Supplier Code of Conduct 2020

This statement is made by Seawind Ocean Technology (Seawind) and is made to outline our expectations with our suppliers and partners.

Our values

Our success is based on a clear vision and set of values. They set the tone, help create our culture, give us one common set of principles and are fundamental to ensuring a sustainable business. These values extend through our business into our partners and supply chain.  Our values are:

Excellent: Delivering the highest quality in everything we do. Taking a right first-time approach and managing our team, partners and supply chain appropriately.

Innovative: Using our technical and business expertise to create and develop new solutions that will save time, cost and carbon.

Respectful: Managing our teams, working with our partners and impacting the community with the highest level of respect.

Collaborative: Working with Seawind, developers, partners and communities to find the right solutions

At Seawind, doing the right thing guides how we work and live. Seawind strives to protect and enhance the human dignity of our personnel and everyone who has dealings with our Company.

We require our supply chain partners to adhere to these values, formalised in our supply chain contracts and expect them to enforce these same principles upon their suppliers.

Governance

Leadership to ensure that our suppliers and partners and delivering on the promises that they make to Seawind is of paramount importance. In working with our suppliers, we at Seawind will identify, prevent, detect and remedy and issues with substandard quality or performance. Ultimately, we will close contracts and report suppliers to the relevant authorities if we find evidence of any inappropriate or illegal activities. This process is overseen by the Seawind CEO.  

Expectations from Our Suppliers and Partners.

The following are the key expectations we place on ourselves, our partners and our suppliers:

Employees and Service Users

1.1 Respectful treatment

Our employees, those of our suppliers, and service users have the right to respectful treatment. We will not tolerate discrimination, harassment or victimisation in the workplace or in connection with any service we provide. We expect our suppliers to provide the same commitment, including to their own employees; and adhere to local and national laws that protects against discrimination, harassment and victimisation.

1.2 Professional behaviour

We will work constructively and collaboratively with our suppliers. We expect suppliers to be prepared to invest in their relationships with Seawind and establish trust with our staff and with other suppliers involved in delivery. We also expect suppliers to be able to speak out when Seawind employees or other suppliers are not upholding our core values or this Supplier Code of Conduct. We also expect suppliers to speak out, without fear of consequences, when a project or service is unlikely to succeed because of our behaviours or a lack of good governance. We expect the same behaviour when a contract is no longer fit for purpose, for example, in its contractual stipulations or measures.

1.3 Meeting user needs

It is important that contracts with our suppliers meet the needs of our customers. We will work together with suppliers to articulate these outcomes to ensure that the goods and services being provided meet the needs of users and we expect fully reciprocal behaviour from suppliers.

1.4 Human rights and employment law

Seawind and suppliers must both comply with all applicable human rights and employment laws in the jurisdictions in which they work. In addition, suppliers must have robust means of ensuring that the subcontractors in their supply chain also comply.

2 Business practices

2.1 Management of risk

Our aim is to ensure that risk is allocated to the party best able to manage it. To assist us in making that judgement we will, where appropriate, engage with the market to understand its views in order to make informed decisions. We do not expect suppliers or Seawind to be made responsible for managing a risk that is best managed by the other party. We expect suppliers not to pass down risk inappropriately to subcontractors, and not to assert that they can manage risk that is in fact better managed by Seawind. All parties should be prepared to share intelligence of supply chain risks, so that material commercial and operational risks, for example the impact of losing a key supplier, can be mitigated.

2.2 Continuous improvement

We expect our suppliers to use recognised industry practices in the delivery of goods and services to, or on behalf of, Seawind. We also expect suppliers to continuously improve these goods and services and bring innovation, ideas and expertise to help Seawind address its strategic challenges. We will endeavour to create the right conditions to allow suppliers to innovate both during the procurement process and the life of a contract and where appropriate we will inform suppliers of our innovation requirements during the procurement process.

2.3 End-to-end Delivery

Some of the services that Seawind requires are complex, and no single supplier will have complete contractual responsibility for every element of what is needed to deliver to the end service user. In such cases, we will endeavour to create and maintain a culture that facilitates collaboration between all suppliers and Seawind to ensure that the right service outcomes are achieved. In order to achieve this, we expect suppliers to be aware of how they contribute to that overall delivery, and to work collaboratively with Seawind and other suppliers to manage mutual dependencies and ensure that their product or service is used effectively in the delivery of a high quality service.

2.5 Data Quality

A robust delivery model including its pricing structure is dependent on the quality of data on which it is based. Seawind will provide accurate data and/or build in flexibility (consistent with procurement legislation) to allow for subsequent validation of data. For Seawind to be able to do this, where a contract is being re- procured, we will require incumbent suppliers to act in a timely manner and be forthcoming with information required for scoping the re-procurement and thetendering process (for example workforce information) and to behave in accordance with any required standards. As per the contractual obligations, this information should be provided promptly when requested by Seawind and updated as required, for example, during any transitional phase leading to transfer of the provision of the services.

2.5 Value

Seawind’s customers expects Seawind to deliver value. This means that contracts should be priced to offer sustainable value throughout their life, including when changes are needed. Whilst we accept that our suppliers make a fair profit margin in return for the risk they are accepting and the commitments and investments they make in order to be able to deliver services for us, we expect suppliers not to exploit an incumbent or monopoly position, an urgent situation or an asymmetry of capability or information to impose opportunistic pricing.

2.6 Reputation and Public Trust

We want to work with suppliers who are proud of their reputation for fair dealing and quality delivery. We want working with Seawind to be seen as reputation enhancing for the supplier. We expect all parties to be mindful of the need to maintain customer trust and protective of Seawind’s reputation, and ensure that neither they, nor any of their partners or subcontractors, bring Seawind into disrepute by engaging in any act or omission which is reasonably likely to diminish the trust that the public places in Seawind.

2.7 Cyber Security

It is essential that suppliers safeguard the integrity and security of both their own IT equipment and the information passed to Seawind. Suppliers must inform the Seawind if they become aware of any cyber security incident that affects or has the potential to affect Seawind data.

2.8 Sustainable Procurement

We expect our suppliers to be aware of, and support Seawind in producing equipment that balances cost and carbon. We expect our suppliers to assist Seawind in the understanding and reduction of supply chain impacts on our environment, and risks related to the security of raw material supply. We expect suppliers to be open and transparent in assisting Seawind in reporting on product or service utilisation and any environmental impacts.

2.9 Confidentiality

Seawind and suppliers are both expected to comply with the provisions in our contracts and any legal requirements to protect commercial and sensitive information. Seawind and suppliers may both also be party to confidential information that is necessary to be effective partners.

2.11 Conflicts of Interest

We expect suppliers to mitigate appropriately against any real or perceived conflict of interest through their work with Seawind. A supplier with a position of influence gained through a contract should not use that position to unfairly disadvantage any other supplier or reduce the potential for future competition.

Looking ahead

Seawind is committed to continually developing our approach to supply chain management and seeks to be recognised as a global leader in good practice. Therefore, we will review and evolve how we operate on an annual basis.

Vincent Dewulf

Chief Executive Officer

December 2019