Code of Conduct
Explaining the Code of Conduct
This Code applies to all Quistor companies and its employees world-wide. Any non-adherence to this Code will require the instant notification to the Management Board. The Management Board will not hold management accountable for any loss of business resulting from compliance with this Code of Conduct and will see to it that no employee suffers as a consequence of reporting a breach, or suspected breach, of this code.
Employees are urged to report suspected irregularities internally to their manager or, if they consider reporting to their manager inappropriate, to their superior manager or if they consider reporting to the superior manager inappropriate, to the local Trusted Person. Employees who wish to file a report can also send an email to the Local Trusted person. The report will be handled by this Trusted Person.
1. Free enterprise and fair competition
Quistor believes in fair and open competition in compliance with national and international competition laws and regulations. Whenever national laws and regulations are found to be less strict, international laws are leading and vice versa. These laws and regulations are numerous and often complex, hence, Quistor provides timely guidance and support to employees to ensure that they continue to understand competition laws and apply them correctly.
2. Legal compliance
Quistor companies are required to both comply with the laws and regulations of the countries in which they operate and international laws and regulations. Whenever the national laws and regulations are found to be less strict, international laws are leading and vice versa.
Consequently, these laws and regulations are numerous and often complex. Whenever any question arises, employees should seek guidance on these requirements from their superior or the company’s legal department. In case an employee violates any law and/or regulation or is (possibly) involved in any irregularity, including fraud, such irregularity should be instantly notified to the Chief Operating Officer, which employs him, and the Chief Financial Officer in accordance with Quistor’s internal Irregularity & Fraud Reporting Procedures.
3. Business integrity
Quistor conducts its business with integrity, honesty and fairness, with due respect for the interests of those with whom it is doing business and for the community at large. Integrity is essential to Quistor’s business and cannot and should not in any Code of conduct 5
circumstances to be sacrificed for the sake of results or otherwise. These principles are embedded in The Quistor Values
3.1 Bribery and corruption
In dealing with customers, contractors, consultants, suppliers or any other external party, which may include governmental bodies, Quistor stipulates that its managers and employees neither give nor receive bribes or anything of value in order to retain or bestow business, financial or personal advantages. Quistor employees are directed that any demand for or offer of such bribe or anything of value must be immediately rejected and
reported.
3.2 Conflicts of interest
Quistor employees are expected to avoid all situations in which their personal or financial interests may conflict with the company’s interest or interfere with effective job performance.
Quistor accepts the concept of its employees to have private financial and/or business interests outside their professional activities with Quistor. However, to the extent these interests may have directly or indirectly an interface with activities of Quistor companies, it invites these employees to report such interests to their superiors or the person designated by the Management Board, to keep a record thereof.
3.3 Gifts and business entertainments
The giving of small business gifts to individuals should be decided on in consultation with the superior of the donating employee on the basis of local business practice and regulations. Gifts of a total value of up to EUR 100 (or the equivalent in local currency), in any one year would in most cases not cause a conflict or give the appearance of causing a conflict. An employee must declare to his or her immediate superiors, details of any gifts received from customers, contractors, consultants, suppliers or any other external party, and shall not retain such gifts without the consent of his or her superior
3.4 Securities transactions & insider trading
Quistor employees may become aware of information about Quistor or other companies that has not been made public. The use of such non-public or “inside” information is unethical and may also be a violation of law. Employees must not engage in ‘insider trading’ in Quistor Securities based on confidential Quistor or other companies information or give information to anyone who might trade on the basis of such information. Quistor employees should adhere to the relevant companies’ securities.
3.5 Public activities
Quistor does not participate in party politics nor makes payments or donations in kind to political parties or to the funds of groups whose activities are directed at promoting party Code of conduct 6 interests. When dealing with governments or other (governmental) agencies Quistor companies are encouraged to promote and defend their legitimate commercial objectives. They may do so directly or through bodies such as trade associations. Quistor companies are encouraged to respond to requests from governments and other agencies including NGOs (Non-Governmental Organizations) for information, observations or opinions on issues relevant to their business and to participate in the development of proposed legislation or regulations in areas which may have an effect on their legitimate interests.
3.6 Drugs, alcohol and weapons
It is the policy of Quistor and its subsidiaries to maintain a work environment at its terminals that is safe for employees and conducive to attaining high work and ethical standards. This statement is to notify and remind all employees and employees of contractors and other companies having access to a Quistor location, that possession or use of intoxicating beverages, firearms or weapons, drugs and narcotics are not permitted on any Quistor location.
3.7 Money laundering
Quistor or its employees will make sure not to cooperate, be it directly or indirectly, in money laundering. In case a Quistor employee finds a certain financial transaction suspicious, the employee should seek guidance from his or her (superior)manager and/or the company’s legal department. Quistor provides timely guidance and support to employees to ensure that they continue to understand money laundering and how to react to it.
3.8 Working with suppliers and contractors
Quistor companies are required to retain suppliers and (sub)contractors on the basis of the qualifications and abilities needed for the work to be performed, including their reputation, safety performance and reliability, and to see to it that these suppliers and contractors apply the same ethical business principles as applied by Quistor. We expect our suppliers and contractors with whom we do business to uphold the same standards
and we use our best endeavors to ensure compliance with these standards, which are reflected in this Code of Conduct and the Quistor Values.
3.9 Payments to agents/intermediaries
Payments to be made to agents or other intermediaries in connection with the awarding of contracts by customers and closures, agreements and settlements by 3rd parties should be measured against the services performed in return and should be cleared in advance with the member of the Management Board having prime responsibility for the activity
3.10 Presence in high risk countries
Quistor has activities in numerous countries. Potentially this includes countries where there is a risk that counterparties are not always acting in line with this Code of Conduct. Quistor will enforce its Code of Conduct within its sphere of influence to the full extent.
We believe our activities provide opportunities to improve the living standards and welfare of the communities in which we operate. We will support fundamental human rights as included in the UN Universal Declaration of Human Rights. Quistor business units must comply with economic sanctions imposed by the UN. If as a consequence it would be necessary to leave a certain country, the conditions and timeframe of withdrawal from such a country will be determined by the Management Board. In exceptional cases, the Management Board might decide that our presence in a high-risk country remains justified for the good of the local community.
3.11 Security
Quistor conducts its activities with the utmost precaution in order to safeguard its employees, the community it works in and the environment. Security measures and training for employees are continuously monitored and adjusted to the current needs.
3.12 Protection of personal data
Quistor respects any individual’s general right to privacy of their personal data and adheres to all applicable laws on the use of personal data.
3.13 Dress code
Quistor’s official dress code is smart casual. If employees frequently meet with clients or prospects, they should conform to a business dress code. When an employee disregards our dress code, their supervisor should reprimand them. The employee should start respecting our dress code immediately. In some cases, supervisors may ask employees to returning home to change.
4. Communication
4.1 Reporting
Quistor recognizes that, in view of the company’s scope of activities, proper communication on its activities is essential. Quistor will report honestly, factual and timely (within confidentiality restraints) about the impact of our activities on stakeholders, society and environment, and how we aim to improve our social and environmental performance.
4.2 Accountability
All business transactions shall be accurately and completely recorded in accordance with the company’s accounting principles (including, but not limited to, International Financial Code of conduct 8 Reporting Standards (IFRS). Quistor accounting and operational records and supporting
documents must accurately describe and reflect the nature of the transactions and shall be subject to independent external audits. Undisclosed or unrecorded accounts, funds or assets will not be maintained or established.
5. Sustainability
Quistor is committed to conduct its operations in an environmentally sound and sustainable manner and aims at continually improving its environmental performance. Quistor has established procedures and compliance programs to ensure the minimum
adverse impact on the environment. Such procedures and programs are periodically being reviewed and appraised. Quistor considers safe and healthy working conditions for its employees to be fundamental and a pre-requisite. To achieve protection of the health and safety of employees, customers and the public, Quistor has established procedures and compliance programs. Such procedures and programs are periodically being reviewed
and appraised. It is the responsibility of each employee to comply with health and safety regulations according to the local country legislation and company guidelines. Quistor seeks to extend its concern for health, safety and the environment to its suppliers, contractors and customers.
6. Employees
Quistor subscribes to the United Declaration of Human Rights, the Organization for Economic Cooperation and Development (OECD Guidelines for Multinational Enterprises and the fundamental International Labour Organization’s conventions regarding forced labour, child labour, non-discrimination, freedom of association and collective bargaining.
6.1 Child labour & forced labour
Quistor adheres to the legal minimum age requirements in all countries in which the company is active. Quistor does not employ children under the age of 16. Quistor will under no circumstances make use of forced labour. No employee is required to lodge deposits, and no individual will be deprived of identity papers upon commencing employment with the company. Local business management is responsible to comply with the Quistor standards
regarding child labour and forced labour and let that be known to key suppliers and contractors.
6.2 Non-discrimination and equal opportunity
Quistor companies recruit, employ and promote employees on the sole basis of their qualifications and abilities (including reputation and reliability). Quistor endeavors to enable each individual to develop its talents in various ways, e.g. by offering training programs. It is the policy of Quistor to ensure equal employment opportunity without discrimination or harassment based on race, colour, national origin, religion, sex, age, trade union membership or any other characteristic protected by law (either local, national or international law). Quistor prohibits and will not tolerate any such discrimination or harassment. Quistor and its subsidiaries are committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices. Quistor expects that all relationships among persons in the workplace will be business-like and free of bias, prejudice and harassment.
6.3 Right to organize & collective bargaining
Quistor recognizes the freedom of employees to establish or join an organization of their choice (including trade unions) and will respect this right. We will not make employment of an employee subject to the condition that he/she must or should not join a union or must accept or relinquish trade union membership. Quistor respects, within the framework of applicable laws, regulations, prevailing labour relations and employment practices, the right of employees to be represented by staff representatives, trade unions and other employee organizations.
7. Community
Quistor supports activities that improve the lives of people in communities in which our employees live and work. These activities may include education, health care, community building, infrastructure or nature development. Employees are encouraged to actively participate in community programs, and to propose projects to site management. Quistor companies are expected to give their employees the opportunity to play an
active role in society, for example through community or educational programs, unless participation in these activities creates a conflict of interest.
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