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Environmental Policy

Introduction

Offshore Global Logistics Ltd is a logistics and supply chain firm whose operations span across the East African region. We pride ourselves in being at the forefront of end-to-end supply chain solutions through providing innovative, proactive, cost-effective services to our customers and in a sustainable.

Message from Management:
Our company’s reputation is above all founded on the quality of its people who are highly experienced, professional and dynamic individuals with a driving commitment to customer service.
Our company is committed to operating in a way that minimizes our impact on the environment, promotes positive social outcomes, and ensures good governance practices. This ESG manual outlines our policies, practices, and procedures in these areas.


Purpose

The purpose of this ESG policy is to outline Offshore Global Logistics’ ESG and responsible investment philosophy and its commitments and by doing so provide guidelines for how ESG aspects are handled in our operations. Offshore’s day-to-day management of ESG matters and how it is integrated across the company is the responsibility of the management. The Management of Offshore Global Logistics shall constitute ESG Committee and the ESG Committee will assist with handling all ESG related matters.
Environmental, social, and governance (ESG) criteria have been used for years to assess a company’s performance beyond the black-and-white lines of a profit-and-loss statement, challenging executives to measure the value their businesses create in the context of more fundamental ethical values.
For Logistics sector, an ESG framework calls for sustainable energy and waste management systems, investment in community health, and demands that leaders embrace diversity and inclusion as essential duties.

Standards

The Offshore Global Logistics Environmental Social and Governance policy shall meet the following:
  • Host Country Environmental and Labour Legislation;
  • IFC Environmental and Social Performance Standards;
  • Sustainability principles advocated by the UN Global Compact;
  • UN Guiding Principles on Business and Human Rights;
  • ILO Declaration on Fundamental Principles and Rights at Work;
  • International Bill of Human Rights.

Principles

Sustainability - The guiding ESG policy and Environmental and Social Management System (ESMS) established by Offshore Global Logistics provides an opportunity to incorporate environmental and social considerations in the design of the climate change mitigation activities to ensure sustainability.
Do No Significant Harm – any operatins activity cannot cause significant harm to any of the following objectives: climate change mitigation, climate change adaptation, sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, protection and restoration of biodiversity and ecosystem.
The IFC’s mitigation hierarchy - is adopted, which aims to anticipate and avoid, or where avoidance is not possible, minimize or mitigate, and, where residual impacts remain, compensate/offset for risks and impacts to workers, affected communities, and the environment. Fit for purpose - To achieve this, the DPs will adopt a risk-based approach to ensure that E&S requirements and processes are commensurate with the level of risk and nature of the projects.
Gender equality - A gender-sensitive approach will be adopted as part of identifying social risks and impacts which will link the corresponding gender risk management measures to activity-level gender action plans.
Offshore Global Logistics shall design and implement projects and programmes in a manner that will promote, protect and fulfil universal human rights recognized by the United Nations as well as respect workers’ rights in line with the ILO Declaration on Fundamental Principles and Rights at Work, prohibiting forced, compulsory and child labour including in supply chain.
The design and implementation of activities will be guided by the rights and responsibilities set forth in the United Nations Declaration on the Rights of Indigenous Peoples.

ESG Policy Statement

Offshore Global Logistics recognizes that our operations can have impacts on the environment. We also believe that it has a responsibility to positively impact communities in which we operate and recognizes that good governance practices are essential for the long-term success of our company.
  • To ensure that we have minimized the impacts to the environment, have a positive impact to the community and good governance, Offshore Global Logistics is committed to;
  • Complying with all applicable environmental laws and regulations;
  • Monitoring our environmental impact, including our carbon emissions, and setting goals to reduce it over time;
  • Reducing waste by promoting recycling and minimizing the use of single-use materials;
  • Conserving natural resources, such as water and energy, through efficient operations and sourcing of materials;
  • Working with our suppliers to ensure they adhere to the same environmental standards as us;
  • Treating our employees fairly and with respect, providing them with a safe and healthy working environment;
  • Promoting diversity and inclusion in our workforce, recognizing the value of different perspectives and experiences;
  • Engaging with our stakeholders, including customers, suppliers, and the wider community, to understand their needs and concerns, and to respond to them in a responsible way;
  • Supporting social causes and charities through philanthropic efforts;
  • Ensuring our board of directors is diverse and independent, with appropriate skills and experience to provide effective oversight and guidance;
  • Maintaining strong ethical standards and a culture of integrity throughout our company;
  • Being transparent in our reporting, providing timely and accurate information to stakeholders about our operations, financial performance, and ESG practices; and
  • Identifying and managing risks to our business, including those related to ESG factors, and reporting on those risks to stakeholders.

Conclusion

Our company is committed to operating in a way that is environmentally sustainable, socially responsible, and governed with integrity. We believe that by doing so, we can create long-term value for our stakeholders and contribute to a better world for future generations.

ESG Governance Structure, Roles and Responsibilities

For ESG framework to function properly, it is essential that roles and responsibilities for carrying out the necessary procedures and making decisions are clearly defined. This section defines roles and responsibility of key stakeholders in the ESG framework implementation which is summarized in the below:
  • Offshore Global Logistics shall develop an effective governance structure with a clear set of roles and responsibilities in order to implement the ESG;
  • The approach for developing an ESG governance structure is based on a holistic approach to sustainability, with a joined-up structure that operates across the Company. Integration is thus required across business teams dealing with different customer segments, geographies, business functions, product, and revenue models;
  • The ESG governance structure and corresponding roles and responsibilities are developed in a way to gradually develop a cross-functional team of people trained and calibrated on ESG aspects; and
  • The ESG governance structure for the company represents all the relevant internal business and operations areas, led by a member of the Leadership Team. The performance related to various ESG aspects is reviewed at the Leadership;

The following ESG governance structure is adopted for ESG management as part of core business functions: The Company understands the importance of a clear and robust ESG governance structure, which is an essential component for long-term success.

ESG Objectives

ESG objectives of Offshore Global Logistics are developed to guide our efforts to build sustainable development capability and ensure that ESG considerations are integrated into all of our business decisions and every operational level. Our ESG objectives are based on six strategic pillars:

Governance

Objective: we strive to conduct business according to the highest ethical and legal/regulatory standards, while being timely in communicating our performance To achieve this, we are pursuing and strengthening the following:
  • Corporate governance
  • Risk management
  • Disclosure and reporting

Economic Performance:

Objective: we strive to create long-term and sustainable value for investors and shareholders. To achieve this, we are pursuing and strengthening the following:
  • Financial performance
  • Investor relations

Environmental Performance:

Objective: we strive to design, construct and manage our trucks, operations and buildings sustainably with the aim of minimizing the environmental impact of our operations and improving the efficient use of resources. To achieve this, we are managing the following key impact areas of our operations:
  • Climate change
  • Energy management
  • Waste management
  • Water management
  • Green building certificates

Employees:

Objective: we strive to ensure that all employees receive fair and impartial treatment, operate in a safe and comfortable working environment as well as a sustainable career platform. To achieve this, we are focused on the core areas of:
  • Talent attraction and retention
  • Health, Safety and well-being
  • Diversity and inclusion

Partners:

Objective: we strive to forge long-term and responsible partnerships with our business partners and other key parties to enhance ESG performance together. We have identified a number of important partners who can support and benefit from our ESG objectives:
  • Suppliers
  • Partners
  • Contractors
  • Industrial associations

Communities:

Objective: we strive to transform places into vibrant and sustainable communities as well as appropriately integrate communities’ livability into our decision-making. To achieve this, we are focused on the core areas of:
  • Community investment and volunteering
  • Community engagement
  • Local economy

ESG Committee

An ESG Committee dedicated to identifying, managing and evaluating environmental, social and governance issues shall be established. The ESG Committee is chaired by the Managing Director and comprises representative from all departments.

Diversity Equity and Inclusivity

Offshore Global Logistics supports equal opportunity in its employment practices, including the selection, hiring, promotion, transfer, and compensation of qualified applicants and employees without regard to any characteristic protected by applicable law, including, but not limited to, race and/or ethnicity, color, gender, gender identity, gender expression, sexual orientation, age, religion or belief, national origin or ancestry, citizenship status, language, political affiliation, social or economic status, veteran or military status, marital status, familial status, pregnancy, physical or mental disability, medical conditions, genetic information. Offshore Global Logistics does not tolerate harassment of any of its employees, applicants, vendors or customers, and seeks to maintain a work environment free from harassment. Any form of harassment related to an individual’s race and/or ethnicity, color, gender, gender identity, gender expression, sexual orientation, age, religion or belief, national origin or ancestry, citizenship status, language, political affiliation, social or economic status, veteran or military status, marital status, familial status, pregnancy, physical or mental disability, medical conditions, genetic information, and/or any other characteristic protected by applicable law is a violation of this policy and is treated as a disciplinary matter.

ESG Performance Evaluation System

To further consolidate our commitment to sustainable development, we have developed a vision with specific targets for 2030, with the aim of monitoring the continuous improvement of ESG performance. The ESG committee should review on an annual basis the ESG performance of the Company in achieving targets. The employees’ ESG-related performance is incorporated into their overall functional performance, though the evaluation criteria may differ in different employee types. Written recognition, rewards as well as monetary benefits are contingent upon the achievement of the annual performance targets.

Stakeholder Engagement Measures

Key stakeholders have an impact on Offshore Global Logistics and are closely related to our business, which are shareholders/investors, government authorities, neighbors, partners, employees and communities/ nongovernmental, non-profit organizations (NGOs). We are committed to establishing multi-faceted communication and contacts with all stakeholders in order to have in-depth understanding and actively respond to stakeholders’ opinions and demands. The impacts of our operations on stakeholders should be periodically assessed, measured and reported.

Monitoring and Reporting

Offshore Global Logistics shall adopt a robust set of procedures to ensure that the business activities are in line with ESG requirements, and there is a process of undertaking continual assessment and improvement to the ESG procedures. The Management of Offshore Global Logistics shall nominate the ESG Committee and ESG Leader. The ESG Leader shall evaluate the adherence to ESG principles and procedures on quarterly and on an annual basis through an annual performance monitoring process. These include:
  • Quarterly monitoring procedures to track the progress made towards ESG integration
  • Half-yearly reporting to the ESG management committee by the ESG Leader
  • Annual review and monitoring procedures which includes annual performance assessment, implementation of upgrades to the ESG, including an update to the training programs.
  • The ESG Committee shall half yearly report to the Board of Directors of the Company

Labour Management

Scope and Purpose

The Labour Management Plan, LMP, is intended to set out the responsibilities and the management practices associated with the management of labour in all Offshore’s operations. Its focus is to ensure that all Offshore’s operations comply with applicable environmental, health and safety and social requirements, ensure that all personnel associated with Offshore comply with the obligations of the labour management and implement applicable Good International Practices (GIIPs) and to manage labour related issues in an appropriate manner. The LMP applies to all personnel involved in Offshore’s operations. All personnel include the part-time, temporary, seasonal, and migrant employees, contractors and their subcontractors and their employees and lastly the primary suppliers. Objective The objectives of this Plan are to:
  • Promote fair and equitable labour practices for the fair treatment, non-discrimination and equal opportunity of workers;
  • Establish, manage and promote a healthy management-worker relationship;
  • Protect workers’ rights including migrant and third party workers; and
  • Promote healthy, safe, secure and comfortable accommodation that does not impact negatively on the communities in the surrounding area;
  • Address child labour, and prevent worst forms of child labour;
  • Prevent the use of all forms of forced labour;
  • Protect workers, including vulnerable workers such as women, persons with disabilities and migrant workers, contracted workers, and primary supply workers, as appropriate;
  • Provide a Grievance Redress Mechanism (GRM) for workers to raise their concerns. Applicable Regulations, Standards and Guidelines
  • UN Guiding Principles on Business and Human Rights,
  • ILO Declaration on Fundamental Principles and Rights at Work,
  • The sustainability principles advocated by UN Global Compact

Roles and Responsibilities

Offshore will ensure that the LMP is regularly updated and all the changes or the updates have been communicated to all employees, contractors, subcontractors and the primary suppliers. It is the employee’s responsibility to comply with the plan or seek clarifications if needed. The following roles and responsibilities will be in the plan;

    E&S team
  • Lead in the development and review of the Labour Management Plan working closely with other departments;
  • Carry out self-assessment and monitor Offshore’s operations to determine if the plan has been implemented.
    • Departmental Managers
  • Ensure the department’s LMP are aligned to Offshore’s regulations and international practices;
  • Ensure provision of necessary resources, including budget and competent personnel are provided to manage labour issues being aligned with requirements and commitments; and
  • Ensure the Offshore’s LMP is monitored and regularly reviewed.
    • Human Resources team
  • Ensure all employees have access to the LMP at all times in a language they understand;
  • Working closely with the E&S teams to develop and implement the LMP;
  • Monitor working hours and overtime hours of employees to ensure compliance with law;
  • Working closely with the E&S team to receive grievance, ensure they are documented properly into the database;
  • Participate in the review, investigation, resolving and following up grievances; and
  • Ensuring that all employees have understood and signed the Code of Conduct.
    • Subcontractors
  • Develop their own Labour Management Plan in line with Offshore’s guidelines;
  • Implement the Labour Management Plan for all the Offshore’s operations they are supporting;
  • Ensure no child or forced labour is involved in the Offshore’s operations;
  • Develop a separate grievance mechanism which is in line with Offshore to collect and resolve grievance raised by their employees; and
  • Prepare and submit quarterly and annual report during their operations as per Offshore’s guidelines respectively.
    • Employees
      The Labour Management Policy shall be communicated in languages which are understood by the employees, contractors/subcontractors and primary suppliers for further compliance and implementation.
      The Labour Policy shall cover the following areas: Working Relationship, Working conditions & Terms of Employment, Gender Equity, Harassment and Abuse, Workers’ Organizations, No Discrimination & Equal opportunity, Retrenchment, Grievance Mechanism, Child Labour and Forced Labour, Occupational Health and Safety, Workers Engaged by Third Parties and Supply Chain.
      Labour Use on Offshore’s operations

      Categorization of the workforce

      The world Bank Environmental and Social Standards 2: Labour and Working (ESS2) categorizes workers into four categories:
      • Direct workers: People employed or engaged directly to work specifically for an operation.
      • Contracted workers: People employed or engaged by third party contractors to perform work related to core function of an operation, regardless of location.
      • Primary supply workers: People employed or engaged by the primary suppliers.
      • workers: People employed or engaged in providing community
      Any migrant worker who might be involved in Offshore’s operations like the international consultants will be required to adhere to individual countries laws regarding labour which include possessing a work permit.

      Assessment of Key Potential Labour Risks

      Most of the labour risks in Offshore’s operations will be associated with health and safety during the operational activities such as exposure to physical hazards such as: trip and fall hazards, exposure to noise, falling objects, exposure to hazardous materials and exposure to electrical hazards from the use of tools and machinery. Many workers will be exposed to occupational health and safety hazards, primarily including but not limited to:
      • Working at height
      • Movement and working on steep and treacherous terrain.
      • Traffic accidents.
      • Ergonomic hazards
      • Welding hazards (fumes, burns and radiation)
      • Steel erection (Racks) hazards.
      • Gender based violence (GBV) risks

      Terms and Conditions of Employment

      Terms and conditions of direct workers are determined by their individual contracts. Permanent staff will have individual agreements (labour contract or service contract) with fixed monthly wage rates all as agreeable with both parties for all Offshore operations. Recruitment procedures will be documented and filed in accordance to the requirements of in country labour legislation and the ESS2. Requirements and conditions of overtime and leave entitlements are agreed as part of individual contracts. Offshore will ensure that contractors are aware of, and comply with, labour management and OSH policies and procedures outlined in this LMP. Each contractor will be required to submit an assessment of environmental and social risks (including labour risks) associated with their activities and risk mitigation measures in accordance with the environmental and social requirements either quarterly or annually.

      Wage

      All Offshore employees will be paid based on their performance and skills regardless of employees’ characteristic such as gender, age, race, religion, disability, nationality, political beliefs, membership of unions, ethnic origin, religious beliefs, as well as sexual orientation. The base monthly salary shall be determined according to wage scale and shall not be lower than the regional minimum wage.

      Freedom of Association

      Offshore will recognize the freedom of its employees and those of its sub-contractors to be able to participate in collective bargaining agreements. Workers shall be allowed to establish and join work-based organizations if they wish to negotiate wages and other working conditions.

      Equality of Treatment

      The ILO conventions to be applied include the C 100 -Equal Remuneration 1951; and C111- Discrimination (Employment and Occupation 1958) Conventions. Discrimination means denying someone a job or training on the basis of a factor, which does not affect their ability to perform that job. Offshore is committed to ensuring that men and women hired for work receive equal rates of pay for equal types of work. It will not discriminate in its hiring and employment practices on any basis of sex, race, culture, religion, sexual orientation, or other aspect as per ILO convention.

      Age of Employment

      Offshore target countries have ratified both the ILO Minimum of Age Convention (C138) and the ILO Worst Forms of Child Labour Convention (C182). The minimum age of employment will be 18 years. To ensure compliance, all employees will be required to produce an identification form as per in country legislation to identity and age. This shall be applicable for contractors and their sub-contractors.

      Occupational Health and Safety

      The Offshore OHS measures are based on the requirements of the relevant sections of intranational best practices and country legislations. Offshore’s E&S team shall establish OSH guidelines for all workers, monitor and implement training on OHS for workers and establish a system for regular monitoring and reporting on OSH performance including documentation and reporting of occupational accidents, diseases and incidents. Offshore’s managers will ensure effective methods are put in place for responding to identified hazards and risks, establishing priorities for taking action and evaluating outcomes. Please refer OHS management plan below.

      Sexual Exploitation and Abuse and Sexual Harassment

      Provisions to prevent sexual exploitation and abuse and sexual harassment will be included in the Code of Conduct for staff and for contracted workers in line with relevant international standards and national legislation. A separate Sexual Exploitation and Abuse Harassment policy has been developed to ensure that all risks related to SEAH have been mitigated.

      Forced Labour and Child Labour

      Forced labour in line with ILO Convention is defined as any work or service extracted from a person under threat or penalty, which includes penal sanctions and the loss of rights and privileges, where the person has not offered him or herself voluntarily. It includes slavery and abduction, misuses of public and prison works, forced recruitment, debt bondage and domestic workers under forced labour situations, and internal or international human trafficking. Offshore commitments to follow the requirements are emphasized in the ILO conventions, IFC PS 2, GCF environmental and social policy and local relevant laws in terms of prohibition of forced labour in any form, including slavery and human trafficking. Offshore takes a firm stand against all forms of forced labour and expects the same of its primary suppliers, partners, contractors and subcontractors. Offshore will not tolerate child labour under circumstances. A clear distinction between child labour and young worker shall be established according to internationally recognized standards. The employment of young workers, I,e, minor aged 15 years to under 18 years who have reached the minimum age of employment and completed compulsory schooling, is allowed under strict conditions and in compliance with requirements of internationally recognized standards and local relevant laws and regulations.

      Worker Grievance mechanism

      Grievance mechanism entails a formal process for receiving, evaluating and redressing Offshore grievances from affected workers, communities and the general public. Typical work place grievances include demand for employment opportunities; labour wage rates; delays of payment; disagreement over working conditions; and health and safety concerns in work environment Offshore has established a Grievance Redress Mechanism which shall be applicable to managing labour related issues in all its operations. Training of workers, contractors, subcontractors, community, and suppliers on Grievance Redress mechanism shall be implemented. Please refer to Grievance Redress Mechanism above.

      Human Immunodeficiency Virus/ Acquired Immunodeficiency Syndrome (HIV/AIDS)

      Risky sexual behaviour and engagement in illicit sex by both genders is real risk. In order to counter the risk of spreading HIV/AIDS, the Offshore operations will develop a HIV/AIDS strategy or policy consistent with ESS2 and ESS4 that shall spell out sensitization and awareness creation strategies for contractors and other employees.

      Contractor Management

      Each contractor engaged by the Offshore to provide services will be expected to adopt the protective measures outlined in this document. The contracts drawn by Offshore will include provisions, measures and procedures to be put in place by the contractors to manage and monitor the relevant OHS, child labour, forced labour, and other employment terms and conditions issues.

      Primary Supply Workers

      Offshore will identify potential risks of child labour, forced labour, and serious safety issues which may arise in relation to primary suppliers as part of the environmental and social assessment in accordance with ESS2 para.39. Based on the scope there is potential for child labour, forced labour and safety risks related to the hazardous nature of the equipment to be procured. Offshore will conduct a mapping exercise to identify possible suppliers and the extent to which they may present the potential risks in accordance with ESS2 GN39.1. In case it will be impossible to identify specific primary suppliers, Offshore will review the general industry labour issues and risks relating to the supply of such specialized equipment for Offshore’s operations. Based on the provisions of ESS2 GN39.2 Offshore will periodically update the assessment of potential risks that may arise in relation to primary suppliers.

      Monitoring

      Offshore shall develop processes for monitoring, assessment and audit will be developed to document the implementation and effectiveness of management and mitigation measures, assess actual impacts against predicted impacts and demonstrated compliance with applicable legal and other requirements. Offshore will conduct both desktop and field-based inspections programs to confirm that specified mitigation measures are being implemented effectively and achieving the intended outcomes. SMART Performance indicators, both lagging and leading, shall be developed and shared.

      Reporting

      Offshore will ensure that a aperiodic report is complained to address the labour and working conditions which are contained in this plan. Some of the key areas to be included in the report include grievances lodged by the workers and community, induction training, number of employees, issues raised by workers committees, any incidents or accident reported among others.

      Training and Awareness

      A training need analysis shall be established to determine the relevant trainings which shall be conducted. The needs analysis will be based on the requirements of this plan. It involves a basic assessment of the knowledge and skills of the people involved in training implementation. Some of the key areas to be covered in training shall include disciplinary and grievance procedures, cultural awareness, code of conduct, health safety and security,, human rights awareness among others.

      Communication

      Offshore shall ensure that the Labour Management Plan is disclosed to its staff, contractors, subcontractors and O&M contractors. Any grievances raised by workers shall be logged and followed up in accordance with the Offshore Grievance Mechanism.

      Guideline on Code of Conduct

      A satisfactory code of conduct will contain obligations on all workers (including sub-contractors) that are suitable to address the following issues, as a minimum. Additional obligations may be added to respond to particular concerns based on the location and the sector or to specific operational requirements. The Code of Conduct will be written in plain language and signed by each worker to indicate that they have: received a copy of the code, had the code explained to them, acknowledged that adherence to this Code of Conduct is a condition of employment and understood that violations of the Code can result in serious consequences, up to and including dismissal, or referral to legal authorities. Offshore and her contractors will conduct awareness raising and training activities to ensure that workers abide by the Code of Conduct (such as through toolbox talks). The Contractor will also ensure that local communities are aware of the Code of Conduct and enable them to report any concerns or non-compliance. The issues to be addressed include:
      • Compliance with applicable laws, rules, and regulations of the jurisdiction
      • Compliance with applicable health and safety requirements (including wearing prescribed personal protective equipment (PPE), preventing avoidable accidents and a duty to report conditions or practices that pose a safety hazard or threaten the environment)
      • The use of illegal substances
      • Non-Discrimination (for example on the basis of family status, ethnicity, race, gender, religion, language, marital status, birth, age, disability, or political conviction)
      • Interactions with community members (for example to convey an attitude of respect and non-discrimination)
      • Sexual harassment(for example to prohibit use of language or behaviour, in particular towards women or children, that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate)
      • Violence or exploitation (for example the prohibition of the exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour)
      • Protection of children (including prohibitions against abuse, defilement, or otherwise unacceptable behaviour with children, limiting interactions with children, and ensuring their safety in all areas)
      • Sanitation requirements (for example, to ensure workers use specified sanitary facilities provided by their employer and not open areas)
      • Avoidance of conflicts of interest (such that benefits, contracts, or employment, or any sort of preferential treatment or favours, are not provided to any person with whom there is a financial, family, or personal connection)
      • Respecting reasonable work instructions (including regarding environmental and social norms)
      • Protection and proper use of property (for example, to prohibit theft, carelessness or waste)
      • Duty to report violations of this Code
      • No retaliation against workers who report violations of the Code, if that report is made in good faith.
      • Disturbing wildlife or bushmeat hunting workers prohibited under any circumstances from engaging in any disturbance of wildlife or bushmeat hunting during the entire duration of their employment/engagement

CORPORATE CODE OF CONDUCT

PREAMBE

Offshore Global Logistics Ltd is a logistics and supply chain firm whose operations span across the East African region. We pride ourselves in being at the forefront of end-to-end supply chain solutions through providing innovative, proactive, cost-effective services to our customers and in a sustainable way. Our company is committed to operating in a way that minimizes our impact on the environment, promotes positive social outcomes, and ensures good governance practices. It is of great importance that as we pursue the provision of the highest quality supply chain solutions, the highest standards of conduct and integrity be observed. Through this, we will bring more value to our customers and stakeholders while building trust and ultimately contributing to the enrichment of the values of our society. This code of conduct cuts across and applies to all our stakeholders, employees, shareholders, customers, business partners and consultants. For us to achieve this, Offshore Global logistics has set forth this Corporate Code of Conduct. We expect all our stakeholders to adhere to these standards and consider them as the minimum acceptable standards for doing business with Offshore Global Logistics Limited or any group of companies.

Principles and standards of business conduct.

Provision of quality services

We shall, at all times, endeavor to provide logistics and supply chain services of outstanding quality while paying close attention to the safety and integrity of both our business and those of our clients.

Compliance with Laws

Offshore Global Logistics complies with all the applicable laws and regulations of the countries it operates. It is therefore required that all our employees and stakeholders including contractors and agents observe the highest standards of conduct. Any businesses which contravene the laid down regulations must be turned down. Offshore shall not provide any services that are considered illegal.

Prohibition of Bribery

Offshore Global logistics prohibits payment or a promise to pay any financial or non-financial advantage of any form for the purpose of business or other gains. Employees of offshore Global Logistics are forbidden from demanding, accepting or accepting a promise of money or any form of reward for the purpose of any business or individual gain to the paying party. Prohibition of conflict of interest Offshore Global Logistics employees shall not engage into other activities, roles or tasks that can violate the interests of the company. We shall engage in trade with vendors with fairness and objectivity without violation of the interests of the company whether or not by promoting self-interests, those of a family member(s), relatives, friends, acquittances or organizations. Management must be informed whenever there is a financial participation (greater than one percent) by immediate family members.

Safeguarding company assets

Offshore Global Logistics places great value on the integrity of her employees. Our success is pegged on the innovativeness of our employees and the experience they have gained over the years. Therefore, all Offshore Global Logistics employees must ensure the business secrets of the company are kept secret. Publicizing operational and other business secrets without permission, passing information to third parties or use of information for self-gain is strictly forbidden. The use of Offshore Global logistics operational resources, including IT infrastructure by staff and stakeholders, including suppliers and clients for personal gain without the right approval, unless this has been allowed in the work contract is forbidden.

Public and Media dealings

At Offshore Global Logistics, we understand that providing the public and the media with well thought out, clear and consistent information strengthens our image. Therefore, all statements to the public or the media relating to Offshore Global Logistics can only be made after consultation and approval by the authorized employees.

Fair dealings

We value our customers, business partners and suppliers. Employees must deal fairly with our customers, business partners and suppliers and treat them with honesty and respect.

Theft and Fraud

Offshore Global Logistics employees must only use the company resources for legitimate business purposes and are mandated to protect them from theft, misuse or loss. Theft of company resources is a criminal offense.

Prohibition of conflict of interest

Offshore Global Logistics employees shall not engage into other activities, roles or tasks that can violate the interests of the company. We shall engage in trade with vendors with fairness and objectivity without violation of the interests of the company whether or not by promoting self-interests, those of a family member(s), relatives, friends, acquittances or organizations. Management must be informed whenever there is a financial participation (greater than one percent) by immediate family members.

Relationship with its People and the Society

Environmental protection

We shall uphold the legal regulations related to environmental protection and will engage actively in protection and preservation of the environment. Political and religious activities Offshore Global Logistics does not have any political or religious affiliations. The organization will not allow any political activities to be undertaken within its premises or during any of the business activities.

Prevention of Discrimination

Offshore Global Logistics guarantees its employees of a working environment free of discrimination. Any forms of aggravation or disadvantage on account of race, ethnic origin, religion, disability, age, gender or sexual identity will not be tolerated. We expect our employees and management to focus on promoting equality amongst fellow staff.

Creating and Maintaining Safe and Fair working Conditions

Offshore Global Logistics takes great responsibility for its employees and strives to ensure an attractive working environment. We strive to ensure the safety and health of our employees. We ensure fair renumeration and reasonable working hours in line with the laid out legal framework. We condemn strongly all forms of child or forced labor.

Social Contribution activities

As a good corporate citizen, Offshore Global Logistics promotes harmony with regional communities and the international society. We are actively engaged in social contribution activities through our business operations and sustainable development of our corporate value.

Sound corporate Accounting

Offshore Global Logistics shall ensure sound financial statements in compliance with the relevant laws and regulations.

Promoting Diversity

Offshore Global Logistics embraces the diversity of its employees and we recognize the importance of diversity in realizing sustainable growth through tapping into a wide range of human resources. Offshore Global Logistics Code of Conduct Version 2021.4.0

IMPLEMENTATION AND ORGANIZATION

All employees of Offshore Global Logistics Ltd are obliged to adhere by this Corporate Code of Conduct. Managerial staff are mandated with the responsibility of promoting the Code of Conduct as role models in their area of responsibility. The Code of conduct is reviewed regularly and adjusted in line with the current working conditions and legislation. Our stakeholders and clients will be notified of this corporate code of conduct.

ANTI-FRAUD & Anti-Corruption Policy

Scope and Purpose

The purpose of this Anti-Bribery & Anti-Corruption Policy is not only prevent bribery and corruption but also safeguard the integrity and reputation of Offshore Global Logistics. While this policy is comprehensive, it should be noted that stricter local laws or regulations will take precedence.

To whom does this Policy extend?

This policy is applicable to all individuals within Offshore Global Logistics, including employees, officers, and directors. It encompasses not only those directly employed by Offshore Global Logistics or its affiliates but also includes temporary workers who are assigned by a staffing agency to work on behalf of Offshore Global Logistics.

Where does this Policy Apply??

We are committed to conducting all our operations and activities in compliance with applicable laws and regulations. As a result, this policy is applicable to all Offshore Global Logistics activities worldwide.

What is Bribery and Corruption?

Corruption is the improper exploitation of entrusted power for personal gain or for the benefit of one's family, friends, or acquaintances. This can manifest in forms such as bribery, kickbacks, and conflicts of interest.
Bribery refers to the inappropriate act of offering, giving, promising, receiving, accepting, authorizing, or soliciting something valuable to or from a person or entity in order to gain or maintain a business or other advantages. The term "something valuable" encompasses both tangible and intangible goods, as well as other items or benefits that hold economic value.
Bribery encompasses a wide range of actions, including, but not limited to:
  • Public bribery involving individuals within the government sector.
  • Private bribery involving the commercial sector.
  • Both direct and indirect bribery, which may involve the use of intermediaries, agents, subcontractors, or other third parties to facilitate the exchange of bribes.
  • Kicking back a portion of a contract payment or any other form of benefit to another party, or receiving a kickback.
  • Facilitation payments, which refer to unofficial payments made to expedite actions that the payer is already entitled to, or other unofficial payments made to government officials in order to secure certain favours or advantages.

Offshore Global Logistics has a strict policy against bribery and corruption, which means that employees, officers, and directors are prohibited from engaging in the following activities:
  • Any form of bribery or corruption, whether active or passive, direct or indirect. Enabling such actions is also strictly forbidden.
  • Arranging, giving, offering, or approving bribes or any improper transfers of value, even if they are intended to benefit Offshore Global Logistics.
  • Involvement in facilitation payments, whether making, receiving, or participating in such transactions.
  • Soliciting or accepting bribes, kickbacks, or any improper transfers of value for personal gain or on behalf of family, friends, acquaintances, or co-workers.
  • Receiving, approving, or offering gifts or entertainment that are deemed unreasonable, inappropriate, or disproportionate. This applies regardless of whether the recipients are government officials or other business partners, as it should not unduly influence business decisions.
  • Holding external positions or engaging in activities outside of Offshore Global Logistics that could potentially create conflicts of interest or be perceived as such.
  • Engaging in actions that provide unwarranted preferential treatment, whether utilizing company resources or not, for the benefit of family, friends, acquaintances, or creating an appearance thereof.
  • Entering into agreements on behalf of Offshore Global Logistics that could be seen as conflicts of interest or give rise to such perceptions.
  • Making monetary or in-kind contributions, on behalf of Offshore Global Logistics, to government officials, political parties, organizations, or individuals involved in politics or charities closely associated with government officials

ORGANIZATIONAL MEASURES

Offshore Global Logistics has implemented a comprehensive set of controls to address potential issues related to bribery and corruption. These controls include:
  • Conducting regular risk assessments to identify areas of vulnerability and potential risks.
  • Establishing robust policies and guidelines that outline the expected behaviour and standards regarding bribery and corruption.
  • Providing training programs and effective communication channels to educate employees about their responsibilities and the company's zero-tolerance policy towards bribery and corruption.
  • Conducting audits and implementing monitoring systems to ensure compliance with the established policies and guidelines
  • Establishing clear reporting channels that allow employees, business partners, and other stakeholders to report any concerns or suspected violations related to bribery and corruption.
  • Initiating thorough investigations to assess reported concerns and allegations, and implementing appropriate disciplinary processes to address confirmed cases of bribery and corruption.

By implementing these measures, Offshore Global Logistics aims to prevent, detect, mitigate, and resolve potential bribery and corruption issues effectively. Violation of this policy is considered a significant breach of Offshore Global Logistics' Code of Conduct, and appropriate disciplinary actions will be taken, which may include the termination of employment. In certain circumstances, Offshore Global Logistics may also report the violation to enforcement authorities.

Conflicts of interest

Offshore Global Logistics requires its employees to proactively avoid any conflicts of interest and to disclose any situations where such conflicts may arise or be perceived. Ancillary activities or outside financial interests should not compromise an employee's integrity, objectivity, or pose a risk to Offshore Global Logistics. It is important for employees to disclose potential conflicts of interest and to seek prior written permission from Offshore Global Logistics, in accordance with the Conflict-of-Interest Guidelines and relevant policies and procedures, before engaging in any ancillary activities.
Furthermore, Offshore Global Logistics strictly prohibits employees from making or receiving facilitation payments.

Keeping Accurate Books and Records

Offshore Global Logistics emphasizes the need for employees to maintain accurate books and records of business transactions. This includes ensuring proper registration and documentation of various activities, such as expenses claimed by Offshore Global Logistics employees and exchanges of gifts and entertainment with third parties. By upholding these practices, Offshore Global Logistics promotes transparency, integrity, and compliance with financial and regulatory standards. Accurate record-keeping is essential for maintaining the trust of stakeholders and ensuring the company's adherence to applicable laws and regulations.
Offshore Global Logistics places a strong emphasis on the reporting and resolution of any issues, violations, or concerns related to its policies, particularly those pertaining to bribery and corruption. Employees, business partners, and third parties are encouraged to promptly report such matters to the relevant offices of the company.
Offshore Global Logistics fully supports individuals who refuse to participate in bribery or corruption and will not tolerate any form of retaliation against them or those who report concerns in good faith. If you believe that your report may have led or is leading to negative consequences, it is important to contact Offshore Global Logistics.
Any violation of this policy is considered a significant breach of Offshore Global Logistics' Code of Conduct and will be met with proportionate disciplinary actions, including the potential termination of employment. In certain circumstances, Offshore Global Logistics may also report the violation to relevant enforcement authorities.

Reporting and Resolving an Issue, Violation or Complaint

Offshore Global Logistics is committed to fostering a culture of integrity, transparency, and accountability, and encourages everyone to contribute to the prevention and detection of bribery and corruption through the reporting and resolution processes outlined in its policies.

RESPONSIBILITIES AND CONSEQUENCES

Employees, Officers, and Directors
Employees, officers, and directors of Offshore Global Logistics are required to take immediate action if they suspect any instances of bribery or corruption by reporting their suspicions to the Authorities and Offshore Global Logistics. Additionally, if they feel comfortable, they should inform their department manager or relevant representative about any suspected cases of bribery or corruption.
By promptly reporting suspicions and cooperating with relevant departments, Offshore Global Logistics aims to ensure the prevention and effective handling of bribery and corruption cases, maintaining a culture of integrity and ethical conduct.
Managers
Managers play a critical role in preventing, detecting, and reporting suspicions of bribery or corruption within Offshore Global Logistics. They are responsible for overseeing the development and maintenance of effective controls in this regard.
If managers have any suspicions of bribery or corruption, they are required to promptly report them to the Ethics Office. If necessary, they should escalate the matter to higher-level (line) management for appropriate action. By fulfilling these responsibilities, managers contribute to maintaining a culture of integrity and compliance with anti-bribery and anti-corruption standards at Offshore Global Logistics.

CONSEQUENCES

Any act performed by an employee that goes against the provisions stated in this policy will be deemed a significant violation of Offshore Global Logistics' Code of Conduct and this policy. In the event of a violation, appropriate disciplinary measures will be implemented, including the potential termination of the employee's employment, proportionate to the severity of the breach.
It is crucial to acknowledge that engaging in acts of bribery or corruption may result in external ramifications. Individuals involved, including the employees and business partners, may face legal consequences, including personal, civil, administrative, and criminal sanctions or liabilities. Furthermore, such actions can inflict damage upon the reputation of the individuals involved as well as that of Offshore Global Logistics.

REPORTING TO AUTHORITIES

In the event that a violation of law or external regulations is substantiated, Offshore Global Logistics may have an obligation to report or inform the appropriate enforcement authorities, such as the police or regulatory bodies. This action is taken to ensure compliance with applicable laws and regulations. Offshore Global Logistics further retains the right to initiate separate legal proceedings against the individuals or entities involved in the violation.

Questions

Offshore Global Logistics holds the expectation that all employees and business partners will consistently uphold the standards set forth in the Code of Conduct and this policy. It is crucial to exercise good judgment and, if necessary, seek guidance or support when faced with uncertainties. In case there are any inquiries regarding this policy or the relevant laws and regulations, individuals are advised to reach out to their department manager or the relevant offices. These avenues are in place to help and address any questions that may arise.

Exceptions

In the event that an exceptional circumstance arises which necessitates a departure from the minimum requirements outlined in this policy or other Offshore Global Logistics policies referenced herein, the responsible manager is required to seek written authorization from the policy owner through a waiver request. Local Offshore Global Logistics entities or departments may establish more stringent regulations based on local laws, regulations, or risk assessments. However, these rules must align with the requirements of this policy, and the policy owner must always be kept informed. Any deviation from this policy must receive written approval from the policy owner.
NOTE:
Please be aware that this policy is supplementary in nature, and any relevant local laws or regulations take precedence. This policy must not contradict any local laws or regulations, and in the event of a conflict, the law or regulation will prevail. If the terms of this policy are more stringent than the applicable legislation or offer additional protections, rights, or remedies, the terms of this policy will take precedence. In cases where there are differences in interpretation due to various translations, the English version of the policy will be considered authoritative.
You can report suspect violations of this Policy to Offshore Global Logistics at:
P.O. BOX 50610-00100 NAIROBI KENYA
PH: +254 (0) 111 052251
E-mail : info@offshorelogistics.co.ke
Offshore Global Logistics will keep the reported information confidential, provided it does not hinder any investigation that may follow thereafter.

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