ALL THE WAY
A.P. MOLLER - MAERSK
SUPPLIER CODE OF CONDUCT
Responsible
				way of doing
  business
Content
    MESSAGE FROM THE CEO       _____________________________________________________ 3
    OUR MAERSK VALUES _________________________________________________________ 4
    INTRODUCTION _______________________________________________________________ 5
    IMPLEMENTATION ____________________________________________________________ 6
    REPORTING CONCERNS       _______________________________________________________   7
    SUPPLIER CODE OF CONDUCT __________________________________________________ 8
         Business ethics
         Health and safety
         Environment
         Working conditions and employment practices
    GLOSSARY ___________________________________________________________________ 14
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A.P. Moller - Maersk Supplier Code of Conduct                            Message from the CEO   Our Maersk Values
                           Message
                           		 from the CEO
                           Dear valued suppliers,
                                   At A.P. Moller - Maersk, our deeply rooted values drive       Human Rights, ISO standards on HSE and the core labour
                           the way we do business and we live by them each day. These            conventions of the International Labour Organisation (ILO).
                           values reflect our commitment to sustainable development                     We require our suppliers to commit and act in
                           and guide us in conducting our business in an ethical and             accordance with the requirements under this Code and
                           upright manner.                                                       extend similar standards to their supply chain partners. Our
                                   Our suppliers play a vital role in the way we conduct our     procurement practices are designed to work collaboratively
                           business and deliver value to our stakeholders. As responsible        with our suppliers through a continuous improvement
                           corporate citizens, we endeavour to work with suppliers who           approach and support them to meet our requirements.
                           share a similar commitment to responsible business practices.         By working together with our suppliers, we can provide
                           Through this Supplier Code of Conduct, we communicate                 sustainable solutions to our customers and embed
                           the minimum requirements that we expect our suppliers                 sustainability in supply chains as well as the wider transport
                           to follow while conducting business in an ethical, social and         and logistics industry.
                           environmentally responsible manner. These requirements                       As a valued supplier of A.P. Moller - Maersk, I count
                           are based on the United Nations Universal Declaration of              on your commitment and support to continuously adopt and
                                                                                                 promote responsible business practices. I also encourage you
                                                                                                 to go beyond compliance and strive for higher standards of
“Our suppliers play a vital role
                                                                                                 sustainability.
in the way we conduct our                                                                        Sincerely,
business and deliver value to our
stakeholders.”                                                                                   Vincent Clerc
                                                                                                 CEO of A.P. Moller - Maersk
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A.P. Moller - Maersk Supplier Code of Conduct          Message from the CEO   Our Maersk Values
                           Our Maersk Values
                           At A.P. Moller - Maersk (Maersk), we have a distinctive set of 5 Core Values which drive the way we do business.
                           The Values were ingrained into our operations by our founders and have remained guiding principles, governing the development of Maersk
                           for over a century.
                           In today’s world of rapidly evolving economic and market conditions, the Values interplay with present time and remain key to ensuring we
                           grow for the future in a sustainable way.
                           CONSTANT CARE                  HUMBLENESS                              UPRIGHTNESS             OUR EMPLOYEES             OUR NAME
                           Take care of today,            Listen, learn, share,                   Our word is our bond.   The right                 Sum of how we live
                           actively prepare for           give space to others.                                           environment for the       the Values and how
                           tomorrow.                                                                                      right people.             we are perceived.
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A.P. Moller - Maersk Supplier Code of Conduct
Introduction
The A.P. Moller - Maersk Supplier Code of Conduct (hereinafter referred to as ‘Code’) sets out minimum
requirements for our direct suppliers and select sub-suppliers as decided by us (hereinafter referred to
as suppliers) to operate in accordance with responsible business principles detailed in this Code and in
full compliance with all applicable laws and regulations. Where the standards in this Code differ from
local and national laws as well as international standards, we expect our suppliers to apply the stricter
standard. In the event of standards in this Code conflicting with local and national laws as well as
international standards, we encourage our suppliers to address such conflicts to us in order to jointly
establish the most appropriate course of action.
This Code reflects our commitment to the United Nations Global Compact (UNGC) and our respect
for universally recognised normative standards such as the United Nations Universal Declaration of
Human Rights, ISO standards on HSE and the core labour conventions of the International Labour
Organisation (ILO).
In the case of business relationships such as non-controlled joint ventures, alliance partners,
vessel sharing partners etc., we endeavour to engage with such business partners to influence
the implementation of principles and standards of this Code or similar internationally recognised
standards towards mitigating sustainability risks in supply chains.
Our suppliers are also required to implement the principles and standards of this Code or similar
internationally recognised standards to their own business partners, including suppliers, contractors
and joint venture partners.
More guidance on successful implementation of principles and standards mentioned in this Code and
other relevant resources are available on our website https://www.maersk.com/procurement/what-
we-expect-of-suppliers
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A.P. MOLLER - MAERSK SUPPLIER CODE OF CONDUCT
Implementation
Our suppliers are required to acknowledge and commit to the adherence of responsible business principles of the Code. We
assess our suppliers’ compliance with the Code through a combination of audits, self-assessments and documentation reviews
through our Sustainable Procurement Programme. Suppliers should address any gaps in the implementation of this Code by
establishing and implementing a time-bound improvement plan in consultation with Maersk. Periodic reviews and follow-up
audits as per our internal risk procedures are conducted to monitor the compliance levels.
We expect and encourage our suppliers to develop and implement relevant management systems, appropriate for
a company of their size and industry to ensure compliance with applicable laws and regulations and the requirements of
the Code.
The underlying objective of this Code is to establish a basis for positive development of sustainable procurement practices
through regular dialogues and ongoing working relationships. However, in the incident of severe violations of the Code, we
reserve the right to take actions including and up to termination of contracts.
A.P. MOLLER - MAERSK SUPPLIER CODE OF CONDUCT
Reporting
			concerns
We expect our suppliers to have a reporting system to ensure that employees can voice grievances anonymously and
without fear of reprisals on any aspect of this Code. All grievances should be investigated in a fair and timely manner.
We also welcome concerns from anyone within or outside of Maersk if they suspect or know of any potential or actual
violations of this Code. We do not tolerate retaliation against persons making reports in good faith.
You can report concerns through the channel you are most comfortable with, such as Maersk representatives or
relationship partners, any member of management, or through the Maersk Whistleblower system. The Whistleblower
system is administered by an independent company (NAVEX Global) and is available 24 hours a day, 7 days a week. It can
accommodate calls in more than 75 languages and offers the ability to submit a report anonymously.
Reporting a concern online – please visit www.maersk.ethicspoint.com.
Reporting a concern by phone - please contact the international phone number at +1 866 307 5672 (i. e. available from
most countries, charges may apply) or refer to www.maersk.ethicspoint.com for toll free numbers for your country.
A.P. MOLLER - MAERSK
Supplier Code
		 of Conduct
— Business ethics
— Health and safety
— Environment
— Working conditions and employment practices
A.P. Moller - Maersk Supplier Code of Conduct                      Business ethics   Health & safety   Environment   Working conditions & employment practices
Business
  			 ethics
We require our suppliers to conduct their business by adopting the highest standards of ethical
behaviour. Suppliers should:
•   avoid participation in or knowingly benefit from, any kind of corruption, extortion or bribery;
•   adhere to applicable anti-corruption and anti-bribery laws, directives and regulations that govern
    operations in the countries in which they operate;
•   avoid facilitation payments and work towards eliminating it;
•   adhere to anti-trust and other competition laws;
•   disclose any potential or actual conflict of interest to Maersk;
•   adhere to national and international foreign trade control laws pertaining to business transactions
    with countries, companies and persons (sanctions), and the transfer of goods and services, software
    or technology between countries (export controls).
•   exercise quality and sustainability due diligence when designing, manufacturing, and testing
    products;
•   adhere to data privacy laws and comply to contractual requirements on confidentiality and
    information security.
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A.P. Moller - Maersk Supplier Code of Conduct                    Business ethics   Health & safety    Environment   Working conditions & employment practices
Health
			and safety
We require our suppliers to provide a safe, secure and healthy working environment for all of their
workforce. Suppliers should:
•    develop and implement effective health and safety management systems with worker participation
     in the safety committees;
•    ensure that safety management systems support identifying risks, measuring and monitoring
     performance, and driving continual improvements to mitigate or minimise health and safety risks
     emanating from its operations;
•    ensure compliance with applicable laws, regulations and customer requirements;
•    ensure protection of their workforce by providing basic personal protective equipment appropriate
     to the nature of work and relevant training on health and safety systems;
•    empower workers to report unsafe practices without fear of reprisal;
•    commit to proactively undertake safety initiatives to protect people and assets from harm and
     damage.
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A.P. Moller - Maersk Supplier Code of Conduct                    Business ethics   Health & safety   Environment   Working conditions & employment practices
Environment
We require our suppliers to integrate environmental considerations in their operations and strive
for continuous improvements to mitigate or minimise any adverse impacts on the environment.
Suppliers should:
•    comply with all relevant local and national environmental laws as well as international standards,
     obtain and maintain all the necessary environmental permits, approvals and registrations;
•    develop and implement effective environmental management systems that support identifying
     risks, measuring and monitoring performance, and driving continual improvements to mitigate or
     minimise environmental impacts emanating from its operations;
•    develop a precautionary principle approach and promote environmentally friendly technologies and
     processes in their own operations and across the supply chain;
•    commit to proactively undertake initiatives to protect the environment from harm and degradation
     in relation to their operations.
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A.P. Moller - Maersk Supplier Code of Conduct                     Business ethics   Health & safety   Environment   Working conditions & employment practices
Working
		conditions &
employment
								practices
We are committed to creating and sustaining a working environment where workers are treated with
dignity and respect. We require our suppliers to also adopt and enforce similar workplace practices.
Where local laws dictate any additional requirements, those will be applicable along with the
requirements mentioned below.
Suppliers should respect and adhere to internationally recognised labour and human rights
standards as defined in the principles of the United Nations Global Compact. Suppliers should:
•    respect all applicable laws, regulations and international standards related to labour practices and
     protection of human rights;
•    ensure equal treatment and refrain from discrimination of any form, including on grounds that are
     prohibited in national laws and international standards;
•    commit to a workplace free of harassment and abuse, and not use, or permit the use of, corporal
     punishment or other forms of mental or physical coercion, sexual harassment or abuse, nor execute
     threats of such treatment;
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A.P. Moller - Maersk Supplier Code of Conduct                      Business ethics   Health & safety   Environment   Working conditions & employment practices
•    establish fair disciplinary, grievance and termination procedures;
•    not employ workers below the age of 15 years or below the age of 16 for work at sea or the locally
     applicable minimum legal age, whichever is more stringent;
•    ensure that employees, including trainees, under the age of 18 do not undertake night-shift
     work or work overtime or carry out work that is hazardous or harmful to their physical or mental
     development;
•    not use or benefit from any kind of forced or involuntary labour and prohibit the use of
     recruitments fees, deposits, including by recruitment agencies, or other practices that may prevent
     employees from freely ending their employment;
•    take extra precautions to respect the rights and wellbeing of migrant workers whose rights may be
     at risk or who may lack access to basic public services;
•    respect the rights of their employees to associate freely, join or not join trade unions and/
     or workers’ councils, and engage in collective bargaining in accordance with national laws and
     international conventions;
•    ensure employment terms are clearly understood by workers and are explained verbally or provided
     in a written contract in a language they understand, as per local regulations and aligned to the
     provisions of this Code as a minimum;
•    comply with appropriate working hour requirements including overtime, breaks, and rest periods –
     as established by national law, relevant collective agreements and international standards;
•    adhere to relevant national laws, industry standards and international standards relating to
     minimum wages; overtime wages, and legally mandated benefits;
•    adhere to relevant national laws, industry standards and international standards for paid sick leave,
     paid annual leave and paid parental leave;
•    ensure that security guards operating at suppliers’ premises act in accordance with universally
     recognised human rights standards including guidelines on the use of force;
•    ensure collection and further processing of employees’ personal data are done in compliance with
     the applicable data privacy legislation and best practices.
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A.P. Moller - Maersk Supplier Code of Conduct
Glossary
 Bribe: A bribe is a direct and/or indirect payment, offer or promise to pay or give anything of value
 to cause an official not to perform his/her duty, or to do what he/she should not do, e.g. providing a
 service the payor is not entitled to receive.
 Employee: An employee is an individual who works part time or full time, under an open or fixed term
 contract of employment that may be oral or written.
 Facilitation payment: A facilitation payment is a personal payment or amenity to a low-level official
 to cause that person to perform a routine service the payor is entitled to receive, but which the official
 refuses to provide without payment.
 International standards: Maersk is a signatory to the United Nations Global Compact. References
 to international standards in this document, should primarily be interpreted as referring to the ten
 principles of the United Nations Global Compact.
 Precautionary principle: When an activity raises threats of harm to human health or the
 environment, precautionary measures should be taken even if some cause and effect relationships are
 not fully established scientifically.
 Supplier: An entity, organisation or individual providing goods or services, or acting or sourcing on
 behalf of A.P. Moller - Maersk (including any controlled joint ventures and associated companies)
 under a contract or otherwise, or as an agent, contractor or distributor.
 Worker: An individual performing work at the employer’s direction, instruction or request, whether
 under a contract of employment (implied, oral or in writing) or otherwise, or who is deemed to be a
 worker by the legislation.
 Workforce: total number of people employed directly or indirectly by a company or an organisation.
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A.P. Møller – Mærsk A/S
Supplier Code of Conduct