct.

This Supplier Code of Conduct is therefore made available to our suppliers with the goal of strengthening our mutual understanding of how sustainability should be practiced in day-to-day business.

A supplier, in this context, can be defined as any entity providing Marinetek with any material, equipment, goods, commodities and/or services.

Marinetek expects all its suppliers and sub-suppliers to share the principles which are expressed in this Supplier Code of Conduct and that comprise an important component of supplier selection and evaluation. Moreover, we expect our suppliers to replicate these standards further down the supply chain.

Suppliers are expected to self-monitor their compliance with this code. Furthermore, Suppliers should ensure the compliance of their own subcontractors and must notify us in a timely manner of any noncompliance.

2. Ethical Business Conduct

The Supplier shall ensure good business practices in all its business activities and comply with the laws and regulations applicable to its operations in all jurisdictions it operates.

The Supplier shall have zero tolerance towards corruption and bribery. The Supplier shall ensure that all parties acting on its behalf comply with the same principles.

The Supplier shall avoid and prevent all possible conflicts of interest with Marinetek and with its other business partners. The Supplier shall inform Marinetek immediately when a conflict of interest is detected.

The Supplier shall compete in a fair manner in compliance with applicable anti-trust laws and regulations on anti-money laundering, privacy rules and applicable economic and trade sanctions.

The Supplier shall protect all confidential information provided by Marinetek or other parties and comply fully with data security legislation including the GDPR 2016/679 (General Data Protection Regulation 2016/679).

To prevent all unethical business practices, Marinetek expects that its Supplier has the necessary processes and guidelines in place, implemented and trained for all parties acting on its behalf.

The Supplier shall respect the confidential information of companies and individuals and treat all confidential information with due care. The supplier will only use confidential information for legitimate business purposes.

3. Meeting Legal Obligations

Marinetek conducts its business in compliance with applicable laws and regulations, for example in relation to governance, the environment, human and labour rights, communications and disclosures, insider trading and market abuse, anti-bribery, anti-corruption, anti-money laundering, data protection, tax law and financial industry standards. Marinetek expects comparable compliance of its Suppliers.

4. Environmental responsibility

Marinetek expects its Suppliers to be aware of the environmental impact and environmental risks of their activities and strive to minimise the adverse environmental effects of their activities.

The Supplier should implement a precautionary approach towards their relevant environmental risks and impacts, and implement remediation, mitigation, and management related activities.

The Supplier shall, identify, measure, and monitor their environmental impacts and risks relevant to their industry, which include but are not limited to greenhouse gas emissions and energy consumption; pollution prevention and waste reduction; hazardous substances; water consumption; air and water emissions and reduction; resources use; and biodiversity and nature protection.

The Supplier should take immediate action to address any activities within their sphere of influence that may be harmful to the environment and to take measures to remedy the situation and minimise the risks.

The Supplier should aim to reduce the carbon dioxide emissions from their own activities by increasing the carbon neutrality of their energy sources and other purchases and by improving energy efficiency.

5. Social responsibility

Marinetek expects that our Suppliers comply with the basic human rights principles in the workplace, as stipulated in the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work, and the eight ILO core conventions Marinetek also expects suppliers to adhere to the requirements of UN Guiding Principles on Business and Human Rights, the OECD Guidelines on Multinational Enterprises, and the International Bill of Human Rights. Suppliers should immediately address any activity within their sphere of influence that violates or may violate human rights and to take measures to remedy the situation and minimise the risks.

The Supplier shall treat all its employees equally with respect and dignity and ensure that none of its employees faces physical, verbal, psychological or sexual harassment or abuse.

The Supplier shall comply with applicable laws and regulations on working hours, minimum wages, overtime, breaks, rest time, sick leave, annual holidays, parental leave, and mandatory benefits. Supplier will also appropriately record these metrics.

The Supplier should promote equality of opportunity and remuneration, ensure an inclusive workplace, where appropriate support disadvantaged workers, and refrain from practicing any type of discrimination in the workplace.

The Supplier shall protect employees who exercise their legal rights related to freedom of association, collective bargaining, and peaceful assembly.

6. Health and Safety

Suppliers should be committed to creating a healthy and safe work environment that prevents occupational injuries and illnesses, and where appropriate emergency procedures and equipment are provided.

The Supplier should always provide safety training to their employees, where appropriate, and recognise that their employees have the right to stop unsafe work.

The Supplier should record health and safety incidents and use preventive measures.

The Supplier shall at least comply with the minimum standards according to national and local laws and regulations regarding the work environment.

7. Embracing Marinetek Supplier Code of Conduct and raising concerns

The Supplier is expected to implement mechanisms to identify, determine and manage risks in all areas addressed by this Supplier Code of Conduct and with respect to all applicable legal requirements.

The Supplier will establish appropriate training measures to allow their managers and employees to gain an appropriate level of knowledge and understanding of the contents of this Supplier Code of Conduct, the applicable laws and regulations and generally recognized standards.

Marinetek expects that actions inconsistent with this Supplier Code of Conduct are corrected promptly. If such inconsistencies are not corrected, Marinetek may at the utmost choose to terminate the existing business relationship. All misconducts against this SCC needs to be solved without delay. Marinetek does not accept any kind of retaliation against an employee who reports a misconduct to the best of his/her knowledge.

Marinetek’s Suppliers and their employees are expected to report potential misconduct or violations of this Supplier Code of Conduct or Marinetek’s Code of Conduct. Suppliers can raise their concerns to their Marinetek contact person or through our whistleblowing channel (https://firstwhistle.fi/marinetek).

8. Applicability

As a Marinetek’s Supplier, we as the Supplier sign this document to assure that we including our subcontractors are committed to the requirements of this Supplier Code of Conduct.