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Ethics and Compliance
SBM Offshore Ethics and Compliance Program
SBM Offshore is committed to conducting its business ethically, lawfully and professionally in the best interests of SBM Offshore, thereby upholding its reputation and credibility.
Our Code of Conduct is grounded in our Core Values and serves as a guide in making responsible decisions. It outlines the standards we must follow when interacting with each other as well as with third parties, ensuring that our actions reflect our commitment to integrity at all levels.
Our aim is to enable our employees and business partners to make the right decisions, with commitment to integrity at all levels.
Therefore, SBM Offshore has implemented a comprehensive Ethics and Compliance program applicable for all entities of the SBM Offshore Group. It is designed to prevent, detect and respond to compliance risks and promote an ethical culture, in line with our Core Values and Code of Conduct.
The Code is supplemented by our policies and procedures, periodically updated, that provide further information and guidance on how to apply the principles outlined in the Code.
The Code of Conduct Builds on Our Core Values
The Code of Conduct is based on our four Core Values – Integrity, Care, Collaboration and Ownership – which form the heart of what we do as a company and as individuals. They provide the framework to ensure that we act responsibly and ethically in every business situation.
Core Principles from Our Code of Conduct
- Always comply with laws, regulations, policies, and procedures
- Consistently display exemplary behavior and embody our Values
- Treat all individuals fairly, respectfully, and equally, without discrimination
- Target Excellence, apply a right-first-time approach and create a safe workplace
- Maintain high integrity standards in all dealings, especially with third parties and public officials
- Avoid any actual or perceived conflicts of interest
- Optimize and transform daily activities to reduce environmental impact
- Protect confidential information and data
- Use the company’s assets appropriately
- Speak up or intervene when things are not (done) right
Our Code of Conduct
Our Code of Conduct serves as a behavioral and standards guideline for SBMers and for external parties, and reflects our company’s commitment to drive quality performance in a safe and compliant manner. It is applicable to all SBM Offshore’s board members, employees and contracted staff. Our business partners, (sub)contractors and suppliers are required and encouraged to act consistently with the Code of Conduct.
Code of Conduct (English)
Código de Conduta (Portuguese BR)
Código de Conduta (Portuguese PT)
行为准则 (Chinese)
Additional documents applicable to SBM Portugal:
Annex to the Code of Conduct, applicable for SBM Portugal (English)
Anexo ao Código de Conduta, aplicável à SBM Portugal (Portuguese PT)
Corporate Business Ethical Responsibility
SBM Offshore is committed to maintaining high standards of corporate integrity including zero tolerance to unethical behavior at all times across all SBM Offshore jurisdictions.
Our Business Ethics Policy
Our Business Ethics Policy sets out the ethical standards that must guide all business activities and interactions with third parties, covering topics such as Anti – Bribery and Corruption, Gifts, Hospitality, Entertainment (GHE), Donations and Sponsorships, Conflicts of Interest, Financial Records, Relationships with Third Parties, Trade Compliance, Economic Sanctions & Export Controls, Fraud Prevention and Anti – Money Laundering and Competition and Antitrust.
Business Ethics Policy (English)
Política de Ética Empresarial (Portuguese BR)
Política de Ética Empresarial (Portuguese PT)
Additional documents applicable to SBM Portugal:
Plano de Prevenção de Riscos de Corrupção e Infrações Conexas (PPR), aplicável à SBM Portugal (Portuguese PT)
Interim Evaluation Report of the PPR – October 2024, applicable for SBM Portugal (English)
Relatório de Avaliação Intercalar do PPR – Outubro 2024, aplicável à SBM Portugal (Portuguese PT)
Annual Evaluation Report of the PPR – SBM Portugal (English)
Relatório de Avaliação Anual do PPR – SBM Portugal (Portuguese PT)
Speak Up – We Care
At SBM Offshore, we promote an open culture which fosters trust and honest communication. We strive to create an inclusive environment where people feel encouraged and safe to speak up.
SBM Offshore has established internal channels for reporting any actual or suspected violations of our Code of Conduct, policies and procedures, and applicable legislation. Topics may include but are not limited to:
- Discrimination, racism, (sexual) harassment, modern slavery, and human rights violations;
- Violation of health, safety, security and environment (HSSE) procedures;
- Fraud, bribery or tax evasion;
- Conflict of interest;
- Anti-competitive behavior;
- Insider trading;
- Leakage of confidential information or personal data;
- Any act which may harm SBM Offshore’s vital interest or reputation.
Speak up Line
Our Speak Up Line, operated by an independent third party, is available 24 hours a day, 365 days a year, supports multiple languages, and allows for anonymous and confidential reporting.
You can choose to report your concerns via a web form, a mobile application or a toll-free phone number (if available in your country):
- For web reporting, please visit the Speak Up Line website.
- For reporting via the Speak Up app:
- Download the mobile application “SpeakUp – Doing right, made easy” via the App Store or Google Play
- Scan the QR code provided, or
- Select “Connect Manually” and enter our organization code: 117581.
- For phone reporting, please browse through the list of phone numbers and use the one related to your country. Then, enter our organization code: 117581.
Speak Up Policy
Our Speak Up Policy outlines the different stages of handling reported concerns, ensures compliance with legal requirements and provides guidance on the available reporting channels and the procedure we will be following in handling your concern.
Speak Up Policy (English)
Política de Speak Up (Portuguese BR)
Política de Speak Up (Portuguese PT)
Data Privacy
SBM Offshore is subject to regulatory requirements for personal data protection set out in the EU legislation under the General Data Protection Regulation 2016/679 EC (GDPR) and all other non-EU applicable legislation (as LGPD, PIPL, PDPA).
Protection of Personal Data is highly valued in SBM Offshore, ensuring safe processing by implementing all appropriate technical and organizational measures to ensure protection of Data Subjects Personal Data against accidental or unlawful destruction, loss, alteration, unlawful disclosure or access to them and any unlawful processing, as well as to ensure the possibility of restoring availability and access to them.
Our Privacy Policy
Our Privacy Policy ensures that all SBM Offshore entities and its associated workforce, including employees (whether fixed term or permanent), contractors, interns, and seconded staff, comply with applicable laws regarding personal data protection.
Privacy Policy (English)
Política de Privacidade (Portuguese BR)
Política de Privacidade (Portuguese PT)