
matters, is described in the chapter General Information,
Governance.
Business conduct policies and corporate culture
Our policies to promote an ethical business culture include:
Anti-Bribery and Anti-Corruption policy
The policy sets out our objectives to prevent bribery,
corruption, and any improper influence in business
dealings by defining clear behavioural expectations for
everyone representing FairWind. The policy sets out
detailed guidance on the handling of gifts, hospitality,
travel, and other benefits, defining allowable thresholds,
documentation requirements, and conditions under
which such benefits may be offered or accepted. It strictly
prohibits facilitation payments and emphasises stricter
controls for interactions with public officials, requiring
prior clearance from the Global Head of Legal, Risk, and
Compliance.
The policy additionally outlines comprehensive due
diligence procedures for associated persons (agents,
intermediaries, advisors), including identity verification,
capability assessment, market reputation checks,
contractual documentation, and monitoring obligations.
It also describes the identification of red flags that signal
potential integrity risks in business partners, such as
opaque ownership structures, politically exposed persons,
or links to corruption allegations.
The policy stresses the severe consequences of violating
anti-bribery or anti-corruption laws, including criminal
penalties, fines, termination of employment, and
liability for both individuals and the company. It also
establishes expectations for lobbying activities, prohibiting
political donations and requiring transparency, factual
communication, and compliance with registration
requirements. Throughout the policy, employees are
encouraged to seek guidance from supervisors or the
Global Head of Legal, Risk and Compliance whenever
uncertainties arise, ensuring consistent adherence to our
commitment to ethical and lawful business conduct.
Anti–Money Laundering (AML) and terrorist
financing policy
The policy outlines the legal and supervisory provisions
to prevent money laundering and terrorist financing, as
set out in the Money Laundering Act. It defines money
laundering and terrorist financing, describes the scope
of covered transactions, and assigns responsibilities
to the Global Head of Legal, Risk and Compliance for
oversight, internal reporting, staff training, and maintaining
safeguards. The policy sets out risk-based due diligence
requirements for representatives of FairWind when
conducting business with business partners, including
verifying documentation, identifying beneficial owners,
monitoring politically exposed persons, and prohibiting
cash acceptance and suspicious transactions. It also
details procedures for record keeping, periodic verification,
handling doubtful or unusual facts, mandatory reporting
of suspicious activity, and maintaining comprehensive
internal documentation to protect FairWind from legal,
financial, and reputational risks.
Sanctions policy
The policy defines our commitment to complying with
all applicable national and international sanctions and
export control regulations, ensuring that FairWind,
its representatives, agents, and business partners do
not engage in transactions with sanctioned countries,
individuals, entities, or sectors. It explains what sanctions
are, including restrictions on finance, trade, travel, and
dual-use items, and outlines obligations to screen all
parties against relevant sanctions lists such as the EU,
the US, the UN, the UK, and Canadian regimes. The
policy details compliance requirements, including due
diligence, escalation of any dealings involving sanctioned
jurisdictions, freezing transactions when risks are
identified, and mandatory reporting to the Global Head
of Legal, Risk and Compliance. It also highlights severe
penalties for non-compliance, assigns responsibility to the
Global Head of Legal, Risk and Compliance for oversight
and updates, and mandates ongoing staff awareness and
training to ensure adherence to evolving sanctions laws.
Details on other policies related to responsible business
conduct covering topics such as HSEQ, human rights,
discrimination, harassment, and workforce wellbeing are
provided in the respective topical standards of this report.
All policies are formally approved by our CEO, who is the
senior-most accountable authority and is supported by
various departments for their implementation. All our
policies are reviewed on a regular basis.
Our actions to promote corporate culture
Our ongoing actions covering our global operations to
promote our corporate culture include:
Communication and engagement
Our policies, procedures, and guidelines are centrally
hosted on the company intranet, ensuring that employees
can conveniently access and consult them whenever
needed.
The ExM conducts monthly review meetings with internal
departments and the other members of the leadership
team (C-level management team) to discuss business
performance, wherein business conduct matters are also
discussed. In addition, our dedicated and independent
function, the Global Head of Legal, Risk and Compliance
oversees and maintains the implementation of our
governance policies and procedures. The BoD is provided
with updates on business conduct matters by the ExM
and the Global Head of Legal, Risk, and Compliance on a
regular basis.
Through our Code of Conduct, we communicate clear
expectations for ethical and responsible business
behaviour to both employees and business partners.
The Code covers essential topics such as anti-corruption,
fair competition, health and safety, and human and
labour rights etc., guiding the standards we uphold
across our value chain. We maintain dedicated Code of
Conducts for employees and business partners to ensure
that expectations are tailored to their respective roles.
Employees are made aware of these requirements through
mandatory training on our governance documents.
Business partners such as non-employees, contractors,
suppliers, and any party entering a commercial relationship
with FairWind receive our Code of Conduct during
onboarding, and suppliers are additionally required to sign
the document as part of their contractual engagement.
Grievance redressal mechanism
As explained previously, we formalised our grievance
redressal mechanism by introducing the grievance policy
in 2025. More detail on grievance policy is available in
chapter S1 Own Workforce Work Conditions.
103Overview Management Review Sustainability Statement Consolidated Financial Statements Parent Company Financial Statements