Corporate Social Responsibility

Purpose & Aims

The purpose of this policy is to make clear to all Partners what we mean by Corporate Social Responsibility (CSR) and how we propose to work towards achieving it. The CSR policy applies throughout all of the Supply Chain and governs the approach to all our activities.
We take our legal, ethical, health and safety and environmental responsibilities in this regard very seriously. Seajacks operates in different areas around the world, and, as such, devises procedures appropriate to and compliant with local laws, culture and operating conditions but within the overall context of this policy.

Seajacks encourages its Partners to read and agree with our HSEQ objectives to:

• Pursue the goal of no harm to people;
• Protect the environment;
• Use material and energy efficiently;
• Play a leading role in promoting best practice in our industries;
• Manage HSEQ matters as any other critical business activity;
• Provide a safe and healthy workplace, presenting no immediate hazards to its employees and visitors. Any housing provided to its employees is safe for habitation, provides access to clean water, food, and emergency healthcare to its employees in the event of accidents or incidents at the workplace;
• Promote a culture in which all employees share this commitment.

In this way we aim to continue to sustain the confidence that our customers, shareholders & society at large have in us. This commitment is endorsed by the Seajacks Chief Executive Officer and subsequently adopted by all employees, shareholders, directors, clients and suppliers. We encourage our Partners to follow similar principles when conducting their own business also.

Objectives

Seajacks is committed to acting responsibly, ethically and with integrity in its dealings with employees, clients, suppliers, the community and the environment as a whole. All our employees strive for the best and therefore comply with our CSR objectives:

• Maintaining a HSEQ performance that we can be proud of;
• Treating all our employees equally, ethically, respectfully and with dignity by providing excellent working conditions, competitive terms and conditions, good training and opportunities to grow;
• Continually improving our environmental performance, by protecting biodiversity, reducing pollution, conserving natural resources and operating sustainable procurement, waste, water and energy management;
• Complying with regulatory framework in every country and place in which we are operating; such as a zero tolerance towards bribery and corruption, child labour and involuntary prison labour;
• Contributing positively to the local communities in which we are operating; such as supporting education, developing the industries we work in, sourcing of local products and resources and involvement with local charity and sporting events.

Seajacks expects its business Partners (including suppliers, vendors, purchasers and clients) to promote the application of this policy within their organisation and throughout their own supply chain.

Accordingly, Partners with whom Seajacks work are required to comply with the terms of the CSR policy. In the event that the partner does not have the required policies/systems in place, the partner shall be required to demonstrate and warrant that it will develop and/or actively promote the principles of such required policies/systems set out in this policy.

Employment & Working Conditions

Seajacks Policy prohibits unlawful discrimination against employees, shareholders, directors, customers and suppliers on account of race; ethnic or national origin; age; disability; gender re-assignment; marriage and civil Partnership; religion or belief; pregnancy and maternity; gender; or sexual orientation. Respect for the individual is the cornerstone of Seajacks’ Policy. 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.

Seajacks expects its Partners to:

• Not employ engage or otherwise use any child labour as prohibited by the ILO (International Labour Organisation);
• Not use forced labour in any form (prison, indentured, bonded or otherwise) and its employees are not required to lodge papers or deposits on starting work;
• Not discriminate against any employees on any ground (including race, ethnic or national origin; age; disability; gender re-assignment; marriage and civil Partnership; pregnancy and maternity; sex; sexual orientation; or religion or belief);
• Not engage in or support the use of corporal punishment, mental, physical, sexual or verbal abuse and does not use cruel or abusive disciplinary practices in the workplace;
• Pay each employee at least the minimum wage, or a fair representation of the prevailing industry wage, (whichever is the higher) and provide each employee with all legally mandated benefits;
• Comply with the laws on working hours and employment rights in the countries in which it operates; and
• Respect its employees’ right to join and form independent trade unions and freedom of association.
• Have ethical and human rights policies, such as an appropriate complaints procedure to deal with any breaches of policies.

Regulatory Framework

It is Seajacks’ Policy to comply with all applicable laws and governmental rules and regulations in every country and place in which it is operating. It is the responsibility of each Partner that their employees and officers adhere to the standards and restrictions imposed by those laws, rules and regulations. This includes any laws, rules and regulations relating to accounting and auditing matters and to Seajacks rules (if these are not in conflict with the applicable legislation).

The use of any Seajacks funds or Seajacks property for any unlawful purpose under the laws of any state is prohibited.

Act fairly when conducting business

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

Seajacks desires fair and open competition in all markets, both nationally and internationally. Under no circumstances shall Seajacks Partners be part of actions that breach applicable competition legislation.

Seajacks will not tolerate corruption

Seajacks are committed to supporting the aims of the UK Bribery Act 2010 and all laws relevant to countering bribery and corruption in all the jurisdiction in which the company operates and expects no partner of Seajacks to directly or indirectly offer, promise, give or receive bribe, illegal or inappropriate gifts or other undue advantages or remuneration in order to achieve business or other personal advantage.

In dealing with public officials and private citizens, domestic and foreign, including business associates and customers, Seajacks expects its Partners to follow only ethical practices. Payments of any size, gifts or offers of payment or gifts to induce domestic or foreign officials to fail to perform their duties or to perform them in an unlawful or improper manner are prohibited.

Gifts and Hospitality

This Policy does not prohibit normal and appropriate hospitality (given or received) to or from third parties.

The giving (or receipt) of gifts is not prohibited, if it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits.

Seajacks does not find it acceptable for its Partners (or someone on their behalf) to:

• Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
• Give, promise to give, or offer, a payment, gift or hospitality Regulatory Framework to a government official, agent or representative to ‘facilitate’ or expedite a routing procedure;
• Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
• Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
• Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns.

Respect all Seajacks confidential information

All Partners will preserve the confidentiality of information obtained in the course of their relationship with Seajacks. Unless specifically authorised to do so by the Chief Financial Officer no partner will give out any information of a confidential nature concerning company business or its relationship with any customer to an unauthorised fellow employee or anyone outside the company.

The Local Community

Seajacks is committed to being a responsible corporate citizen through the support for appropriate non-political and non-sectarian projects across a range of organizations and charities. Regardless of regional or national boundaries, Seajacks aims to support the creation of prosperous, educated, sustainable and healthy communities in the countries and cultures in which it operates – with a focus on education and enterprise, health and welfare, and the environment.

Seajacks expects its Partners will ensure that they deal responsibly, openly and fairly with their suppliers by:

• Ensuring that they use local suppliers as much as possible;
• That they will endeavour to pay on time;
• Not expecting any discounts to have a detrimental effect on their business.