|Customer and market confidence in ethical business culture
|Non-compliance events with security, reputational and/or financial consequences
|Healthy partnerships with serious actors
|Operational or supply chain disruption
|Higher employee engagement as a responsible employer
|Business dealings in high governance risk countries
The industry we are operating in is exposed to several risks. To mitigate risks and prevent and mitigate unethical business practise, we have a governance system in place including policies, audits, risk assessments, and reporting. We also have an external and internal whistleblowing channel and perform continuous awareness training to ensure our employees understand our expectations.
Our policies on ethics and anti-corruption are clear. We do not tolerate corruption in any form, and we expect all employees to match the high ethical standards we've outlined in our governing documents and Code of Conduct. Our work with business standards is continuous, and our various stakeholders rely on us as a transparent and compliant partner.
Principles guiding our anti-corruption efforts
We follow internationally recognised guidelines in our anti-corruption work, such as the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act 2010. The six principles outlined below form the basis of our anti-corruption efforts.
Top-level commitment: We have a clearly articulated policy against corruption. Our group management team constantly communicate their commitment towards zero tolerance for any kind of corrupt activities throughout the organisation. The management team has the full support and encouragement from the board.
Proportionate procedures: Our anti-corruption measures are proportionate to the variation in risk we have across our diversified organisation and the various parts of the world where we operate.
Risk assessment: Corruption risk assessments are carried out in all our business areas, identifying whether we face a high, medium or low risk. The risk varies, depending on geographical location and the nature of the business we conduct
Communication (including training): We constantly communicate the anti-corruption policy in order to make sure that our policy is understood throughout the organisation. Anti-corruption training is compulsory for all employees.
Due diligence: We conduct due diligence of business partners where appropriate and in a variety of forms. The comprehensiveness of the due diligence conducted is proportionate to the risks. We utilise licensed screening systems to conduct due diligence in-house and, if necessary, source from third party consultants.
Monitoring and review: We acknowledge that monitoring, reviewing and reporting is challenging, yet essential to ensure effective implementation. The board of Wilhelmsen as well as the group management team receive and review anti-corruption reports. To ensure our data are accurate, we have a number of reporting initiatives including a whistleblowing channel, giving all employees and external stakeholders the opportunity to anonymously report irregularities, thorough investigation of complaints, audits of risk exposed areas of operation, and third party verification of our anti-corruption procedures. All potential breaches are handled according to our routines and regulatory framework.
Expectations to operate with the same ambitious standards on ethics and compliance are clearly conveyed through board members of the respective companies. In addition, we actively share our policies and best practice documents with these companies with the aim of moving towards alignment of anti-corruption standards and practices.
Supply chain management
We are committed to doing business with responsible suppliers. We need to ensure our ESG expectations are clear to suppliers and that products and services are compliant with our standards.
Our objective is to actively manage and encourage suppliers to meet governance standards including decent employment conditions for their employees and responsible stewardship for the environment.
In their vetting, contracting and audit and review processes, entities place clear responsibilities on suppliers to comply with minimum requirements including but not limited to:
- Preventive measures of financial fraud
- Sanctions and compliance
- Quality management systems and accreditation
- Environmental management and impact
- Business ethics and code of conduct
- Human rights, harassment and discrimination
- Supporting the UN Convention on the rights of the child
- Health and safety
- Cybersecurity precautions
We include environmental, social, and governance (ESG) issues in our investment analysis, business decisions, ownership practises, and financial reporting. Our policy is to secure that there are clear expectations to portfolio companies to manage risk and exposure and implement a systematic approach to ESG. As an active owner, we have expressed expectations to companies where we have equity investments to reduce environmental impact; contribute to promote human rights, sound working standards; and work towards eliminating corruption in own operations and investments, as well as the operations of suppliers and business partners. We have also expressed expectations and support for those companies to invest in green growth and to take an active role in the decarbonisation of the maritime and logistics sector.
Management and the Board assess investment risks and opportunities related to equity investments under different scenarios on an annual basis. Information and interactions with relevant personnel at these companies inform this evaluation. We participate in investor meetings with these companies as an opportunity to address expectations, strategy and ESG matters. In response to the rapidly developing focus on ESG issues, we are developing a detailed ownership requirements statement to clarify our expectations towards companies where we have a significant shareholding.