A.P. Moller - <strong>Maersk</strong> Group march 2011 2/11Legal ComplianceIn addition to this Code <strong>of</strong> Conduct we expect our Suppliersto respect all applicable laws and regulations andprevailing industry standards.In case there are different standards set forth in this Code<strong>of</strong> Conduct compared to national laws or other applicableregulations or standards, we expect the Suppliers to worktowards higher or more stringent requirements.We expect our Suppliers to address any conflicts betweenthis Code <strong>of</strong> Conduct and applicable laws and regulationsto A.P. Moller - <strong>Maersk</strong>, in order to jointly establish themost appropriate course <strong>of</strong> action.Code <strong>of</strong> ConductResponsible Business BehaviourWe expect our Suppliers to <strong>conduct</strong> business in an ethicaland lawful manner and act with integrity and in compliancewith all applicable laws including anti-trust laws.Anti CorruptionWe expect our Suppliers to avoid participation in orknowingly benefit from, any kind <strong>of</strong> corruption, extortionor bribery. Consequently, the Supplier may not <strong>of</strong>fer,promise, authorise or give anything <strong>of</strong> value to any public<strong>of</strong>ficial in any country, or to any business partner, in orderto gain any improper business advantage <strong>of</strong> any kind. Inaddition, the Supplier may not solicit or accept any form<strong>of</strong> bribe from any person.Working and Employment ConditionsHealth and SafetyWe expect our Suppliers to provide a safe and healthyworking environment for all their employees. An employeeis an individual who works part time or full time,under an open or fixed term contract <strong>of</strong> employment,that may be oral or written. This applies to any companyprovidedaccommodation.Products LiabilityWe expect our Suppliers to exercise due diligence whendesigning, manufacturing, and testing products; In orderto protect against product defects which could harm thelife, health or safety <strong>of</strong> people, likely to be affected by thedefective product, or have an adverse impact on the environment.We expect our Suppliers to have effective health andsafety management systems that ensure, among otherthings:• Compliance with applicable laws and regulations.• Compliance with customer requirements.• Management <strong>of</strong> hazards and risks associated withits operations (risks and hazards are identified andcontrolled).We expect our Suppliers to continuously work to reduceand mitigate health and safety risks in the workplace. Weexpect our Suppliers to educate, train and protect all employeesfrom any harm arising from workplace activities.Respectful TreatmentWe expect our Suppliers to not use, or permit the use <strong>of</strong>,corporal punishment or other forms <strong>of</strong> mental or physicalcoercion, sexual harassment or abuse, nor execute threats<strong>of</strong> such treatment.Use <strong>of</strong> Company Security ForcesWe expect our Suppliers to prevent its security guardsfrom excessive or uncalled for infringement on the libertyand security <strong>of</strong> others, by providing the necessary trainingon when to intervene in security-related situationsand how to use the minimal force necessary.A.P. Møller - mærsk A/S • Esplanaden 50 • 1098 københavn K • maersk.com
A.P. Moller - <strong>Maersk</strong> Group march 2011 3/11Equal Opportunity RightsWe expect our Suppliers to not engage in or support discriminationand to adopt a non-discriminating practicethat strives to ensure equal treatment in recruitment, hiring,compensation, access to training, employee benefitsand services, promotion, termination and retirement,irrespective <strong>of</strong> age, gender, race, colour, disability, religionor belief, language, national or social origin, trade unionmembership, or any other status recognised by internationallaw.Child LabourWe expect our Suppliers to work towards eliminatingchild labour.CompensationWe expect our Suppliers to pay all employees a fair andequal compensation, in accordance with national lawsand regulations, including overtime hours and all legallymandated benefits.Working HoursWe expect our Suppliers to comply with appropriateworking hour requirements as established by nationallaw or relevant collective agreements. We expect ourSuppliers to ensure that overtime is voluntary, communicatedto the employee and appropriately compensated inaccordance with local and international regulations andcollective agreements.The acceptable minimum age for employees is 15 years.As far as necessary and only if national law permits,children under the age <strong>of</strong> 15 are allowed to carry out lightwork that does not interfere with compulsory schooling.Employees under the age <strong>of</strong> 18 years are not to beinvolved in night work or work that is hazardous or likelyto have a negative impact on the employee’s physical ormental development.Voluntary LabourWe expect our Suppliers to not use or benefit from, forcedor involuntary labour as per ‘Guidelines & Good BusinessPractice’ addition to this document. All employees shallenjoy the freedom <strong>of</strong> movement during the course <strong>of</strong> theiremployment. Personal/employment documents or payment<strong>of</strong> compensation must not be withheld, therebypreventing such an employee from terminating his/heremployment.Freedom <strong>of</strong> Association and Collective BargainingWe expect our Suppliers to respect the rights <strong>of</strong> its employeesto associate freely, join or not join trade unionsand/or workers councils, or engage in collective bargaining,in accordance with national law and internationalconventions.EnvironmentWe expect our Suppliers to integrate environmentalconsiderations in its activities and strive for continuousimprovement, by minimising any adverse effects <strong>of</strong> its activitieson the environment.We expect our Suppliers to comply with all relevant localand national environmental laws and regulations, as wellas all requirements for environmental licences and permits.We expect our Suppliers to strive to develop and implementenvironmental management systems that includemeasurement and monitoring in order to:• Identify environmental impacts.• Reduce waste, energy and emissions to air, groundand water.• Handle chemicals in an environmentally safe way.• Handle, store and dispose <strong>of</strong> hazardous waste in anenvironmentally safe manner.• Contribute to the recycling and reuse <strong>of</strong> materials andproducts and implement environmentally friendlytechnologies.Policy <strong>of</strong> Dealing with Severe ViolationsThe underlying objective <strong>of</strong> the Code is to establish a basisfor a positive development <strong>of</strong> responsible procurementpractices through dialogue and ongoing working relationships.environment, A.P. Moller - <strong>Maersk</strong> will contact theSupplier within 24 hours <strong>of</strong> the discovery <strong>of</strong> the incidentand will request to terminate the practice and set up adialogue around prevention <strong>of</strong> the same in the future.However, in cases <strong>of</strong> a severe violation <strong>of</strong> the Code, suchas Supplier engaging in or benefiting from the use <strong>of</strong> childlabour, corruption, severe violation <strong>of</strong> internationallyrecognised labour rights and/or significant damage to theA.P. Moller - <strong>Maersk</strong> will endeavour to terminate the businessrelationship with Suppliers who repeatedly andknowingly violate the <strong>code</strong> and refuse to collaborate withA.P. Moller - <strong>Maersk</strong> in implementing improvement plans.A.P. Møller - mærsk A/S • Esplanaden 50 • 1098 københavn K • maersk.com