Code of Business Ethics
Introduction
As a global operating Company, ORA Offshore Customs Consultancy interfaces with customers and suppliers all over the world. These groups, together with other organizations and individuals with which our businesses interact, take a close interest in what we do. Our Code is organized into seven (7) fundamental behaviors.
It applies to all third parties, such as consultants, agents and suppliers, and are also required to comply with our Code when acting on our behalf.
Their opinions about ORA are influenced by our actions. A good reputation is not just important, it is essential to our ongoing success. A key determinant of this reputation is how we all behave – both as individuals as collectively.
In a complex world, it is impractical to set specific rules and regulations to cover every situation. However, we at ORA do have a Code of Business Ethics which seeks to offer clear standards and guidance for the business dealings of every day.
This Code is introduced in 2018 and reflect today’s challenges. It outlines the standards that we must all attain and covers a range of different areas of activity. Whilst it cannot deal with every circumstance, it creates a framework to help us decide how to behave.
The Code is designed to help set our interactions with external stakeholders and the communities in which we work on strong ethical foundations. Supporting the Code are specific policies.
They underline the important message that behaving responsibly, and ethically, is an integral part of our jobs. As such it is the personal responsibility of each one of us, as well as an important duty of line management to monitor compliance.
If you are ever in any doubt about how to behave in specific situations or wish to report what might be a violation of the Code, there are several ways of doing this. In addition to usual management there is established a confidential reporting line to the management. This helpline is also available via e-mail.
We undertake that anyone raising a concern in good faith may do so without fear of victimization or negative consequences.
In conclusion it is vitally important that ORA and its businesses are, and can be seen to be, responsible and ethical participants in the markets in which we operate around the globe.
Our demand is the commitment of every customer and all third parties to uphold the Code and to contribute towards a for all parties satisfying way of doing business the right way.
Hadassah Vorm,
Executive Director at ORA Offshore Customs Consultancy.
Speaking up and zero tolerance for misconduct
Speak up about disrespectful, inappropriate, fraudulent, unethical or illegal behavior. If you have a good faith concern about disrespectful, inappropriate, fraudulent, unethical or illegal behavior of any kind, ORA wants you to speak up. You can always escalate your concern without fear of retaliation if you do not receive an acceptable response from your first point of contact. We take seriously all concerns raised, including allegations of retaliation.
Act or reach out for guidance when approached about a concern involving disrespectful, inappropriate, fraudulent, unethical or illegal behavior. We take concerns seriously and act or otherwise raise them via the appropriate channel. We always seek to ensure it is handled confidentially and with sensitivity.
We compete fairly
ORA believes in competing fairly and vigorously in its market sectors. ORA does not engage in, nor is it party to, agreements, business practices or conduct that, as a matter of law, are anti-competitive.
We do not collaborate with competitors on how to price our services or whether to pursue opportunities in a particular market. We are fierce but fair competitors.
We act with integrity in all our business dealings
Because of proper business behavior ORA acts with integrity always to safeguard the trust in which ORA is held by its customers, shareholders, suppliers and other individuals and organizations with which our businesses interact.
ORA does not offer, promise, give, demand or accept bribes or other unethical advantage in order to obtain, retain or give business or other advantage.
Anti-Corruption & Bribery
At ORA we comply with anticorruption laws without exception. Our stance on corruption sometimes referred to as bribery, is very simple: Corruption is wrong, it is against the law and we don’t give or accept bribes. We comply with anticorruption laws - without exception, regardless of local business culture or practices.
Even if our competitors give bribes or make questionable payments, ORA has zero tolerance for bribery or any other activity that violates these laws.
We do not give or accept bribes. We pride ourselves on our relationships with our clients and understand that cultivating those relationships often is best accomplished in social settings - such as meals, sporting events or other forms of entertainment.
While ordinary relationship-building activities - including gifts and entertainment - can be appropriate, we must also remain vigilant to ensure nothing we do could create even an appearance of impropriety.
Bribes are “anything of value” intended to secure an improper advantage or otherwise inappropriately influence the recipient. This means anything that is valued by the person that someone is attempting to influence - whether or not it has any commercial value.
Before providing or accepting any gift or entertainment, apply ORA’s five gifts and entertainment criteria to confirm that it is:
Trade Compliance
We comply with all applicable international trade controls - including economic sanctions and export controls -
and we review all business opportunities to ensure compliance. International trade controls are laws that govern the cross-border transfer of goods, technology and services.
These laws include economic sanctions, which are legal measures that restrict where and with whom we can do business; and export controls, which are laws that impose special legal requirements like government licensing on the international transfer of certain goods, technology and services.
Export controls often apply in connection with highly regulated industry sectors like offshore and wind farms, measurement equipment and communication systems for crane vessels, or software with advanced data encryption capabilities.
As international trade controls may change over time, we are responsible for understanding the applicable policies and working with lawyers to ensure compliance.
International trade controls do not impose any specific requirements on the cross-border transfer of ordinary consumer items available to everyone in the retail marketplace, unless a prohibited country, organization or individual is involved in the transfer.
Our legal approved ORA AEO Declaration Dual Use & Strategic Goods document © is applicable for import- and export customs documentation and when carrying any customs documentation order, must in advance be undersigned by the legal representative of our clients.
Anti-money Laundering
We do not engage in any money laundering or terrorist financing activities or assist any other party in doing so, we escalate any red flags that we identify for further investigation.
ORA has zero tolerance for financial crime. This includes money laundering and terrorist financing. ORA is at a higher risk of being exposed to money laundering and terrorist financing activities when we:
Money laundering and terrorist financing are linked because terrorism is more often funded by money or assets that were obtained illegally, but then laundered to appear as if they came from a legitimate business.
ORA will not hesitate to- and will always- report any red flags of suspicious activity to the government where required.
Human Rights
We support and respect human rights as expressed in the International Bill of Human Rights and our commitment is our intent to align to the United Nations Guiding Principles on Business and Human Rights.
ORA seeks to uphold all internationally recognized human rights wherever its operations are located.
ORA adheres to all relevant government guidelines designed to ensure that products are not incorporated into weapons or other equipment used for the purposes of terrorism or abuse of human rights.
We speak up if we experience any human rights violations and take action, or reach out for guidance, if we witness or become aware of any violations.
We focus our human rights efforts on areas most relevant to our business and operations in terms of potential human rights impacts such as child labor, women traffic and modern slavery. Therefore, we continue to review human rights efforts across our operations, as well as best practices in the marketplace, to understand how we can further strengthen our commitment.
If it is unclear how to apply the law consistent with our human rights principles, we will seek to use good judgment consistent with our core values to support and respect the principles of internationally recognized human rights.
Speak up about disrespectful, inappropriate, fraudulent, unethical or illegal behavior. If you have a good faith concern about disrespectful, inappropriate, fraudulent, unethical or illegal behavior of any kind, ORA wants you to speak up. You can always escalate your concern without fear of retaliation if you do not receive an acceptable response from your first point of contact. We take seriously all concerns raised, including allegations of retaliation.
Act or reach out for guidance when approached about a concern involving disrespectful, inappropriate, fraudulent, unethical or illegal behavior. We take concerns seriously and act or otherwise raise them via the appropriate channel. We always seek to ensure it is handled confidentially and with sensitivity.
We compete fairly
ORA believes in competing fairly and vigorously in its market sectors. ORA does not engage in, nor is it party to, agreements, business practices or conduct that, as a matter of law, are anti-competitive.
We do not collaborate with competitors on how to price our services or whether to pursue opportunities in a particular market. We are fierce but fair competitors.
We act with integrity in all our business dealings
Because of proper business behavior ORA acts with integrity always to safeguard the trust in which ORA is held by its customers, shareholders, suppliers and other individuals and organizations with which our businesses interact.
ORA does not offer, promise, give, demand or accept bribes or other unethical advantage in order to obtain, retain or give business or other advantage.
Anti-Corruption & Bribery
At ORA we comply with anticorruption laws without exception. Our stance on corruption sometimes referred to as bribery, is very simple: Corruption is wrong, it is against the law and we don’t give or accept bribes. We comply with anticorruption laws - without exception, regardless of local business culture or practices.
Even if our competitors give bribes or make questionable payments, ORA has zero tolerance for bribery or any other activity that violates these laws.
We do not give or accept bribes. We pride ourselves on our relationships with our clients and understand that cultivating those relationships often is best accomplished in social settings - such as meals, sporting events or other forms of entertainment.
While ordinary relationship-building activities - including gifts and entertainment - can be appropriate, we must also remain vigilant to ensure nothing we do could create even an appearance of impropriety.
Bribes are “anything of value” intended to secure an improper advantage or otherwise inappropriately influence the recipient. This means anything that is valued by the person that someone is attempting to influence - whether or not it has any commercial value.
Before providing or accepting any gift or entertainment, apply ORA’s five gifts and entertainment criteria to confirm that it is:
- For a proper purpose and not intended to secure an improper advantage or otherwise inappropriately influence the recipient
- Permitted by law
- Permitted by ORA’s company policies
- Permitted by the recipient’s policies and by any agreements between ORA and the recipient’s employer
- Reasonable in value and appropriate under the circumstances
Trade Compliance
We comply with all applicable international trade controls - including economic sanctions and export controls -
and we review all business opportunities to ensure compliance. International trade controls are laws that govern the cross-border transfer of goods, technology and services.
These laws include economic sanctions, which are legal measures that restrict where and with whom we can do business; and export controls, which are laws that impose special legal requirements like government licensing on the international transfer of certain goods, technology and services.
Export controls often apply in connection with highly regulated industry sectors like offshore and wind farms, measurement equipment and communication systems for crane vessels, or software with advanced data encryption capabilities.
As international trade controls may change over time, we are responsible for understanding the applicable policies and working with lawyers to ensure compliance.
International trade controls do not impose any specific requirements on the cross-border transfer of ordinary consumer items available to everyone in the retail marketplace, unless a prohibited country, organization or individual is involved in the transfer.
Our legal approved ORA AEO Declaration Dual Use & Strategic Goods document © is applicable for import- and export customs documentation and when carrying any customs documentation order, must in advance be undersigned by the legal representative of our clients.
Anti-money Laundering
We do not engage in any money laundering or terrorist financing activities or assist any other party in doing so, we escalate any red flags that we identify for further investigation.
ORA has zero tolerance for financial crime. This includes money laundering and terrorist financing. ORA is at a higher risk of being exposed to money laundering and terrorist financing activities when we:
- Handle funds or process financial transactions or applications on behalf of clients
- Conduct business in countries where there is little enforcement of laws prohibiting money laundering and terrorist financing activities
- Conduct business in countries where financial transparency standards (e.g., bank secrecy) make it easier to hide these activities, and therefore they are more widely prevalent
Money laundering and terrorist financing are linked because terrorism is more often funded by money or assets that were obtained illegally, but then laundered to appear as if they came from a legitimate business.
ORA will not hesitate to- and will always- report any red flags of suspicious activity to the government where required.
Human Rights
We support and respect human rights as expressed in the International Bill of Human Rights and our commitment is our intent to align to the United Nations Guiding Principles on Business and Human Rights.
ORA seeks to uphold all internationally recognized human rights wherever its operations are located.
ORA adheres to all relevant government guidelines designed to ensure that products are not incorporated into weapons or other equipment used for the purposes of terrorism or abuse of human rights.
We speak up if we experience any human rights violations and take action, or reach out for guidance, if we witness or become aware of any violations.
We focus our human rights efforts on areas most relevant to our business and operations in terms of potential human rights impacts such as child labor, women traffic and modern slavery. Therefore, we continue to review human rights efforts across our operations, as well as best practices in the marketplace, to understand how we can further strengthen our commitment.
If it is unclear how to apply the law consistent with our human rights principles, we will seek to use good judgment consistent with our core values to support and respect the principles of internationally recognized human rights.