Code of conduct
The Code is not exhaustive, and more detailed requirements may apply to your position, business unit, and depending on in which country you work. If you are in doubt about any of the terms used in the Code, or the specific requirements related to your position, please ask your manager.
Breaching the Code may have financial and reputational consequences for the Wilhelmsen group. It may also result in disciplinary action being taken against you and, in serious cases, dismissal and/or court action. It is therefore important that you familiarise yourself with the Code and live by it in your daily work. If you experience others breaching the Code, you should raise it with your manager or report it through our whistleblowing channel.
Combined with our vision, values, leadership expectations, Owner’s statement, and policies, and standards, this Code forms the foundational elements of the Wilhelmsen group’s governing elements.
If you face a challenge, always remember to ask yourself whether it is right, legal, and ethical, and that you can stand behind your actions if being challenged. Together #WeAreWilhelmsen and together we shape the maritime industry!
1. COMPLIANCE WITH THE LAW
As a group, we comply with the laws and regulations of the countries in which we operate.
You should not let any sense of loyalty or desire for personal gains make you or any member of the Wilhelmsen group violate applicable laws, our governing elements or policies and standards implemented by the group or your business unit.
You must conduct annual mandatory training related to this Code and other governing elements.
All our governing documents can be found in our global governance and quality management system (GIMS) and it is your responsibility to familiarise yourself with relevant documents.
2. FAIR AND ETHICAL COMPETITION
We protect the interests of our customers and other stakeholders by conducting our business in a fair and ethical manner, and in accordance with applicable competition law.
We also comply with economic sanctions and trade restriction regulations, and we do not engage in any money laundering activities.
We expect you comply with the same standards.
You may participate in trade associations, industry conferences and seminars where competitors meet, but you should not engage in any formal or informal arrangements which could restrict fair and healthy competition. This includes engaging in price fixing or improper sharing of information, bid rigging, agreements to limit production or capacity, agreements to exclude other competitors from the market and/or abusing a dominant position.
3. CORRUPTION AND BRIBERY
Bribery is the acceptance, offering, solicitation or promise of benefits, monetary or in kind, to gain business advantages to which we would otherwise not be entitled. Bribery is illegal worldwide. We have zero-tolerance towards bribery, and we are committed to comply with laws prohibiting bribery.
Facilitation payments are regrettably still a practice in a few countries, and we are committed to working towards eliminating this practice. A facilitation payment is a small payment made to secure or expedite a routine action. Where payments are requested from third parties, a valid receipt to document the transaction must be obtained. If no such receipt is provided, details of the payment must be logged in line with the reporting processes implemented by your business unit.
You should not offer or accept monetary benefits or gifts to achieve business advantages which we would not otherwise be entitled to. If you receive such offers, you must question why these offers are being made and if anything is expected in return. All offerings of any significance must be disclosed and pre-approved by your manager.
4. THEFT AND FRAUD
We have zero-tolerance towards theft and fraud.
We expect you to act diligently and loyally towards the Wilhelmsen group’s interests, values, and policies in all transactions carried out on behalf of the Wilhelmsen group.
5. WORKING ENVIRONMENT
We are committed to providing safe, healthy, and decent working conditions where we all feel included and valued. Harassment, bullying, discrimination, or any other behaviour that may be seen as threatening or degrading is not acceptable. This includes discrimination on the grounds of race, gender, sexual preference, religion, or any other grounds.
Lack of respect for basic human and labour rights is not acceptable. We therefore expect you to treat others with respect, contribute to a fair and inclusive workplace, and act responsibly to prevent incidents to ensure we provide a workplace where we all feel physically and psychologically safe.
6. DRUGS AND ALCOHOL
Possession or use of any substance prohibited by law is not tolerated while on duty or representing Wilhelmsen.
Consumption of alcohol in the workplace is not allowed except where it is acceptable in moderate amounts, appropriate under the circumstance, and complies with local customs and applicable laws.
7. CONFLICTS OF INTEREST
You cannot engage in activities, hold, trade in assets, or engage in relationships that involve, or might appear to involve, a conflict between your personal interests and those of the Wilhelmsen group. Such conflicts of interest could impact our ability to make correct business decisions. If in doubt, the situation should be transparently discussed with your manager and/or your HR manager.
8. TRAVEL
All travel arrangements must be pre-approved by your manager.
When attending internal business functions, it is the most senior level employee from the hosting business unit who is responsible for paying for entertainment.
9. EXTERNAL ENGAGEMENTS
You must obtain approval from relevant manager(s) before engaging in external board memberships, external business enterprises, statutory authorities, or similar bodies which may have commercial relations to the Wilhelmsen group.
The Wilhelmsen group’s reputation can be affected by what we all say, do, and share in public, both positively and negatively. In addition, we have listed companies in the Wilhelmsen group, and they are bound by regulations regarding news that could potentially affect the trading of their shares.
When you participate in external activities or on a channel/platform (for example social media like LinkedIn or X) on behalf of, or identifiable as an employee of Wilhelmsen, any opinions expressed should be in line with Wilhelmsen group’s interests and relevant guidelines.
10. PROTECTING THE ENVIRONMENT
We act responsibly to minimise the environmental impact of our operations in relationships with customers and suppliers. We equally expect you to contribute to reducing the environmental footprint in your daily job.
11. CYBER SECURITY
Passwords and company assets (for example your PC and mobile phone) are to be handled in a professional and secure way. Taking this approach will help us minimise the risk of cyber-attacks and avoid important data and IT systems being lost, stolen, or accessed by third parties. The group cyber policy, including acceptable use of our IT resources and systems, is mandatory to follow. We expect you to protect your passwords, are careful when surfing or downloading software from the internet and/or when sharing documents and information with others.
Annual cyber training is mandatory for all employees, and we will conduct regular campaigns to ensure we have a vigilant and cyber focused culture.
We are committed to promoting responsible AI practices, protecting data privacy, maintaining security, and conducting operations in a responsible, ethical, and sustainable way, reflecting our commitment to data integrity.
12. HUMAN RIGHTS
We are committed to safeguarding the rights of individuals set out in the UN Universal Declaration of Human Rights, the International Labour Standards, and prohibiting any form of modern slavery, including human trafficking, forced labour, exploitative working conditions and practices, slavery, and child labour. We expect the same commitment from you in your daily operations.
13. CONFIDENTIAL INFORMATION AND PERSONAL DATA PROTECTION
We expect you to maintain and safeguard the confidentiality of our business data. It should only be shared on a “need to know” basis and with appropriate safeguards in place (e.g. confidentiality agreements).
Where we are dealing with personal data, you are required to comply with the policies, procedures and binding corporate rules that we implement to comply with laws relating to the protection of personal data.
No information that may affect the price of the shares in the listed entities in the group may be used to trade, or influence others to trade, in the shares. If you are unclear on what this means, please contact your manager.
14. WHISTLEBLOWING
We are committed to taking proper action if suspicion of evidence of breaching laws and regulations, our Code and/or our policies and standards are brought to our attention. You and external stakeholders are therefore encouraged and expected to report any suspicious actions using our whistleblowing channel to ensure professional handling.
If you reach out, we are equally committed to safeguard your confidentiality and ensure your identity is not disclosed.
When information is provided, the reported matter will be investigated and proper mitigation actions executed as applicable. Regardless of the outcome of the case that you tell us about in good faith, you will not be disadvantaged in any way.
This Code of Conduct was approved by the Group Management Team and the board of Wilh. Wilhelmsen Holding and is applicable from 1 October 2025.
Thomas Wilhelmsen
Group CEO