Business Code of Conduct and Ethics

Veson Nautical Business Code of Conduct and Ethics

August 2026

Our Values

Our values are core to who we are and how we do business every day. They guide and motivate each of us as we work with leading organizations across the globe, including our clients, partners, vendors, and colleagues. These principles reflect a way of life here at Veson Nautical and are a critical cornerstone of our success.

Do the right thing.
Take pride in your work.
Move forward.

Introduction

Veson is committed to fostering a respectful, inclusive, and professional environment. Our community is built on the principles of mutual respect, collaboration, and shared commitment to excellence. Our behaviors and actions, whether we interact in person, online, or through other mediums, significantly impact the well-being and success of our community members. We are driven by our core values and take ethics, sustainability, compliance, and legal matters seriously.

This Code of Conduct and Ethics reflects the standards Veson upholds across all of its operations and subsidiary companies. By embracing these standards, we contribute to a culture of respect, trust, and collaboration.

Whistleblower Policy

At Veson we are dedicated to maintaining the highest standards of integrity, transparency, and accountability in all our operations. Our commitment to ethical conduct and compliance with applicable laws and regulations is fundamental to our mission and values. To support this commitment, Veson has instituted a Whistleblower Policy. This policy is designed to encourage and protect individuals who report misconduct, illegal activities, disrespectful behavior, or policy violations, including policy violations under this Code of Conduct and Ethics. It provides a safe, confidential channel for employees, contractors, volunteers, and other stakeholders to raise concerns in good faith without fear of retaliation.

Anti Bribery and Corruption Policy

At Veson, we are committed to upholding the highest standards of integrity, transparency, and ethical conduct in all our dealings. Corruption, bribery, and any form of unethical behavior undermine the trust placed in us by our stakeholders, distort markets, and impede sustainable development. Therefore, we have established our Bribery and Anti-Corruption Policy, which outlines our firm stance against these practices and provides a framework for their prevention and detection. In summary, this policy specifically states that members of the Veson community may not directly or indirectly:

Make, promise, approve, authorize, or offer to give anything of value to anyone (including but not limited to cash payments) for the purpose of improperly inducing the recipient to take (or to refrain from taking) action that would bestow a benefit on Veson or any other party; or
Receive or accept anything of value (including but not limited to cash payments) if such item is intended to induce or reward improper performance of one’s responsibilities or duties or to gain an improper advantage.

Veson employees and directors are not permitted to offer or accept any gifts or hospitality of value. Small value, customary gifts and hospitality are acceptable.

Conflicts of Interest

Employees and directors are required to disclose any actual or potential conflict of interest they may have when dealing in any professional capacity as part of their employment or work with Veson Nautical. This includes but is not limited to personal relationships with clients, suppliers and contractors, or service providers. In cases of a conflict of interest, the relevant person must disclose the conflict and remove themselves from any position where that conflict arises.

Fraud and Fair Dealing

Veson strives to be an ethical company and employer. This extends to how we compete with others. We do not condone any fraudulent or otherwise illegal behavior in the pursuit of our goals and clients. Veson is committed to compliance with anti-trust and competition law in the jurisdictions in which it operates. Employees are expected to maintain accurate and complete business records and financial data. Employees who engage in fraudulent or illegal behavior will face disciplinary action, up to and including termination.

Employees are encouraged to report any suspected fraudulent or otherwise illegal activity in good faith under the Whistleblower Policy.

Legal Compliance

Compliance Statement and Monitoring

Veson is committed to compliance with applicable laws and regulations in the jurisdictions in which it operates. We periodically perform compliance checks to ensure we remain up to date with our obligations. If any rules within this Code of Conduct and Ethics conflict with applicable laws and regulations, employees, and directors are expected to prioritize legal compliance.

Client Privacy and Confidentiality

Veson employees who access or handle client or company confidential data must do so lawfully, responsibly, and only to the extent necessary to carry out their responsibilities. Veson is committed to keeping confidential data protected and expects employees to use such data only in connection with a legitimate business purpose, whether during or after employment with Veson. Employees are expected to follow Veson’s data protection and information security practices when handling this information.

Modern Slavery and Supply Chains

Veson complies with its obligations under the UK Modern Slavery Act 2015. To access our Modern Slavery and Human Trafficking Statement visit: https://veson.com/modern-slavery-statement/.

We are dedicated to the monitoring and prevention of modern slavery, human trafficking, forced labor, and child labor, within our operations and supply chains.

Respectful Workplace Policy

Harassment and Discrimination

Veson is dedicated to fostering a workplace environment where every individual is treated with respect and dignity. Our success as an organization is built on the foundation of mutual respect and collaboration, and we believe that a respectful workplace is essential for the well-being and productivity of all our employees.

Veson has instituted a Respectful Workplace Policy which outlines our commitment to creating and maintaining a positive, inclusive, and supportive work environment. We recognize that workplace conflict or poor working relationships have the potential to escalate into discriminatory behaviors and harassment which may affect workplace and individual well-being. Unlawful discrimination, harassment, retaliation, victimization, and bullying will not be tolerated. We are devoted to ensuring that all employees, regardless of their role, background, or personal characteristics, feel valued and empowered to contribute to their fullest potential. Complaints of negative or inappropriate workplace behaviors will be taken seriously and investigated in accordance with applicable local legislation.

Working Conditions

Veson is committed to complying with applicable local laws governing working hours, overtime, wages, and legally mandated benefits. Veson is also committed to providing a safe and healthy working environment in accordance with applicable health and safety laws and regulations.

Diversity, Equity, Belonging, and Inclusion (DEBI)

We are committed to fostering a diverse, equitable, and inclusive environment where every individual feels like they belong and feels valued and empowered to bring their whole selves to work. We believe that our strength lies in the diverse perspectives, experiences, and backgrounds that our employees bring to the table. Embracing diversity and inclusion is not only a moral imperative but also a strategic advantage that drives innovation, creativity, and success.

We are dedicated to creating a workplace that reflects the diverse communities we serve and where everyone has an equal opportunity to thrive. We are committed to dismantling barriers, challenging biases, and fostering a culture where all voices are heard and respected.

Our approach to DEBI is grounded in the following principles:

Diversity: We celebrate and value the unique attributes, experiences, and backgrounds of our employees. We are dedicated to building a workforce that reflects the diversity of our global community.
Equity: We strive to ensure fair treatment, access, and opportunities for all individuals. We are committed to identifying and eliminating systemic inequalities that may exist within our policies, practices, and culture.
Belonging: We aim to create an environment where everyone feels welcome and a sense of belonging. We believe that when individuals feel they truly belong, they are more engaged, productive, and motivated.
Inclusion: We actively seek to create a culture where all individuals feel included and respected. We encourage diverse perspectives and foster an environment where everyone can contribute to their fullest potential.

We recognize that achieving these goals requires ongoing effort, reflection, and commitment from all members of our organization. We are dedicated to continuous learning and improvement, and we will hold ourselves accountable by periodically assessing our progress.

By adhering to this DEBI Statement, we affirm our commitment to building a more inclusive and equitable workplace. Veson Nautical is committed to compliance with applicable federal, state, and local laws governing discrimination in employment. We believe that fostering a culture of diversity, equity, belonging, and inclusion is not only the right thing to do but also essential to our long-term success and sustainability.

Environmental Goal Statement

Veson recognizes the critical importance of environmental stewardship and our role in promoting a sustainable future. As responsible corporate citizens, we are committed to minimizing our environmental impact and actively contributing to the preservation of our planet for future generations. This Environmental Goal Statement outlines our dedication to integrating sustainable practices into every aspect of our operations.

We acknowledge that our actions have significant implications for the environment, and we are determined to make positive changes that reflect our commitment to sustainability. Our environmental goals are designed to address pressing environmental challenges such as climate change, resource depletion, pollution, and biodiversity loss. By setting ambitious yet achievable targets, we aim to reduce our carbon footprint, conserve natural resources, and promote ecological balance.

This commitment extends to all areas of our business, from product design to community engagement. We strive to innovate and adopt best practices that enhance our environmental performance and support global sustainability efforts. Transparency and accountability are central to our approach, and we will periodically assess our progress toward these goals.

We understand that achieving our environmental objectives requires the collective efforts of our employees, partners, and stakeholders. Therefore, we foster a culture of environmental awareness and responsibility within our organization and collaborate with others who share our vision of a sustainable future.

By adhering to this Environmental Goal Statement, we reaffirm our dedication to environmental excellence and our belief that sustainable practices are essential to the long-term success and viability of Veson. We are committed to leading by example and inspiring others to join us in our pursuit of a healthier and more sustainable world.

We are committed to taking a leadership role as responsible stewards of the physical environment. This commitment includes:

Purchasing environmentally preferable products (high energy efficiency ratings, use of post-consumer recycled products, used products, etc.)
Minimizing the use of toxic substances and handling waste responsibly
Conserving natural resources through recycling and reuse
Centrally locating our offices so that employees can use public transportation and reduce their carbon footprint
Investing in non-profit organizations that support and safeguard the environment