Privacy Policy

3. Applicability and scope

This Policy applies to all entities within the Company, including all Co-workers. It is a management responsibility to ensure that the Policy is distributed and made available to all Co-workers and to ensure compliance with the Policy.

4. Legislation

This Policy is governed by the Norwegian Penal Code and the Norwegian Working Environment Act, Anti-discrimination Legislation, Norwegian Competition Act, Norwegian Marketing Act and all applicable Norwegian rules pertaining to Securities and Trading.

4.1 Working environment and personnel policy

INRIGO shall be a valuable workplace ensuring personal development and an including working environment. We shall act with respect and integrity towards each other and all the persons we meet in our work. Discrimination, harassment, bullying, and the like are not accepted. Co-workers shall have the opportunity to use their skills and qualifications in order to contribute to the value of the Company and their personal development.

4.2 Equality and diversity

INRIGO respects diversity and views it as strength. Our employment policy is open and fair. Discrimination of any kind is not tolerated, including discrimination based on ethnicity, color, gender, age, disability, HIV-status, marital condition, sexual orientation, religion, political or other opinions, national or social origin, or another status. Our goal is to have a workplace free from all discrimination and harassment.

4.3 Sexual harassment

Sexual harassment creates an intimidating and hostile work situation and is not tolerated. Sexual harassment encompasses conduct that is overt or sexually suggestive in content: the scope of such prohibited conduct is not limited to opposite-gender confrontations.

4.4 Sexual exploitation

Any form of sexual exploitation is forbidden. Sexual exploitation is coercion and/or manipulation by a person in a position of power or influence, where such person provides any form of employment-related benefit to another person, in exchange for any form of sexual activity. In such situations, the potential victim believes she/he has no choice other than to comply, thus there is no actual consent to the sexual act, which is exploitation. INRIGO is against the purchase of sexual services. Such services may be interlinked with illegal acts of trafficking and involve a breach of human rights. INRIGO's co-workers may not accept or solicit sexual services during or after working hours when on service on behalf of INRIGO.

4.5 Substance use

INRIGO is a drug-free workplace. Accordingly, being under the influence of intoxicating substances, including alcohol, is strictly forbidden while at work. However, limited amounts of alcohol may be served when the occasion or local custom make it appropriate to do so, provided the consumption of alcohol is not combined with operating machinery, driving or any other activity that is incompatible with alcohol consumption. No one should use or encourage others to use substances in a manner that can place the user, the Company, or any of its Business Associates in disrepute or embarrassment.

4.6 Health, Security and Environment (HSE)

All activities shall be planned and executed in a safe way to protect human life and health, the environment, equipment, and property. INRIGO's HSE strategic goal is zero incidents. All Co-workers must take responsibility for HSE by focusing on personal behavior, openly communicate HSE issues and performance, practice knowledge sharing, and by taking active steps to learn best practices. HSE performance is a useful tool when hiring staff and to improve, evaluate, and reward staff performance. Line management shall prove HSE leadership and implement all HSE policies.

4.7 Climate and environment

As a heavy industry enterprise, INRIGO is subject to extensive and changing laws and regulations designed to protect the environment. These include laws and regulations on air and water quality, imposing limitations on the discharge of pollutants into the environment and establishing standards for treatment, storage, and disposal of toxic and hazardous wastes. INRIGO takes environmental responsibilities and social corporate responsibilities seriously. We are highly aware of the environmental effects our activities may cause, and thus, we take necessary steps to limit the impact by continuously developing technologies, practices, and business opportunities compatible with sustainable development.

4.8 Society

We shall be a responsible Company and always pay respect to the societies we are part of, including their environment, culture, and religion. INRIGO sees social contributions as strength in terms of showing responsibility and positively taking part in social development. Our presence and operations in developing countries bring higher levels of awareness to our role in societies. We shall see social contributions in the local context, considering government systems, laws, and ethics as well as specific needs. In particular, we shall focus on the role that education and training play as a method for social development and aid.

4.9 Conflict of interest and impartiality

Co-workers shall not seek to obtain advantages for themselves (or related persons) that are improper or in any other way may harm INRIGO's interests, whether or not this constitutes criminal fraud. If you become aware of a potential conflict of interest, you shall without delay, notify your immediate superior.

4.10 Confidentiality

The principle of confidentiality applies to all Co-workers. We shall not disclose business information to third parties. The confidentiality obligations continue after the Co-worker has left the company. Strictly confidential information includes, but is not limited to: Contracts and agreements – existence and content Business plans and strategies Technical information concerning products, vessels, and equipment Designs and drawings Sensitive employee information such as private telephone numbers and addresses

4.11 Company resources

INRIGO's intellectual property is highly valued. It comprises knowledge, ideas, structures, and work methods. These values shall be protected and managed to the best of the Company's interests. INRIGO shall respect the similar rights of third parties. Personal use of INRIGO's resources is forbidden. Resources include funds, property, equipment, and other assets. The company's resources must not be loaned, sold, or donated without approval from the employees immediate superior. The individual employee is encouraged to speak up upon discovering misconduct. The employees are obliged to notify their immediate supervisor about any infringement of the ethical codes. If it is not possible the issue should be raised with a member of the corporate management team.

4.12 Information systems

Electronic communication is considered company records. Information produced and stored on INRIGO's IT system is regarded as INRIGO's property. INRIGO, therefore, reserves the right to access all such information except where limited by law or agreement. Personal use of such information must be approved by management. The viewing of offensive material such as pornography on INRIGO's systems is never permitted. Any downloading, storing, distribution, or use of software, which is a breach of copyright law or provision, is prohibited.

6. Combating corruption and improper payments

6.1 Accurate information, accounting, and reporting

All internal and external business information shall be communicated accurately and thoroughly. All accounting information shall be accurate, registered, and quoted in compliance with applicable laws and regulations, including relevant accounting standards. All intentional actions, which communicate incorrect accounts, will be treated as fraud.

6.2 Corruption

Corruption undermines legitimate business and involves distortion of competition, is detrimental to the business reputation and exposes the company and individuals to risk. INRIGO is against all forms of corruption and shall work actively to ensure this does not exist in the Company. Co-workers must not offer any party anything of value to obtain an improper advantage in selling goods and services, conducting financial transactions or representing INRIGO's interests to governmental authorities. The Company and its Co-workers shall not accept gifts or services (including dining and similar entertainment) of more than symbolic, nominal value unless approved in writing by appropriate senior management. Any demand for or offer of sensitive material or questionable payment in any form made to any INRIGO Co-worker must be rejected and reported immediately to management. Examples of items that never is acceptable to give or receive, regardless of value: Cash and checks Drugs or other controlled substances Product and service discounts not available to all employees Personal use of accommodations or transportation INRIGO employees shall not offer, promise or give any undue advantage to a public official or a third party, to obtain or retain business or other improper advantages in the conduct of business, or refrain from acting in relation to the performance of her/his official duties. This code applies regardless of whether the advantage is offered directly or through an intermediary. Corruption is not tolerated in INRIGO, and violations will lead to disciplinary actions.

6.3 Financial inducements

6.4 Public Officers

INRIGO shall not accept gifts or payments or offer any value to Public Officers, except when this is explicitly accepted by the CEO. INRIGO may within reasonability, cover expenses for Public Officers in connection with business activities. Such costs may be reasonable travel, lodging, and training costs when this is legitimate due to business reasons. In no event shall such expenses be covered if this represents a breach of the Public Officer's duties.

6.5 Fair competition and competition law

INRIGO shall compete in a fair at ethically responsible manner within the frames of antitrust regulations and competition laws applicable to the markets in which INRIGO operates. This applies to business relations to competitors as well as customers and suppliers.

6.6 Gifts, hospitality, and expenses

INRIGO's Co-workers shall not, directly or indirectly, accept or offer gifts from or to any Business Associate or anyone closely related to a Business Associate, unless such gifts are modest. Monetary gifts shall under no circumstance be accepted or offered. Gestures of etiquette such as social gatherings, meals, or entertainment may be accepted or offered if it is based on commercial interests and the cost is at a modest level. Travel and lodging costs of Company employees shall in no event be covered, either directly or indirectly, by a Business Associate. Neither shall INRIGO offer to cover such expenses for any employee of a business associate.

8 Compliance

8.1 Disciplinary Actions

Non-compliance with the relevant policy/legislation may involve disciplinary actions or dismissal and may be reported to relevant public authorities.

8.2 Complaints and expressions of concern

Employees who feel the need for advice or support in the face of an ethical dilemma should consult their line manager or another in INRIGO they trust. Employees are encouraged to notify violations of the Company's ethical guidelines or current law so that the business can be corrected. If desired, inquiries will be handled confidentially.

8.3 Protecting the whistle-blower

INRIGO will not impose sanctions or other forms of retribution against any individual who notifies of censurable conditions at the Company provided, that the individual adheres to the Whistle-Blowing Policy.

9 Implementation

This Policy has been approved by the Board of Directors of Inrigo and shall be effective as of 01.01.2019 and the Policy will be reviewed periodically and may be amended to meet changing circumstances. Any exceptions to this Policy, where necessary, will only be granted in exceptional circumstances and only with the approval of the CEO of Inrigo or a representative expressly appointed by the CEO.

Policy Framework

• Inrigo is subject to the Act on Enterprises' Transparency and Work on Fundamental Human Rights and Decent Working Conditions – the Transparency Act. Our work is based, among other things, on the UN Human Rights Convention.
• Inrigo is committed to operating our company with integrity and in accordance with the standards and principles of business conduct and ethics outlined in our Code of Ethics, this policy, applicable laws, regulations, and international guidelines and conventions.
• We conduct annual due diligence assessments throughout our value chain to ensure that our suppliers and business partners adhere to the same declarations, conventions, and norms for universal human rights and decent working conditions as we do.

Anti-Corruption

• Inrigo has zero tolerance for corruption. We will combat corruption in all its forms—direct as well as indirect, active as well as passive, and in both the private and public sectors. Implementing anti-corruption measures is an integral part of our corporate social responsibility and protects our reputation and the interests of our stakeholders.
• Business relationships with partners unwilling or unable to comply with our ethical guidelines or this policy shall be terminated.

Anti-Money Laundering

• Inrigo will comply with applicable anti-money laundering regulations. Money laundering involves activities aimed at concealing proceeds from criminal activities by disguising their illegal origin.
• Criminal proceeds include not only money but all types of assets, property, and intangible assets obtained through criminal activities.

Sanctions

• Inrigo will always comply with all applicable sanctions, trade restrictions, and export regulations in the countries where we operate.

Competition Law

• Inrigo will not engage in or tolerate any anti-competitive behavior, such as price fixing, bid rigging, market allocation, exchange of competitively sensitive information, or abuse of market power.

Fraud Prevention

• Inrigo does not tolerate any form of fraud. We expect employees not to engage in fraud to create benefits for themselves, Inrigo AS, or others, nor to use Inrigo's property or resources for personal gain or in competition with Inrigo.