1.      Purpose

The purpose of this code is to express LNT Marine’s statement of its commitment and principles in connection with issues of ethical nature that relate to business practice and personal conduct.

The Code of Ethics and Business Conduct describes the ethical principles guiding our business. The code is a framework intended to support LNT Marine and its Representatives in the performance of their duties. It is not exhaustive and is supplemented by other subject matter policies and other relevant procedures in LNT Marine’s Management System.

2.      Introduction

The LNT Marine Code of Ethics and Business Conduct reflects our commitment to our shareholders, customers and employees to conduct our business according to the highest standards of integrity.

LNT Marine’s values are based on openness, competence and team spirit and are rooted in honesty and respect for the individual. Successful businesses are profoundly dependent on confidence and a good reputation. LNT Marine’s activities demand a high degree of care, honesty and integrity.

This Code of Ethics and Business Conduct applies worldwide to all employees in LNT Marine and companies in which LNT Marine has a majority interest, including joint ventures, and also to all LNT Marine board members, officers, temporary employees and legal agents, consultants, intermediaries and others who act on behalf of the LNT Marine (Collectively “Representatives”).

It is the expectation of LNT Marine that all applicable business partners, suppliers, agents or other third parties (collectively referred to as “Suppliers”) will also observe equivalent principles when conducting business with LNT Marine. To that end LNT Marine has created a “Supplier Code of Ethics and Business Conduct” in which it expresses the expectations we hold for our Suppliers.

If you are uncertain whether a particular activity is legally or ethically acceptable, the rule is to seek advice and guidance from LNT Marine Management, or other compliance contacts notified to you in local procedures.

As a Representative, you are responsible for making these guidelines known and promoting and monitoring compliance. All consultants, intermediaries and others who act on LNT Marine’s behalf must make themselves familiar with the Code of Ethics and Business Conduct and act accordingly.

3.      General Guidelines

LNT Marine requires Representatives to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Representatives must practice fair dealing, honesty and integrity in every aspect in dealing with employees, business relations and customers, the public, the business community, shareholders, suppliers, competitors and government authorities.

In its business activities LNT Marine will comply with applicable laws and governmental rules and regulations in every country in which LNT Marine has activities.

It is the personal responsibility of everyone to adhere to the standards and restrictions imposed by those laws, rules and regulations, including those relating to accounting and auditing matters, and to internal LNT Marine rules (if these are not in conflict with the applicable legislation).

The principles contained in this Code of Ethics and Business Conduct apply to all transactions, large or small, and drive the behavior always expected in the conduct of LNT Marine’s business. LNT Marine will not condone or tolerate any instance of unethical or unlawful behaviour.

4.      No Tolerance for Corruption

LNT Marine is against any and all forms of corruption and is committed to support and promote a business environment free of corruption and bribery. LNT Marine is committed to complying with anti-corruption laws.

No one in LNT Marine, being board members, officers, employees, temporary employees and legal agents, consultants, intermediaries, or others who act on LNT Marine’s behalf shall directly or indirectly offer, promise, give or receive bribes, kickbacks, inappropriate gifts or other undue advantages or remuneration in order to achieve improper business or personal advantage.

If such an act occurs, it may result in disciplinary action, contractual termination, or dismissal with or without notice, and may also be reported to the relevant authorities. Also, pursuant to applicable legislation, LNT Marine and its officers and employees directly involved may be subject to fines, imprisonment, and civil litigation.

LNT Marine will take the necessary steps to prevent its financial transactions from being used by others to launder money.

5.      Confidentiality and Protection of Assets

Trade secrets and other proprietary information about LNT Marine, its business activities, technology, other intellectual property, financial position, or personnel, as well as information about or received from LNT Marine’s customers, suppliers and partners, must be treated as confidential.

Such information may not be disclosed to persons outside LNT Marine or to Representatives without proper authority. The obligation to preserve LNT Marine’s confidential information continues after employment ends.

6.      Data Protection

Data protection rules apply to any information that can be used on its own, or in combination with other clues, information, or context, to identify, contact, or locate an individual.

LNT Marine is committed to protecting personal data, and to do so Representatives must know the types of data we hold, where data is held, what it is used for, and then understand the consequences of a data protection breach.

If personal data falls into the wrong hands, it may be possible for criminals to identify an individual and target them for illegal activity. We therefore all have a responsibility to protect the data of our clients, fellow Representatives and other parties such as Supplier individuals.

Privacy incidents are often caused by people making simple mistakes. To help avoid any such mistakes, Representatives should follow the following principles:

  • Don’t collect data unless you have
  • Make sure the data is processed lawfully, fairly and
  • Don’t use data for purposes other than the purpose about which you have informed the individual – make sure you only collect data for specified, explicit and legitimate purposes. Don’t process data in a way that is incompatible with those purposes.
  • Use personal data only for the purposes for which it was originally obtained. Make sure your use of data is adequate, relevant and limited to what is
  • Protect data at all costs and safeguard identity by stripping out information unnecessary for the purpose (i.e. removing names immediately from files when hourly salary data is only needed for the purpose of project cost modelling).
  • Limit internal access to any personal data you hold for legitimate
  • Destroy data when it’s no longer
  • Make sure your data is accurate and, where necessary, kept up to

LNT Marine will observe the same principles when collecting, using, handling and retaining personal information of its Representatives.

LNT Marine has established a public Privacy Policy, accessible on the corporate website and further information on our Data Protection compliance programme, including relevant procedures can be found by Representatives on our Management System (or are circulated to Representatives only having external access, such as our third parties, when necessary) or by contacting the company’s management.

If there is any data breach, employees must report this to our CEO or COO.

7.      Records and Communications

Accurate and reliable records of many kinds are necessary to meet LNT Marine’s legal and financial obligations and to manage the affairs of LNT Marine. LNT Marine’s books and records must reflect, in an accurate and timely manner, all business transactions. The Representatives responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Representatives must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to false expense, attendance, production, financial, or similar reports and statements.

8.      Competition

LNT Marine is committed to fair and open competition. In no circumstances shall LNT Marine engage in any anti-competitive practices or other activities in violation of applicable anti-trust laws and directives. No Representative shall enter into any formal or informal understanding, agreement or plan, with any competitor in regard any competitive information; nor engage in any other conduct which violates anti-competition laws. Joint venture agreements and proposals, or subcontracting agreements with competitors which have been approved by LNT Marine’s management are not prohibited.

9.      Insider Trading

Insider information is information capable of affecting the price of securities and which is not publicly available or generally known to the market. An example would be that one company decides to take over another and a person is in a position to know this is taking place before it happens. Knowing this information, a Representative might be in a position to make a financial win as the share price of the companies might rise when the takeover news becomes public. This is knowing insider information and trading on it to your advantage.

LNT Marine’s insider trading policy is that no individual may use, or contribute to others using, insider information about LNT Marine or other companies to subscribe for or trade in securities, either privately or on LNT Marine’s behalf. This applies to Representatives and any person living in their households, like a spouse or anyone who is financially dependent, such as children.

LNT Marine is not a listed company. Should it become listed, LNT Marine will issue regulations for its primary insiders wishing to trade in LNT Marine or other securities.

Aside from being a “Primary Insider” as a Representative of LNT Marine you may still be in possession of sensitive information which should not be revealed to other people, inside or outside of the Company. All Representatives should be mindful that they should not share sensitive information and that such information can take many different forms, for example financial statements and results, accounts receivable figures, commercial terms, project milestone dates etc.

If you are in doubt or need clarification, please contact LNT Marine management directly.

10.  Funds and Other Assets

Representatives who have access to LNT Marine’s funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in LNT Marine’s policies and procedures or other explanatory materials, or both. LNT Marine imposes strict standards to prevent fraud and dishonesty. If Representatives become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that LNT Marine can promptly investigate further.

When a Representative’s position requires spending LNT Marine funds or incurring any reimbursable personal expenses, that individual must use good judgment on LNT Marine’s behalf to ensure that good value is received for every expenditure. LNT Marine funds and all other assets of LNT Marine are for the purposes of LNT Marine only and not for personal benefit.

11.  Dealing With Outside People and Organizations

Representatives must take care to separate their personal roles from their LNT Marine positions when communicating on matters not involving LNT Marine business. Representatives must not use LNT Marine identification, stationery, supplies, and equipment for personal or political matters.

When communicating publicly on matters that involve LNT Marine business, Representatives must not presume to speak for LNT Marine on any topic, unless they are certain that the views they express are those of LNT Marine, and it is LNT Marine’s desire that such views be publicly disseminated.

Social media is constantly evolving. impacting our notions of privacy and communication norms. LNT Marine does not endorse the use of online social media platforms for professional purposes, however respects that outside work. Representatives may be active users. When interacting on social media, the privacy rights of current and former employees should be respected and LNT Marine or its Representatives should not be represented in a false or misleading way.

When dealing with anyone outside LNT Marine, including public officials, Representatives must take care not to compromise the integrity or damage the reputation of either LNT Marine, or any outside individual, business, or government body. No business communications should be conducted using personal devices, except via company authorized applications.

12.  Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the public and others in LNT Marine, all Representatives must make every effort to achieve complete, accurate, and timely communications – responding promptly and courteously to all proper requests for information and to all complaints.

13.   Personal Conduct

When acting on behalf of LNT Marine, Representatives shall not take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair dealing practices.

LNT Marine expects its Representatives to conduct themselves in a businesslike manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job or representing LNT Marine on business travel.

14.  Respect for the Individual, Human Rights and Employment Practices

LNT Marine prohibits unlawful discrimination against employees, shareholders, officers, directors, customers and suppliers on account of race (including colour, nationality and ethnic or national origin), social status or origin, age, gender or gender identity or expression, sexual orientation, marital or civil partnership status or family structure, maternity or pregnancy, religion, political belief or disability. All persons shall be treated with dignity and respect and they shall not be unreasonably interfered with in the conduct of their duties and responsibilities. Inappropriate workplace conduct, such as harassment will not be tolerated. Harassment can include unwanted physical contact, bullying, intimidation or offensive jokes, and may relate to a form of discrimination. LNT Marine prohibits and will not tolerate any form of harassment and abusive behavior. All LNT MARINE Representatives shall contribute to a work environment free from any discrimination and harassment.

LNT MARINE is committed to ensuring effective employee relations through mechanisms for receiving employee feedback and addressing employee concerns, including supporting freedom of association and collective bargaining.

LNT Marine commits to the United Nations Universal Declaration of Human Rights and the standards advised by the International Labour Organisation. Slavery, forced labour, child labour, torture and other violations of human rights are totally unacceptable. The term “child” refers to any person under 15 or the minimum legal age for employment where the work is performed. LNT Marine will adhere to regulations prohibiting human trafficking and comply with all applicable laws in the countries in which we operate and must not, for example require Representatives to pay recruitment fees or deposits; destroy, confiscate or conceal identify or immigration documents. LNT Marine is committed to preventing slavery and human trafficking.

LNT Marine conducts due diligence on its third parties. These procedures support our efforts to ensure that our supply chains operate in an ethical and responsible manner and to prevent slavery, human trafficking, forced or child labour and any other violations of human rights and labour standards. For more information on LNT Marine’s expectations regarding our suppliers, please refer to the Supplier Code of Ethics and Business Conduct.

15.  Loyalty & Conflict of Interest

LNT Marine requires Representatives to be loyal to LNT Marine, and to refrain from actions or to have interests that make it difficult to perform their work objectively and effectively.

Representatives must behave impartially in all business dealings and not give other companies, organisations or individuals improper advantages. The employees may not take part in or seek to influence any decision under circumstances that can give rise to an actual or perceived conflict with LNT Marine’s interest or could in any way have a negative effect on their own freedom of action or judgement. Such circumstances may be a personal interest in the subject matter – financial or otherwise – directly or through spouse, partner, close relative or any other person with whom they have close relations.

Regardless of the circumstances, if Representatives sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest, they should immediately communicate all the facts to the LNT Marine management, or other local compliance contacts notified to you.

16.  Trade Compliance

LNT Marine is committed to complying with all relevant Trade Sanctions and Export Controls. These are laws and regulations which govern whether you can do business, and what you can do, with certain individuals, entities or countries.

LNT Marine will ensure that all business activities, and the 3rd parties’ activities performed on our behalf, are conducted in accordance with all applicable laws and regulations covering the economic sanctions and the Import and Export of goods and services, this includes compliance with Strategic Export Control Regulations, Customs regulations and related tax laws and anti-boycott laws.

17.  Expressions of Concern

LNT Marine wants to encourage open discussions about responsible conduct. This should take place through a constructive and non-threatening process. If you discover any unethical or illegal practice or find yourself in an ethical dilemma you are obliged to seek advice. If you would like to report a concern in respect to breach of laws and regulations (such as possible bribery or corruption) LNT Marine management encourages you to report your concerns even on an anonymous basis. This also applies to concerns of a more general nature, such as breach of any of our corporate policies.

LNT Marine shall register all reported cases and will decide on adequate actions and follow up on all reported cases, including appointing members to form an investigation team as deemed necessary for the establishment of facts. The confidentiality must be ensured by the involved parties. If the expression of concern is about another person, the person in question shall be informed at an appropriate point in the investigation and will be given the opportunity to give his/her version of the matter. The person who has expressed his/hers concern shall be given feedback of the handling and the outcome of the process, unless the notification was done anonymously. We reiterate our commitment that no retaliation or reprisals will be taken against any employee for raising any concern or questions in good faith.

LNT Marine’s external business partners should report any concern, as notified to them through our onboarding activities, through our Qualification process or in contractual documents provided.

All reports of suspected violations will be treated confidentially. Reviews and investigation will be conducted in an independent, fair and unbiased manner with respect to all parties involved and in accordance with relevant laws and principles (including fair hearing). All reports will be documented and if needed will be reported to the relevant authorities..

18.  Communication & Training

LNT Marine will ensure that all Representatives are informed about this code and our policies. Each employee will receive relevant training and new Representatives will be briefed as a part of the introduction programme.

Our Code of Ethics and Business Conduct and accompanying procedures and training materials shall be available in the local language to the extent necessary.

19.  Consequences of Infringement

Breaches of LNT Marine’s Code of Ethics and Business Conduct or relevant statutory provisions may result in disciplinary action, or dismissal with or without notice, and may also be reported to the relevant authorities. Should an improper practice occur within LNT Marine, we are committed to making necessary corrections and taking remedial action to prevent recurrence.

Code of Ethics and Business Conduct

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