Proprietary and confidential information
Trade secrets and other proprietary information about Prosafe, its business activities, technology, other intellectual property, financial position or personnel, as well as information about Prosafe’s consultants, customers, suppliers and other business partners must be treated as confidential. Such information must not be disclosed verbally, in writing or electronically to persons outside the company or to employees without proper authority.
Careful consideration should be given to how, where and with whom Prosafe-related matters are discussed, in order to ensure that unauthorised persons do not gain access to confidential Prosafe information.
Information must be marked appropriately and kept secure. Access must be limited to those who need to know in order to do their jobs.
Upon termination of employment or after an assignment has been completed, all proprietary information must be returned to Prosafe. The obligation not to disclose confidential information continues to apply after the termination of employment or completion of an assignment.
Conflicts of interest
You must avoid entering into any situation in which personal or financial interests or that of persons or companies with which you have ties or links may conflict with those of Prosafe.
If employed on a full-time basis by Prosafe, no outside professional activities should be exercised without first obtaining the written approval of your manager.
No one must work on or deal with any matter in which they themselves, their spouse, partner, close relative, or any other person with whom they have close relations, has a direct or indirect financial interest.
Prosafe’s property or information acquired through your position in Prosafe must not be used for personal advantage or for the purpose of competing with Prosafe.
Any conflict of interest or suspicion of conflict of interest must be flagged. If in doubt, you should consult your manager or the Ethics Committee.
Bribery and corruption, antitrust
Bribery exists when an attempt is made to influence someone in the conduct of their duties through the provision of an improper advantage to obtain an improper commercial or personal advantage. Trading in influence exists when an improper advantage is provided to someone in order to influence the performance of a third party’s duties. Such improper advantage can take different forms, such as cash, objects, credits, discounts, travel, accommodation or services.
You must not offer or provide an undue monetary or other advantage to any person or persons, including public officials or customer employees, in violation of laws and the official’s or employees’ legal duties, in order to obtain or retain business.
Agreements with consultants, brokers, sponsors, agents or others intermediaries must not be used to channel payments to any person or persons, including public officials or customer employees and thereby circumvent Prosafe’s policies regarding bribery and corruption.
Contributions to political parties, political committees and to individual politicians must not be given.
Gifts and hospitality
You must not offer, make, seek or accept any payment, personal gift or entertainment that might reasonably be believed to influence business transactions or that is not within the bounds of customary business hospitality. During commercial negotiations, extra care is merited. You must never request or solicit personal gifts, favours, entertainment or services.
When providing or receiving third party gifts and entertainment, good judgment must be exercised in each case, taking into account pertinent circumstances, including the character of the gift or entertainment; its purpose; its appearance; the positions of the persons providing and receiving the gift or entertainment; the business context; reciprocity, and applicable laws and social norms.
Gifts of nominal value, small promotional items, occasional meals and social events may be acceptable if there is a clear business reason. Hospitality must be kept at a moderate level. Travel, accommodation and other expenses for the individual themselves in connection with such hospitality must always be approved in advance by your manager and paid for by Prosafe.
The above principles also apply in reverse, so that no individual acting on behalf of Prosafe may, in their dealings with customers, suppliers and other parties, offer or agree to pay for gifts, hospitality or other expenses that would violate these principles.
Inside information is information that is likely to have a noticeable effect on the share price or on other securities related to Prosafe and which is not publicly available or commonly known in the market. You are prohibited from using, or enabling others using insider information about Prosafe or other companies, to trade in shares in Prosafe or any other publicly traded company.
Prosafe has set mandatory policies on trading for insiders. More specific instructions are provided for persons defined as primary insiders in Corporate Procedure C1-07- Inside Trading Instructions.
Prosafe has strict procedures for dissemination of information that may influence the market valuation of its securities. As a public company, Prosafe discloses information in accordance with the rules and regulations for companies listed on the Oslo Stock Exchange on which Prosafe’s shares and other securities are listed.
Use of IT systems
As a general rule, use of company owned network and computer systems should be for company business purposes only, and be limited to personnel especially authorised by Prosafe. Personal use must never be at the expense of work-related tasks. All use shall be in accordance with legislation and Prosafe’s management systems and Code of Conduct.
Company sensitive data and information shall be treated in a secure and confidential manner. User access codes and passwords shall always be kept secret. Information, data and programs you are producing are to be considered company property and must be treated accordingly.
Social media must never be used in a way that breaches any of Prosafe’s policies, procedures or ethical standards. You must avoid social media communications that might be misconstrued in a way that could damage Prosafe’s business reputation, even indirectly.
When disclosing information on social media, you must respect intellectual property rights and not disclose any confidential information or information about sensitive business related topics.
You must show respect for colleagues, consultants, customers, suppliers and other business partners. Harassment, bullying and discrimination of colleagues, clients, suppliers or business partners on social media are in conflict with this Code of Conduct.
If you disclose your affiliation as an employee of Prosafe, you must also state that your views do not represent those of your employer and that you are speaking on your own behalf.