Personal responsibility and reporting procedures in the event of violation
If an employee has questions related to practical situations (e.g. giving or receiving of gifts/favours, or conflicts of interest), the immediate manager should be consulted in the first instance.
If an employee suspects behaviour that deviates from the Code of Conduct, this should be reported to the immediate manager as soon as possible. If the latter is involved or otherwise disqualified, the incident should be reported to the next-highest manager or in accordance with the reporting instruction for the company concerned. An employee who suspects behaviour that deviates from the Code of Conduct can always contact Seafire’s CEO regarding the incident, or with Seafire’s Whistleblower as an alternative way of reporting the violation.
All reports shall be taken seriously and investigated where necessary. There shall be no form
of retaliation (termination, harassment, discrimination etc.) for reporting in good faith
deviations from the Code of Conduct or participation in the company’s investigation of a