Trading Policies

Ethical and Environmental Code of Conduct for Suppliers of Goods and Services

Introduction

At Sea Capital we are passionate about everybody getting a fair deal. Based on this, Sea Capital have developed a Supplier Code of Conduct that is applicable throughout our organisation and we expect everyone with whom we have commercial dealings to support these basic principles:

• To have a natural respect for our ethical standards in the context of their own particular culture.
• To extend the same principle of fair and honest dealings to all others with whom they do business, including employees, sub-contractors and other third parties.
• To implement the standards of this policy on their own supply chain.

Sustainability continues to evolve as the understanding of our impacts on the environment and society at large. Sea Capital will periodically review this Code and make revisions when needed, which we will expect suppliers to adopt.

Monitoring

Suppliers with whom we have regular and recurring dealings should have management processes in place to ensure compliance with this Code. Furthermore, suppliers must make reasonable efforts to monitor and ensure that their supply chain is aware of and compliant with the aims of the Code to reduce possible negative attention to the Sea Capital Brand.

Sea Capital reserves the right to randomly review the supplier's policies, procedures or any other document related to the Sea Capital Code of Conduct. In some cases, Sea Capital may require an on-site audit of a supplier's adherence to this Code.

Non-Compliance

To be in full compliance, a supplier must meet all provisions of the Code. Some provisions are required and are indicated by the term 'must'. For those provisions where we have more initial flexibility (as indicated by the term 'should'), Sea Capital requires a development plan be created outlining a timeline for the supplier to come into full compliance.

At all times, our goal is to work with our supply partners on sustainability. In those cases where a supplier or one of its subcontractors is found to be out of compliance with the Code, Sea Capital will work with the supplier on an improvement plan. However, if the issue is serious enough or cannot be resolved in a reasonable time frame, Sea Capital may take steps to review the terms of the contract, including order reduction or cancellation.

The Code

Economic

Economic sustainability focuses upon generating profits and bringing economic benefit to the workers, investors and communities in which a company operates. From an ethical perspective, it is Sea Capital's belief that commercial transactions should be economically beneficial to all parties involved and relationships should be based on the principle of fair and honest dealings.

1. Suppliers must embed basic business principles in a Code of Business Standards or a similar policy, including such items as adherence to local laws and a stand against bribery and corruption.
2. Suppliers should have reasonable payment policies with their own suppliers and subcontractors.

Environmental

Recognising that sustainable business requires recognition of the planet's limited resources, Sea Capital expects its suppliers to support the company's goals around environmental issues.

1. Suppliers must have a written environmental policy appropriate to the size and nature of the supplier's operations that, in its fullest form, addresses CO2 emissions, waste, energy, and wood & paper management.
2. Suppliers should have an effective internal environmental management programme with an adequately trained staff person who, ideally, is able to provide data around key environmental indicators.
3. Suppliers must abide by all legislation and regulations related to the protection of the environment and the handling of dangerous and hazardous materials.
4. Suppliers must keep dangerous and/or Hazardous Materials to a minimum and make Material Safety Data Sheets available for all hazardous materials that are necessary.
5. Suppliers should work actively to improve the environment in the communities in which they operate and pursue initiatives to bring about such improvement

Social

Sea Capital expects suppliers to respect the human rights of their employees and to comply with all relevant legislation, regulations and directives in the countries and communities in which they operate:

Employment Conditions

1. Suppliers must prohibit the use of forced labour and give workers, whether local or migrant, the right and the ability to leave employment when they choose.
2. Suppliers must ensure that child labour is not used and that the employment of young workers adheres to local regulations.
3. Suppliers must ensure that wages meet legally mandated minimums and industry standards without unauthorised deductions.
4. Suppliers should ensure that working hours are in accordance with local regulation and industry practice and voluntary overtime is at manageable levels.
5. Suppliers must treat all employees fairly and not discriminate against any group in its employment practices.
6. Suppliers must not hinder the right of workers to legally organise and join associations such as labour unions.
7. Suppliers should provide clear and uniformly applied disciplinary practices and grievance procedures that include provisions prohibiting mental, physical or verbal abuse.
8. Suppliers must provide a safe work environment, abiding by local laws and regulations, and respecting the health and well-being of its workforce.

Community

1. Suppliers must respect the human rights of the communities in which they operate.
2. Suppliers should strive to improve the communities in which they operate.