ALL THE WAY

A.P. MOLLER - MAERSK

Supplier
Code of Conduct
A.P. Moller - Maersk Supplier Code of Conduct

Contents
Message from the CEO��������������������������������������������������������������������������� 3 Harassment
Security Guards
Introduction��������������������������������������������������������������������������������������������������� 4
Working with Integrity������������������������������������������������������������������ 11
Implementation������������������������������������������������������������������������������������������� 5 Anti-corruption
Anti-Money Laundering
Speaking Up��������������������������������������������������������������������������������������������������� 6 Data Ethics & Cyber security
Competition law
Supplier Code of Conduct �������������������������������������������������������������������� 7 Sanctions and Export Controls
Conflict of interest
Health and Safety��������������������������������������������������������������������������� 8
Labour Rights���������������������������������������������������������������������������������� 9 Environment�����������������������������������������������������������������������������������13

Child Labour  Environmental Compliance & Monitoring

Freely Chosen Employment Management of Hazardous Substances
Employment Contracts Waste and Wastewater Management
Compensation Air Emissions
Working Hours Resource Use
Freedom of Association Biodiversity & Ecosystems
Discrimination Climate Change

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A.P. Moller - Maersk Supplier Code of Conduct

Message
from the CEO “Our suppliers play a vital role
in the way we conduct our
Dear valued suppliers,
business and deliver value to our
At A.P. Moller - Maersk, our deeply rooted values drive the way we
do business, and we live by them each day. These values reflect our stakeholders.”
commitment to sustainable development and guide us in conducting our
business in an ethical and upright manner.
approach. By working together with our suppliers, we can provide
Our suppliers play a vital role in the way we conduct our business sustainable solutions to our customers and embed sustainability in supply
and deliver value to our stakeholders. We endeavour to work with chains as well as the wider transport and logistics industry.
suppliers who share our commitment to continuously strengthening
responsible business practices. Through this Supplier Code of Conduct, As a valued supplier of A.P. Moller - Maersk, I count on your commitment
we communicate the minimum requirements that we expect our and support to continuously adopt and promote responsible business
suppliers to follow while conducting business in an ethical, socially and practices. I also encourage you to go beyond compliance and strive for
environmentally responsible manner. These requirements are based higher standards of sustainability.
on the United Nations Universal Declaration of Human Rights, ISO
standards on HSE, the core labour conventions of the International Labour Sincerely,
Organisation (ILO), as well as the United Nations Guiding Principles on
Business and Human Rights.

We require our suppliers to commit and act in accordance with the

requirements under this Code and extend similar standards to their
supply chain partners. Our procurement practices are designed to work Vincent Clerc
collaboratively with our suppliers through a continuous improvement CEO of A.P. Moller - Maersk

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A.P. Moller - Maersk Supplier Code of Conduct

Introduction
As a global company, A.P. Moller - Maersk takes active responsibility This Code reflects our commitment to the United Nations Global Suppliers to apply the stricter standard. In the event that standards in
for the societies and environment that we operate in. We take constant Compact (UNGC)1 and our respect for universally recognized normative this Code conflict with local and national laws as well as international
care to avoid causing or contributing to adverse impacts on people standards such as the United Nations Universal Declaration of Human standards, we encourage our Suppliers to address such conflicts with
across our value chain. Rights2 and Convention against Corruption3, the core conventions of us in order to jointly establish the most appropriate course of action.
the International Labour Organisation (ILO)4 and the ILO Declaration
The A.P. Moller - Maersk Supplier Code of Conduct (hereinafter on Fundamental Principles and Rights at Work5, the United Nations For further guidance on successful implementation of the
referred to as ‘Code’) sets out minimum requirements for the Suppliers Guiding Principles on Business and Human Rights6, and ISO standards principles and standards mentioned in this Code, kindly refer to the
(hereinafter referred to as ‘Suppliers’) of A.P. Moller – Maersk and the on Health, Safety, & Environment (HSE)7+8. relevant/supporting resources, available on our website.
Maersk Group’s affiliates and subsidiaries to operate in accordance
with responsible business principles detailed in this Code and in full Where the provisions of local and national laws conflict with or are
compliance with all applicable laws and regulations. less stringent than this Code or international standards, we expect our

1. United Nations Global Compact, The Ten Principles of the UN Global Compact
2. United Nations, United Nations Universal Declaration of Human Rights
3. United Nations, United Nations Convention against Corruption
4. International Labor Organization, Conventions, Protocols and Recommendations
5. International Labor Organization, ILO Declaration on Fundamental Principles and Rights at Work
6. The Office of the High Commissioner for Human Rights (OHCHR), ‘United Nations Guiding Principles on Business
and Human Rights
7. International Organization for Standardization, ‘ISO 45001:2018’
8. International Organization for Standardization, ‘ISO 14001:2015’

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A.P. Moller - Maersk Supplier Code of Conduct

Implementation
The Code applies to all Maersk Suppliers. For the purposes of this We expect and encourage our Suppliers to develop and implement
Code, ‘Suppliers’ refers to Suppliers and sub-contractors, agents, relevant management systems, appropriate for a company of their
consultants and their respective affiliates which provide goods and/or size and industry, to ensure compliance with applicable laws and
services to Maersk. regulations and the requirements of the Code.

Our Suppliers are required to acknowledge and commit to the We further expect our Suppliers to implement the principles and
adherence of the responsible business principles as outlined in this standards of this Code or similar internationally recognized standards
Code. We assess our Suppliers’ compliance with the Code through a in their own supply chain, including in their relationships with their
combination of audits, self-assessments, and documentation reviews suppliers, contractors, and joint venture partners. All Suppliers should
through our Sustainable Procurement Program. Suppliers should ensure that the Code is communicated to their own suppliers and
address any gaps in the implementation of this Code by establishing commit to upholding the requirements as outlined in the Code.
and implementing a time-bound improvement plan in consultation
with Maersk. Periodic reviews and follow-up audits as per our internal The underlying objective of this Code is to establish a basis for
risk procedures are conducted to monitor compliance levels. We are positive development of sustainable procurement practices through
committed to working with our Suppliers on their compliance and regular dialogues and ongoing working relationships. However, in case
sustainability journey and expect full transparency as a foundation for of violations of the Code we reserve the right to take actions including
our business relationships. and up to termination of contracts.

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A.P. Moller - Maersk Supplier Code of Conduct

Speaking Up

We expect our Suppliers to have a grievance mechanism in place to

ensure that workers 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 and Suppliers should provide
for or contribute to appropriate, adequate and effective remedy.

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.

Suppliers can report concerns through the channel they are most
comfortable with including Maersk representatives or relationship
partners or the Maersk Whistleblower System. The Whistleblower
System is administered by an independent company 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.

To report a concern online using the Maersk Whistleblower System

– please visit www.maersk.ethicspoint.com. Suppliers are required to
communicate the existence of this channel and to ensure that their
employees as well as their subcontractors are made aware of its
existence.

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A.P. Moller - Maersk Supplier Code of Conduct

Supplier
Code of Conduct
– Health and Safety
– Labour Rights
– Working with Integrity
– Environment

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A.P. Moller - Maersk Supplier Code of Conduct Health & Safety | Labour Rights | Working with Integrity | Environment

Health, Safety
& Security
We expect our Suppliers to strive to provide a safe, healthy and secure
workplace to all workers at all times.

• Suppliers must ensure compliance with applicable laws and

regulations regarding health and safety.
• Suppliers must develop and implement effective health and
safety management systems with worker participation in safety
committees.
• Suppliers must ensure that safety management systems support
risks identification, measurement and monitoring of performance
and the drive for continual improvements to mitigate or minimize
health and safety risks emanating from its operations.
• Suppliers must ensure the protection of their workforce by
providing basic personal protective equipment appropriate to the
nature of work and relevant training on health and safety systems.
• Suppliers must empower workers to report unsafe practices
without fear of reprisal.
• Suppliers must commit to proactively undertaking safety initiatives
to protect people and assets from harm and damage.
• Suppliers must have a clear set of procedures in place to respond
to any potential emergency situations, including worker notification
and evacuation procedures, first-aid supplies, fire detection/control
equipment and clear and unrestricted exits from the site.

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A.P. Moller - Maersk Supplier Code of Conduct Health & Safety | Labour Rights | Working with Integrity | Environment

Labour
Rights
Suppliers are expected to work towards creating and sustaining a • Suppliers and their recruiting agencies must not charge workers
working environment where workers are treated with dignity and recruiting or hiring fees, whether paid by workers out of their
respect and which is diverse, equitable and inclusive. own funds or which gives rise to the risk of workers being
indebted to Suppliers.
Child Labour • Personal official documents, including passports and travel
• Suppliers must not use or tolerate the use of child labour. documents, must stay in the possession of the worker. They can
Suppliers must not employ children who are below the local only be kept by the Supplier in a secure place at the request of the
minimum working age, the age of compulsory education or worker and must be accessible to the worker at all times.
the ages set out in the International Labour Organization Core
Conventions (whichever is higher). Employment Contracts
• Suppliers must ensure that workers, including trainees, under the • Suppliers must ensure that employment terms and conditions,
age of 18, do not undertake nightshift work or work overtime or including payment terms, are clearly understood by workers, and
carry out work that is hazardous or harmful to their physical or provided in a written contract in a language they understand prior
mental development. to the start of their work, as per local regulations and aligned to
the provisions of this Code as a minimum.9
Freely Chosen Employment
• Suppliers must not engage in any form of forced labour or human
trafficking, use or benefit from any kind of forced or involuntary,
bonded or indentured labour and should refrain from practices that
can give rise to a risk of involuntary labour.

9. In US, workers are employed at will. Offer letters and an employment handbook or a collective bargaining agreement with a union covering employment terms may be sufficient.

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A.P. Moller - Maersk Supplier Code of Conduct Health & Safety | Labour Rights | Working with Integrity | Environment

Compensation
• Suppliers must adhere to relevant national laws relating to Discrimination
minimum wages, overtime wages and legally mandated benefits. • Suppliers must provide equal opportunities and support to all
• If no national statutory minimum wage applies, Suppliers must workers and must not discriminate against anyone based on any
ensure that the renumeration is fair in the context of the local grounds such as age, gender, sexual orientation, gender identity or
circumstances and sufficient to meeting workers’ basic needs. expression, ethnicity, race, physical appearance, culture, religion,
• Suppliers must ensure that salary deductions that are allowed by national or social origin, political views, marital status, pregnancy,
applicable local legislation are fair and reasonable and not punitive. dependents, bodily/mental ability or trade union membership.
Pay slips must be provided in writing. • Particular attention must be paid to the rights of workers most
vulnerable to discrimination.
Working Hours • Suppliers must take extra precautions to respect the rights and
• Suppliers must comply with appropriate working hour wellbeing of migrant workers whose rights may be at risk or who
requirements including overtime, breaks, and rest periods – as may lack access to basic public services.
established by national law, relevant collective agreements, and
international standards. Harassment
• Suppliers must ensure that any overtime work is voluntary and • Suppliers must treat all workers with respect and dignity. The work
compensated and that overtime is not done on a systematic or environment should be free from bullying, intimidation, coercion,
structural basis. corporal punishment or harassment in any form including physical,
• Suppliers must adhere to relevant national laws, industry standards psychological, sexual or verbal.
and international standards for paid sick leave, paid annual leave,
and paid parental leave. Security Guards
• Suppliers must ensure that security guards operating at Suppliers’
Freedom of Association premises act in accordance with universally recognized human
• Suppliers must respect the workers’ right to associate freely and rights standards including guidelines on the use of force.10
join or not join trade unions in accordance with national laws and
international conventions.
• Suppliers must rely on open communication and direct engagement
with workers when addressing workplace issues and must refrain
from threats of reprisal, intimidation or harassment.

10. The Voluntary Principles Initiative, Voluntary Principles on Security and Human Rights

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A.P. Moller - Maersk Supplier Code of Conduct Health & Safety | Labour Rights | Working with Integrity | Environment

Working
with Integrity
Suppliers should conduct their business in a manner that ensures • Suppliers must not present any invitations or gifts to our
transparency, honesty and ethical conduct in all interactions. We employees so as to gain any form of influence or inappropriate
expect our Suppliers to have zero-tolerance for corruption and ensure advantages. Any invitations or gifts extended to Maersk
compliance with all UN and Organisation for Economic Co-operation employees or related parties, if any, must be reasonable and
and Development (OECD) conventions against corruption11, and with suitable, i.e., they must be of a low financial value and reflect
all governing anti-corruption laws. ordinary local business custom.
• Suppliers must record and report any offer, receipt, or request to
Anti-corruption give bribes or facilitation payments. Suppliers must also challenge
• Suppliers must avoid participation in, or knowingly benefit from, any request to make or receive bribes or facilitation payments, which
any kind of corruption, extortion or bribery. must be actively refused unless there is a threat to personal safety.
• Suppliers must establish and enforce a written policy against
illegally influencing or bribing public officials, business partners or
customers and promote workers’ awareness of the same. Anti-Money Laundering
• Suppliers must be transparent about commercial, financial or any • Suppliers must comply with all applicable laws governing the
other significant direct or indirect links to government agencies prevention of money laundering and not participate in any money
or departments, political parties and public/government owned laundering activities.
entity officials.

11. Organisation for Economic Co-operation and Development (OECD), Anti-corruption and integrity

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A.P. Moller - Maersk Supplier Code of Conduct Health & Safety | Labour Rights | Working with Integrity | Environment

Data Ethics & Cyber security Sanctions and Export Controls

• Suppliers must protect data generated or entrusted to them in • Suppliers must adhere to national and international sanctions and
order to deliver services to Maersk and our customers and commit export control laws, in particular UN, US, EU, and UK, pertaining to
to only using such data responsibly and for the intended purpose. business transactions with countries, companies and persons, and
• Suppliers must comply with all applicable regulatory the transfer of goods and services, software or technology between
requirements, including data protection and information security countries and any re-exports.
laws relating to the processing, transmission, or disclosure of such • Suppliers must not engage with any sanctioned person or company
data and information. in relation to any business dealings with Maersk.
• Suppliers must safeguard all Maersk data and information from • Suppliers must not provide any restricted services or goods that
unauthorized access, disclosure, or use, and adhere to confidentiality may involve Maersk.
and data protection requirements specified in agreements. • Suppliers must conduct due diligence when selecting suppliers of
• When operating technology or infrastructure in support of Maersk goods and services, software and technology to ensure compliance
business operations, Suppliers must keep such technology secure with sanctions and export control laws.
and protected against unauthorized access that may compromise
confidentiality, integrity, availability or safety. Conflict of interest
• Suppliers must ensure personnel are trained in the correct usage • Suppliers must adopt the highest standards of ethical behavior by
and protection of data and information in compliance with the preventing and avoiding any potential, actual or perceived conflicts
above and in the appropriate notification and response in the case of interest. Suppliers must take decisions based on objective
of a breach. criteria only. Any factors that might influence Suppliers’ decisions
due to private, business or other conflict of interest must be
Competition law prevented. The same applies to relatives and other related parties.
• Suppliers must adhere to anti-trust and other competition laws • Suppliers must immediately disclose to Maersk any potential,
and regulations. actual or perceived conflict of interest.
• Suppliers must always independently compete for business, set
prices, and terms of purchase or supply to vendors and customers.
• Suppliers must never enter into illegal agreements with
competitors that may restrict or distort competition, such as price
fixing, market and customer division or bid rigging.
• Suppliers must never unlawfully provide, request, or discuss
commercially or competitively sensitive information (Competitively
Strategic Information).

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A.P. Moller - Maersk Supplier Code of Conduct Health & Safety | Labour Rights | Working with Integrity | Environment

Environment
We expect Suppliers to demonstrate commitment towards
environmental protection by striving to minimize environmental
impacts and, where material, proactively contribute positively to
shared environmental and climate ambitions.

Environmental Compliance & Monitoring

• Suppliers must establish and enforce policies and procedures in
adherence to local, national, and international environmental laws
and standards in their operations and products.
• Suppliers must monitor and control significant environmental
impacts and performance, ensuring compliance through training
and operational controls.
• Suppliers must ensure that any work that requires a specific
environmental license is only performed by individuals who are
appropriately registered and/or licensed.
• Suppliers must maintain appropriate environmental records to
demonstrate compliance with all requirements for environmental
licenses and permits, including, but not limited to data from the
monitoring of significant environmental impacts.
• Suppliers are encouraged to regularly assess and monitor nature-
related impacts, dependencies, risks and opportunities relevant to
the specific type and size of their operations, and where relevant,
take mitigative action. We further encourage Suppliers to consider
the impact on affected communities and engage with them
appropriately.

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A.P. Moller - Maersk Supplier Code of Conduct Health & Safety | Labour Rights | Working with Integrity | Environment

Management of Hazardous Substances Air Emissions to conserve biodiversity by adopting sustainable land use practices,
• Suppliers must identify and manage substances that pose a hazard • Suppliers must ensure that emissions of volatile organic chemicals, preserving natural habitats and supporting initiatives aimed at
if released into the environment and comply with applicable aerosols, corrosives, particulates, ozone depleting chemicals, and protecting endangered species.
labeling laws and regulations for recycling and disposal in an combustion by-products generated from operations are identified, • Suppliers are encouraged to minimize and ultimately avoid their
environmentally sound manner. monitored, controlled, and treated before discharge through presence in, and impact on, biodiversity-sensitive and protected
• Suppliers must display Material Safety Data Sheets (MSDS) for regular air sampling as required by applicable local and national areas and to strive to contribute to positive outcomes on
any hazardous or toxic substances used in its facilities and provide laws, and international standards. biodiversity and ecosystems where material.
sufficient training to workers handling such substances.
Resource Use Climate Change
Waste and Wastewater Management • Suppliers are expected to utilize energy, materials and water • Supplier shall consider setting greenhouse gas emissions reduction
• Suppliers must ensure proper management of wastewater and resources efficiently and responsibly throughout all aspects of their targets towards low emissions operations including reporting
solid waste from operations and sanitation facilities according operations. This includes minimizing waste, adopting sustainable systems for the monitoring and disclosing of greenhouse gas
to local, national, and international laws, including segregation, practices and continuously striving to improve resource efficiency. emissions and reductions. Maersk recommends target setting
monitoring, treatment, and record-keeping. • Suppliers must make commercially reasonable efforts to recycle methodologies in line with international standards, such as the
• Suppliers must stay well-informed and compliant with any and reuse as much as possible, consistent with good industry Science Based Targets initiative (SBTi)12. For Small and Medium-
regulations or changes thereto, pertaining to the labeling, storage, practices and financial prudence. sized Enterprises (SMEs), Maersk recommends target setting
and disposal of waste. methodologies in line with international standards, such as the
• Suppliers must immediately notify site management, or Maersk Biodiversity & Ecosystems SBTi SME target pathways13. Maersk recommends a 2040 target
project manager or supervisor, in case of spills or release of • Suppliers are expected to undertake initiatives to protect and year to support the achievement of Maersk’s committed net
hazardous material into the environment, so that steps can be restore biodiversity and ecosystems within their operations and zero targets, with due consideration to relevant national and
taken to correct, or control those conditions. supply chains. We encourage Suppliers to actively engage in efforts international climate ambitions.

12. Science Based Targets initiative (SBTi

13. Science Based Targets initiative (SBTi), SME target pathways

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 ALL THE WAY

A.P. Møller – Mærsk A/S

Supplier Code of Conduct
Effective as of 1 October 2024