HAVFISK ASA integrity channel

 
HAVFISK ASA’s vision and core values are designed to cultivate and refine a corporate culture in which people deliver excellent results in a responsible manner.
 
We aim to be a proud manager based on our values Safety, Sustainability, Profitability and Pride in an environmentally friendly, ethical, and socially responsible manner. HAVFISK’s four core values, together with our ethical guidelines, emphasize our standard for ethics and integrity. These values are used to support and guide day-to-day priorities and decision-making. These values underpin our Code of Conduct, and we have established an integrity channel to allow employees and others to raise concerns about improper activities or misconduct and report instances of potential non-compliance with our values without fear of retaliation. Such improper activities or misconduct may include HSE violations, harassment, insider trading, money laundering, fraud, bribery and kick-back arrangements, or other breaches of the HAVFISK ASA’s Code of Conduct.
 
Raising a concern
HAVFISK ASA employees are encouraged to first discuss any compliance matters internally with their immediate supervisor or another member of senior management. Such concerns can also be raised with an employee representative on the Board of Directors. If such measures are not deemed to be sufficient, incidents may be reported through the integrity channel.
 
Reports received through the integrity channel will initially be received and handled by an independent third party; the law firm PricewaterhouseCoopers (“PwC”). PwC is dedicated to maintaining high ethical standards and will handle all submissions with confidentiality. HAVFISK ASA’s CFO, Eldar Farstad, is responsible for the handling of raised concerns within HAVFISK.
 
There are three possible ways to report a concern:
  1. Fill in a form
  2. Send an email to PwC: aker.integrity@no.pwc.com
  3. Send a letter to PwC: PricewaterhouseCoopers, Att. Gunnar Holm Ringen, Postboks 748 Sentrum, N-0106 Oslo, Norway.
 
When raising a concern using one of these three possible ways, the person raising the concern may remain anonymous. However, it will be easier to conduct an investigation and other follow up activities will more likely be successful if the person reporting gives his/her identity. The person raising a concern may also remain anonymous towards HAVFISK, giving his/her identity to PwC only.
After processing the reported concern, PwC will make an initial report to the Compliance Officer in HAVFISK ASA who will then assess the report. If the report is in the nature of an allegation that requires investigation, an investigation team will be assembled and be under the supervision of the Chairman of the Audit Committee.

Unless the person reporting the concern has elected to remain anonymous to all parties, he/she shall receive a response within a reasonable period of time. This response will contain information about how the case has been treated and the outcome.
 
All incidents logged are formally closed by the Audit Committee in Meeting.