Anti-Corruption & Anti-Fraud Policy

This Anti-Corruption & Anti-Fraud Policy (the “Policy”) is applicable to all legal entities within Floatel International Group of Companies (hereinafter referred to as “Floatel International” or the “Company”).

Anti-Corruption

It is Floatel International’s Policy to:

  • prohibit its employees, principals, directors, partners, officers and advisors (collectively “Personnel”) from offering, promising, making, authorizing or providing (directly or indirectly, including through Third Parties) any payments, gifts, or transfers of anything of value to any Public Official, including a person known to be (i) an immediate family member of a Public Official or (ii) a former Public Official, in order to improperly influence or reward any official action or decision by such person for the Company’s benefit. Neither funds from Company nor funds from any other source may be used to make any such payment or gift on behalf of or for of their function or activity; and
  • prohibit Personnel from offering, promising or giving (directly or indirectly, including through Third Parties) any payments, gifts or transfers of anything of value to any Private Sector Counterparty Representative in order to induce or reward that person’s improper performance of their function or activity; and
  • comply with the applicable provisions of the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act and all other applicable anti-corruption laws that relate to the prohibition of payments to Public Officials or Private Sector Counterparty Representatives.

Anti-Fraud

This policy applies to all forms of actual or suspected fraudulent or dishonest behaviour involving employees and/or any other parties with a business relationship with the Group. It is intended to provide direction and help to employees who find themselves having to deal with actual or suspected cases of improper behaviour. It provides a framework for responding to such cases and advice and information on various aspects and implications of an investigation. It is not intended to provide a comprehensive approach to preventing and detecting fraud. Its overall aims are to:

  • improve the knowledge and understanding of everyone in the Group, irrespective of his/her position, to the potential risks of fraud;
  • set out responsibilities regarding the prevention, detection and investigation of fraud; and
  • assist in promoting a climate of openness and a culture and environment where staff feel able to raise concerns sensibly and responsibly.

The Group broadly defines fraud as:

“The theft or misuse of the Group’s funds or other resources, by an employee or a third party which may or may not involve the misstatement of financial records to conceal theft or misuse.

The Group has a duty to develop and maintain effective controls and procedures to prevent fraud and to ensure that if it does occur it will be detected promptly. In addition, the experience, knowledge and good intent of employees is an integral part of preventing fraud and dishonest behaviour.

If fraud occurs, the Group is obliged to carry out a vigorous and prompt investigation, taking appropriate legal and/or disciplinary action in all cases where that would be justified, and to ensure that any necessary changes to controls, systems and procedures take place immediately to prevent similar frauds from happening again.

The Group also has a duty to ensure that its environment is a secure place in which to work and one where people are confident to raise concerns without worrying that it will reflect badly on them. This extends to ensuring that employees feel protected when carrying out their official duties and are not placed in a vulnerable position. Where employees have concerns about any procedures or processes that they are asked to be involved in, the Group has a duty to ensure that those concerns are listened to and addressed.

Violations

Failing to abide by this Policy can result in serious financial and criminal penalties for the Company and its Personnel. In addition, violations of this Policy may subject the involved Personnel to disciplinary sanctions. It is therefore imperative that all Personnel comply with this Policy and consult the Chief Financial Officer if there is any doubt about whether an activity is permitted.

If any Personnel knows or learns of a violation of applicable laws or of this Policy, he or she must promptly report the facts to the Chief Financial Officer or use the Company’s ethics hotline whistleblower.floatel@wr.no

22 Feb 2019