WIXLIB

11competitivenesspromoting responsibilitycommitmentcontinuous improvementQ: Why should we improve our environmentalperformance beyond compliance with legislation?A: Our certification according to ISO 14001 is acommitment to continuous improvement of ourenvironmental performance where legislation isthe baseline. Additionally, due to our commitmentto the UN Global Compact, we are expectedto contribute to promoting environmentalresponsibility and development and diffusion ofenvironmentally friendly technologies. Of course,it should always be assessed how environmentalinitiatives will affect our competitiveness.However, we believe that high environmentalstandards will be key competitive parameters inthe future.Q: My manager asked me to follow a procedure thatI believe is environmentally incorrect. Whatshould I do?A: Never guess about environmental procedures.If you are uncertain of the procedure, check withyour manager to be sure you have understoodthe request. If you still feel the request violatesenvironmental regulations, report the concern tothe Environmental Department, SQE Managementor the Designated Person.Reducingenvironmental impactQ&A

12Respecting employeesWe respect the values and cultures of ouremployees and business partners. We do not acceptdiscrimination with respect to gender, ethnicity,religion, sexual orientation, handicap or age. Wework towards a diverse workplace in which everyoneis included and respected and we regard well-beingat work as a shared responsibility.OUR employees: Contribute actively to maintaining a good workingatmosphere by showing your colleagues respect Do not take part in harassment Intervene and/or report discriminationWe are committed to providing equal employmentand career opportunities for qualified applicants andemployees.OUR employees: Pursue any professional opportunity TORM offersaccording to your qualificationsOUR officers and managers: Ensure that every employee is treated equally andevaluated according to qualifications, and spot andencourage talented employees Do not emphasize a person’s gender, age,nationality, ethnicity, religion, sexual orientation,disability, etc. in recruitment, salary adjustment,career development, training and dismissalWe respect employees’ right to privacy and protectthe privacy of employees’ personal information. Wemust ensure that appropriate systems are in place tosafeguard the access to this type of information.OUR officers and managers: Use only the minimum necessary health tests, asspecified under the law or desired by employees,and be cautious with medical testing of applicants Be cautious to ask about an applicant’s personalcircumstances, such as political beliefs, sexualorientation, religion, family circumstances, etc. Be cautious when registering an employees’personal information and be aware that allemployees are entitled to see the accounts ofpersonal information held about themWe respect the right to associate freely, to join – ornot join – unions, and to bargain collectively and weencourage a constructive dialogue about workingconditions.OUR officers and managers: Ensure that employees and management have aformalized dialogue concerning working conditions

privacynon-discriminationequalityfairnessQ: A co-worker has spoken to me in a way I believe isinappropriate, and it has made me uncomfortable.What should I do?A: You can politely but firmly confront the individual.State how you feel about his or her actions andask the person to stop the behavior immediately.Or you can report the behavior to your directmanager, HR or the designated CSR contact.Q: My manager often tells rude and sometimes racistjokes. I do not believe they are directed at me, but Istill feel uncomfortable. I am also worried about howsome of my colleagues will feel? What should I do?A: Your manager’s behavior is unacceptable. Youshould ask him or her to stop this behavior. If youare not comfortable doing this, contact HR or thedesignated CSR contact.Q: We are recruiting for a job that involves extensivetravel. One of the candidates is a single parent,and despite having excellent experience andqualifications, I do not believe she or he will copewith the travel. I suppose I should just interviewher as a courtesy?A: By making such an assumption, you are violatingour principles, and in some locations possiblybreaking the law. In this case, you must give thecandidate the opportunity to demonstrate thatshe or he can cope with the required travel. Thedecision, that this candidate is unsuitable forthe job must be based on merit, which has beenevaluated fairly during the recruitment process,and not because she/he is a single parent.Q: Can I ask a job candidate if he or she is marriedand has children?A: No, you may not ask personal questions, e.g.questions about marital status and children,religious affiliation, medical information or age.Q: If I encourage a woman to apply for a position,because I think we need more female managers,would I not be discriminating against maleapplicants?A: It is not discriminating to attempt to equalize thebalance between the genders by giving specialattention to female talent. Because there are sofew women in the shipping industry, we want toensure that those who have the skills and potentialare discovered and get an opportunity to exploit it.It is simply a matter of maximizing the talent pool.RespectingemployeesQ&A13

14Doing business responsiblyWe make sure our employees know relevantinternational and national laws, regulations andrecommendations from international shippingauthorities and organizations.OUR employees: Adhere to laws, standards and restrictionsimposed by relevant authorities Be responsible for understanding laws andregulations that apply to our business and yourjob and for preventing, detecting and reportinginstances of non-complianceOur officers and managers: Ensure necessary resources are available for youremployees to know and understand relevant legaland regulatory frameworks Have a continuous dialogue with relevantauthorities and organizations to stay abreast ofupcoming legislation and recommended standardsand be able to act proactivelyWe will not accept corrupt business practices andwe want to avoid the use of facilitation payments(defined as a payment of minor value for a servicewhich we are already entitled to and should not haveto pay for).OUR employees: Never give or receive a bribe. No employee will bepenalized or be subject to other adverseconsequences, for refusing to pay bribes even if itmay result in TORM losing business Do not accept social invitations from businesspartners, which appear to be aimed at gaining animproper advantage and/or involve excessivecost. when you entertain business partnersor colleagues, the cost and nature of theentertainment must be planned and carried out ina way, which reasonably furthers the business ofTORM. if in doubt, consult your superior Are permitted to give or accept gifts of moderatevalue. gifts, which are beyond symbolic tokens orabove the value of USD 30, must be reported toyour superior. Gifts include physical objects,services, favors or other items of value Actively resist claims for facilitation payment,except in incidents where personal safety is atrisk. any amount paid must be kept to a minimumand must always be reported according to the

15procedure for reporting and monitoring facilitationpayments in TORM. Read the procedure in TORM’sQuality Management System (QMS)We are committed to promoting responsiblebusiness practices in our supply chain. We seek tohave a positive impact within our sphere of influence.When possible, we will give preference to supplierswho share our commitment to lawful and ethicalbehavior.Our employees with supplier contact: familiarize yourselves with TORM’s commitmentto responsible business practices in the supplychain Do not necessarily break immediately with asupplier who does not fulfill our expectations, butrather encourage the supplier to worksystematically to improve performance within aset time period Report to your manager or to the designated CSRcontact (csr@torm.com) if you experience orsuspect non-compliances with our requirements.We want to be an asset to the communities wherewe are located. We will work with communities tosupport educational institutions and other worthycauses.Our officers and managers: Encourage your employees to partake in localsocial responsibility activities. Be aware that beingsocially responsible has different meanings indifferent locations and initiatives may take variousforms across regions

16Doing businessresponsiblyQ&AQ: How do we prioritize CSR performance when weevaluate our suppliers? Is CSR as important asprice and quality?A: We prefer suppliers who share our commitmentto lawful and ethical behaviour. We are currentlydeveloping our supplier dialogue on CSR. The firststep we have made is to make CSR assessmenta part of our tender process to ensure thatthe evaluation of potential suppliers is a jointassessment of quality, price and CSR performance.Q: How do we react if a supplier conducts business ina way that conflicts with our business principles?Will we terminate the cooperation?A: The challenge is to strike a balance betweenthe commercial imperative of continuing doingbusiness and the ethical demands. There mightbe economic, political or cultural reasons fordifferences in ways of conducting business, but ifthe supplier is committed to improving the criticalissues, TORM should instead consider how wemay assist the supplier. Terminating the businesspartnership might not serve the overall aim ofensuring the core human rights and labour rightsand reducing environmental impacts.Q: We use a contractor to do some work for TORM.I know some people who work for this contractor,and they told me they may not be doing thiswork in a way that is consistent with regulatoryrequirements. Does this matter and should Ireport this?A: Yes, it matters. What the contractor is doing mighteven make TORM liable. But even if there wouldbe no liability, we still care. You should report thisto your direct manager or the designated CSRcontact.Q: How do I react if I am asked to give a minorpayment to an inspector on board a vessel?A: It is TORM policy to resist facilitation payment,except in incidents where personal safety,environmental safety, vessel or cargo safety isat risk. If you cannot avoid making a payment, itmust be reported according to TORM’s procedure.See procedure and policy on facilitation paymentsin the Quality Management System (QMS).

performancecomplianceQ: A port official has told me it will take weeks todeliver materials to a vessel unless a payment ismade to help him expedite our shipment. Should Icomply with his request?A: First ask to get a receipt. If that is not possible,this payment likely violates the principles.This isa legal determination, and you must review thearrangement with the Legal Department beforeagreeing to make any payments to governmentofficials.Q: I am finalizing an important contract with asupplier who has just sent me an expensive gift?Should I keep it?A: No. Even if the supplier is not intending todeliberately influence your decision, the timing ofthe gift indicates poor judgement on their behalf.You should return the gift and explain that weonly accept gifts that are modest and could notreasonably be regarded as attempting to create abusiness obligation.Q: I was told that I could hire a consultant to takecare of getting all the permits we need from aforeign government. He requested a 40,000retainer and said that he would use the moneyto help move the process along. Since we do notreally know where the money is going, do we haveto worry about it?A: Yes, you do have to worry about it. You must knowwhere that money is going and for what purpose itis being used to ensure that the money is not usedas a bribe. Seek the advice of your direct manageror the Legal Department immediately.Q: The agent that my predecessor hired to negotiateon our behalf with local government officials isdoing a great job, but his fees seem to be higherthan I would have expected. What should I do?A: Any issues must be completely resolved as youmust never continue to use a third party if youare aware of, or suspect, improper behavior. Youshould review the agent’s contract and confirmthat our Supplier Code of Conduct has beenprovided to them, that they understand what itmeans and they acknowledge this understanding.At all times, the third party must comply with allrelevant laws, including ensuring that no portionof their fees are being offered directly or indirectlyto the benefit of the government.Doing businessresponsiblyActresponsiblyResist corruption beyond17

18Ensuring transparencyand fairnessWe will pursue an open-minded dialogue with ourstakeholders about their expectations and ourperformance. However, TORM is a listed companyand therefore it is of the utmost importance to avoidspreading of misunderstandings and misinformation.OUR employees: Actively engage in a constructive dialogue withstakeholders at meetings, events, etc. to learnabout their expectations and needs Have a continuous dialogue with customers tostay ahead of their needs and demands for newsolutions Refer to the Communications Departmentif you are approached by a journalist. Onlyexecutive Management may approach the pressor respond to queries from the press withoutprior consultation with the communicationsdepartment. Read our Press Policy on theintranetWe are accountable to our stakeholders andreport on our financial, social and environmentalperformance in an accurate and transparent way.OUR employees: Keep TORM’s books, records and accounts in away, which accurately, fairly, and in detail reflectstransactions and dispositions of assets Do not intentionally make any false or misleadingentry in books or records Are prohibited to destroy or conceal a record withthe intention to impair its integrityWe want to compete in a free market and followthe antitrust laws in all countries we operate in.Information about competitors must always becollected in an ethical manner.OUR employees: Do not enter into cooperation with competitorsthat can result in anything resembling illegalagreements in terms of pricing, market sharing,misuse of dominant position or other conditionswhere free competition is prevented or reduced.This applies whether the contact is written or oral Only collect information about our competitorsfrom legitimate sources Do not accept or use confidential material, whichrightfully belongs to others

19We expect employees to protect the confidentiality ofTORM information.OUR employees: Maintain absolute confidentiality with regard to allconfidential information obtained during and afteremployment with TORM. Absolute confidentialityapplies to commercial and operational mattersrelating to TORM, business partners and privateindviduals Do not disclose information to unauthorizedpersons inside or outside TORM unless authorizedto do so Refrain from discussing or disclosing anyconfidential information about TORM unlessauthorized to do soWe expect employees to stay free from actual orpotential conflicts of interest in relation to TORM.Conflict of interest is when an employee directly orindirectly has a personal interest that may affect theassessments and decisions they make on behalf ofTORM.Our employees: Avoid any situation or action which may involveconflict of interest with TORM Discuss matters with your immediate superior ifyou are aware of a conflict of interest – or if youare unsure whether a conflict exists. Immediatesuperiors are direct managers, HR, the SeniorManagement Team or the Chairman of the Boardof Directors, as appropriate Never use or attempt to use your position withTORM to obtain improper personal benefits – orbenefits for your family or friends Do not engage in activities for a competitor,customer or supplier, if such activities mayconflict with obligations to TORM

20Ensuring transparencyand fairnessQ&AQ: What should I do if an employee of a competitorapproaches me to discuss prices or marketconditions?A: Such discussions should be avoided. You shouldinform the competitor’s employee that you willnot engage in any such discussions and promptlycontact an attorney in the Legal Department whowill assist you in taking any other steps that mightbe advisable to protect you and TORM.Q: I used to work for a competitor to TORM. CanI brief my team on the competitor’s proposalstrategies?A: No. You have a commitment to protect confidentialinformation of your former employer, and thatcommitment does not cease when you leave thatcompany. TORM does not want information that itdoes not have a right to have. You need to discloseyour prior relationship to your direct manager andto abide by all obligations of confidentiality owedto your former employer.Q: I have been assigned to develop a specificationfor something that TORM may decide topurchase from an outside source. Can I accepthelp from potential suppliers in generating thatspecification?A: Perhaps, but you must be careful. In cases wheresuch an arrangement is appropriate, you mustavoid receiving any proprietary information ormaterials. You must also avoid creation of anyexpectation on the part of a supplier that TORMwill select that supplier or even allow thatsupplier to bid for the TORM requirement.Q: While waiting to attend a proposal meeting, Ioverheard a conversation that a procurementofficer had with one of our competitors. Thecompetitor told the procurement officer abouthis product’s specifications and costs. Can I stillattend the meeting? Can I write a similar proposaland send it to the officer with a lower bid?

confidentialityconflictsobjectivityA: No. You cannot take advantage of the informationin any way. You should politely excuse yourselffrom the meeting and contact the Legal Departmentimmediately and avoid any disclosure of theinformation to individuals connected with theprogram or proposal. As an individual, you willprobably have to withdraw from the bid team, butyou have done your best to protect the ability ofTORM to go forward.Q: I just received some confidential information abouta competitor. I did not as

TORM's Business Principles The Business PrinciPles reflect the values of the philosophy and form the guidelines for the way we conduct our business. The principles ensure that we are in compliance with legislation and live up to our commitment to responsible business practice. This document outlines TORM's business principles from 2012.