Polar Seafood does not tolerate bribery or corruption. Our policy applies to employees and sets expectations for persons acting on our behalf and for relevant business partners.

Employees and representatives of Polar Seafood must not offer, promise, give, request or accept money, gifts, services or other benefits intended to improperly influence a decision or obtain an improper advantage.

Our approach includes the following principles:

• facilitation payments are prohibited;

• cash and cash-equivalent gifts must not be offered or accepted;

• other gifts and hospitality must be lawful, modest, infrequent, transparent and appropriate to the business relationship;

• gifts and hospitality must never be intended, or reasonably appear to be intended, to influence a decision improperly;

• actual or potential conflicts of interest must be disclosed and handled in accordance with applicable internal procedures;

• Polar Seafood does not make contributions to political parties;

• charitable donations and sponsorships must be appropriately approved and must not be used to obtain an improper business advantage.

Anti-corruption controls and due diligence are adapted to the relevant activities and risks. Concerns may be reported through a manager, the relevant Group function or an available whistleblower channel.