Introduction

This Code of Conduct sets out Vopak’s general business principles.

Integrity has been and will be the key in establishing and maintaining our reputation and providing our quality services to our customers. We deem our reputation an asset just like our employees, the installations and barges we operate, and the services we provide.

Our objective is to preserve continuity of the company by maintaining a strong financial foundation and remaining a profitable business. This implies investing for sustainable growth and to weigh up short and long term interests, with due care and respect for our customers, employees, shareholders, neighbours, suppliers as well as the environment. We adhere to the principle of sustainable business practice, in the sense of dealing with respect for individuals, the environment and society as a whole, in combination with a healthy profitability.

We consider it vital that the Vopak employees understand and share our values and therefore comply with the Vopak way of doing business.

We have pulled together in this code of conduct a set of policies and guidelines of which we trust that it provides all Vopak employees an understandable framework they can adhere to in carrying out their responsibilities. We want all Vopak employees to comply with the provisions of this code not only with the letter of these policies, but also with the spirit thereof.

If employees have a concern about what is proper conduct for them or anyone else they should promptly raise that concern with their superior or the person designated by the Executive Board for this purpose. Any concern so raised shall be promptly and discreetly addressed with due care and respect.

Executive Board

 
I. INTEGRITY

Vopak conducts its business with integrity, honesty and fairness, with due respect for the interests of those with whom it is doing business and for the community at large. Integrity is essential to Vopak’s business and is not in any circumstances to be sacrificed for the sake of results or otherwise.

II. LEGAL COMPLIANCE

The Vopak companies comply with the laws and regulations of the countries in which they operate. These laws and regulations are numerous and often complex. Whenever any question arises, employees should seek guidance on these requirements from their superior or the company’s legal department.

III. EMPLOYEES

1. Vopak considers safe and healthy working conditions for its employees to be fundamental and a pre-requisite.
   
2. Vopak companies recruit, employ and promote employees on the sole basis of the qualifications and abilities (including reputation and reliability). Vopak endeavours to enable each individual to develop its talents in various ways (a.o. by offering training programs).
   
3. Vopak and its subsidiaries are committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. Vopak expects that all relationships among persons in the workplace will be business-like and free of bias, prejudice and harassment.
   
4. It is the policy of Vopak to ensure equal employment opportunity without discrimination or harassment on the basis of race, colour, national origin, religion, sex (with or without sexual conduct), age or any other characteristics protected by law. Vopak prohibits and will not tolerate any such discrimination or harassment.

IV. ENVIRONMENT, HEALTH AND SAFETY

Vopak is committed to conduct its operations in an environmentally sound and sustainable manner. To achieve protection of the health and safety of employees, customers and the public, Vopak has established procedures and compliance programs to ensure the minimum adverse impact on the environment. Such procedures and programs are periodically being reviewed and appraised.

V. DRUGS, ALCOHOL AND WEAPONS

It is the policy of Vopak and its subsidiaries to maintain a work environment at its terminals that is safe for employees and conducive to attaining high work standards. This statement is to notify and remind all employees and employees of contractors and other companies having access to a Vopak terminal, that unauthorised possession or use of drugs, narcotics, intoxicating beverages, firearms or weapons are not permitted on any Vopak terminal.

VI. CUSTOMERS AND SUPPLIERS

  Bribes
In dealing with customers and suppliers, which may include governmental bodies, Vopak stipulates that its managers and employees neither give nor receive bribes or anything of value in order to retain or bestow business or financial advantages.
Vopak employees are directed that any demand for or offer of such bribe or anything of value must be immediately rejected.

  Business Entertainments
Accepting and providing reasonable business entertainments in the course of the Company’s business is acceptable.

  Gifts
The giving of small business gifts to individuals should be decided on in consultation with the superior of the donating employee on the basis of local business practice and regulations. Gifts of a total value of up to EUR 100,  in any one year would in most cases not cause a conflict or give the appearance of causing a conflict.
An employee must declare to his or her immediate superiors, details of any gifts received from customers, suppliers or any other external party, and shall not retain such gifts without the consent of his or her superior.

  Payments to agents/Intermediaries
Payments to be made to agents or other intermediaries in connection with the awarding of contracts by customers should be measured against the services performed in return and should be cleared in advance with the member of the Executive Board having prime responsibility for the activity.

  Qualifications (sub)contractors
Vopak companies are required to retain (sub)contractors on the basis of the qualifications and abilities needed for the work to be performed including their reputation and reliability and to see to it that these contractors apply the same ethical business principles as applied by Vopak.

VII. CONFLICT OF INTERESTS

Vopak employees shall avoid personal activities and financial interests, which might be adverse to the interests of Vopak, produce conflicting loyalties or interests, or interfere with effective job performance or which involve the appearance of a conflict of interest.

Vopak accepts the concept of its employees to have private financial and/or business interests outside their professional activities with Vopak. However   to the extent these interests may have an interface with activities of Vopak companies   it invites these employees to report such interests to their superiors or the person designated by the Executive Board to keep a record thereof.

VIII. REPORTING

Vopak accounting   and operational records and supporting documents must accurately describe and reflect the nature of the transactions and shall be subject to audit. Undisclosed or unrecorded accounts, funds or assets will not be maintained or established.

IX. PUBLIC ACTIVITIES

Vopak does not participate in party politics nor makes payments to political parties or to the funds of groups whose activities are directed at promoting party interests.

When dealing with governments or other (governmental) agencies Vopak companies are encouraged to promote and defend their legitimate commercial objectives. They may do so directly or through bodies such as trade associations.

Vopak companies are encouraged to respond to requests from governments and other agencies including NGO’s for information, observations or opinions on issues relevant to their business and to participate in the development of proposed legislation or regulations in areas which may have an effect on their legitimate interests.

X. COMPETITION

Vopak believes in fair and open competition in compliance with applicable competition laws. From time to time Vopak provides guidance to employees to ensure that they continue to understand competition laws and apply them correctly.

XI. SECURITIES TRANSACTIONS

Employees must not engage in ‘insider trading’ in Vopak Securities based on confidential Vopak information, or give ‘tips’ to outsiders who might trade on the basis of such information. Vopak employees should adhere to the Insider Trading Rules 2006 on the holding of and concluding transactions in Vopak Securities, which are stated on Vopak’s website http://www.vopak.com/.

XII. APPLICATION

This Code applies to all Vopak companies world-wide. Any non-adherence to this Code will require the instant notification to the Executive Board.