1. Objectives

Seafood People (SP) is a management consulting and executive search company that provides our clients worldwide with great talent, growth strategies and precise execution. Our success is built on ambitious goals and by conducting our business without compromising on integrity. The Code of Conduct sets standards of behaviour which we can expect from one another, and which external parties can expect from us.

Our Code of Conduct supports SP’s vision in order to maintain our position and to continue to build confidence in our company and our services. Our conduct – what we do and say each day – determines our ability to succeed, together as an organisation. SP’s operations require the confidence of clients, authorities and the rest of society and in order to achieve this, we are dependent on professionalism, skills and a high ethical standard in all parts of our work.

This applies to SP’s business operations and the conduct of each individual employee. All employees must act with due care, honesty and impartiality and refrain from acts that may weaken confidence in SP.

2. Roles and Responsibilities

Owner of this policy: Managing Partner (MP)
Approved by the Board: 23.02.2017

SP’s Code of Conduct applies to members of the Board, managers and other employees as well as those acting on the behalf of the company. The MP has the overall responsibility for the Code of Conduct and is responsible for making the Code of Conduct available and for training employees and making them aware of this issue. The Senior Advisor has the overall responsibility for ensuring that this policy is revised annually.

3. Integrity

This Code of Conduct provides guidelines for SP and each individual employee’s ethical conduct, but is not intended to cover all circumstances. In general, the integrity of SP and each employee must be ensured in all matters. Discretion should, however, be used when considering proper conduct in each individual situation.

4. Laws and regulations

Everyone must comply with all laws, regulations, internal guidelines and relevant ethical standards that are applicable for the industry.

5. Openness

SP is to have an open company culture since openness is a prerequisite for motivation, trust and confidence. The Code of Conduct cannot state what is right and wrong in all situations so it is important to be open about one’s actions and to talk to others. All employees must feel safe when they raise small or large concerns. If employees have any doubts, they must raise the concern with their superior.

Raise three practical tests of an ethical decision:

1. Is it legal? Will I be violating civil law, company policy, or “standard practice”?

2. Is it fair to all involved today and in the long term? Does it promote a solid relationship for the future?

3. How would I feel about it myself? Would I be proud? Would I want my friends/family/colleagues to read about it in the newspaper?

6. Rules governing business practice

A. Human rights

In its operations, SP supports and respects internationally proclaimed human rights, including the UN Human Rights Convention and the International Labour Organisation’s labour rights conventions. SP employees shall not in any way cause or contribute to the violation or circumvention of human rights.

B. Corruption/ Bribery

SP has a zero tolerance principle to fraud, facility payments and corruption. SP requires its own employees at all times to act and comply with its zero tolerance principle by fully conforming to all procedures and policies adopted to prevent corruption and fraud. All members of the governing bodies, employees and agents should, therefore, be irreproachable in their personal conduct. Fraud and corruption are ever-present threats to SP’s reputation and must be a concern of all members of the governing bodies, staff and agents. Behaviour that falls short of the required standards is not acceptable. Where such behaviour is suspected, it will be investigated and, where proven, legal and/or disciplinary action taken.

C. Money laundering

Money laundering is the conversion of the proceeds of a criminal act into an apparently lawful income or increase in net assets. SP will conduct business only with reputable customers and suppliers involved in legitimate business activities with funds derived from legitimate sources.

D. Competition laws

SP and the employees undertake to comply with the competition laws that apply where SP has its operations and does business. SP employees will not enter into any agreements or understandings with competitors, or engage in other conduct, that undermines competition.

7. Rules governing personal conduct

Under no circumstances may anyone deal with, decide on or exert influence in a case where this person or a related party of this person has economic or other personal interests in the matter, either directly or indirectly. The employee is to inform the immediate the MP as soon as he/she becomes aware that a question of prejudice may arise.

A. Discrimination and bullying

Tolerance is to be shown for employees´ and other interested parties´ attitudes and opinions. No one may discriminate against or bully other employees/colleagues, business partners, members or other interested parties. Anyone who feels discriminated against or bullied is to be taken seriously.

B. Duty of confidentiality

Everyone is subject to a duty of confidentiality regarding clients´, employees´ and other parties´ business or personal circumstances that they find out about in connection with carrying out their work for SP. The duty of confidentiality also covers information on SP’s business operations and other factors of an internal or confidential nature. The duty of confidentiality also applies in relation to others that do not need to know the information in their work.

C. Relationship with business connections

Restraint must be shown in relation to private agreements with companies and persons that employees have a business connection with through their work for SP. In addition, restraint must also be shown in relation to business agreements with persons with whom employees have a personal relationship.

D. Business entertainment and events

Employees who, due to their job, represent or may be identified with SP are expected to behave in a way that inspires trust in both SP and the employee.

E. Gifts

As a rule, no one is to receive benefits, such as gifts, from SP’s business connections if the benefit is based on the employment relationship. On special occasions, employees may nonetheless receive gifts of limited value. Internal gifts are covered by separate regulations. Gifts given on behalf of SP are to be moderate and not exceed the value that we are allowed to receive. It must be impossible to doubt SP’s motives and the recipient’s integrity. No one may give gifts or other benefits on behalf of SP with the aim of achieving a return service for his/ her own benefit.

F. Related Parties

Related parties (spouses, partners or other close family relations) may not have jobs in which one of them is the other’s direct superior or where the jobs are incompatible in some other way.

G. Impartiality

No one may take part in dealing with or deciding on an issue when circumstances exist that may weaken the confidence in this person’s independence. In such cases, no influence may be exerted over others in SP either.

H. Secondary jobs and involvement in other companies and organisations

No employees may without the employer’s consent work or have directorships in, run or have considerable interests in an enterprise that has the same type of operations as SP or a business relationship to SP.

I. “Inside” information

Inside information is information that may affect the price of securities and which is not publicly available or generally known in the market. No employee is to use or contribute to others using, inside information on other companies as a basis for trading in securities. This applies both privately and on behalf of SP.

J. Information and IT systems

No one may actively seek information on other employees or clients via internal computer systems unless this is necessary for his/her work in SP.

K. Whistleblowing

Whistleblowing is the reporting of improper conduct to someone who can do something about it.

8. Sanctions for violations

SP acknowledges that the overwhelming majority of employees are honest, hardworking, and in no need of a policy to explain good and proper business conduct. Nevertheless, we do need a policy for clarity and any company policy needs to be accompanied by sanctions if it is violated. The overall aim of applying sanctions is fairness and transparency. Where violations occur the local legal authorities may take appropriate action, including criminal sanctions. Decisions as to sanctions will follow an appropriate process which may include involvement by the board, and which in any event complies with all applicable employment laws, etc.

The severity of the sanction will be decided based on if the situation is gross negligence or accidental/no damage. Gross or willful negligence is where the business or the business reputation could be materially damaged and employee dismissal and a report to the authorities may be called for. When any simple or accidental ethical violation resulting from, for example, conflicting policies, standard operating procedures, or recent changes in law etc. sanctions range from recorded reprimand to verbal warning.