Code of Conduct
FOR A CONNECTED WORLD
The Traderoad Code of Conduct embodies the fundamental principles that guide our business conduct, setting global standards for all employees and select third parties who engage with or represent Traderoad.
To all members of
the Traderoad community
The Traderoad Code of Conduct embodies the fundamental principles that guide our business conduct, setting global standards for all employees and select third parties who engage with or represent Traderoad. It is a dynamic document that endeavors to incorporate societal developments into our corporate strategy and culture. This Code signifies the unwavering commitment of our management board and each individual within our organization to embrace, uphold, and promote these principles.
At Traderoad, our operations are built upon a bedrock of honesty, fairness, and integrity. Operating within the oil and gas sector, we acknowledge our responsibility for the consequences of our decisions on society, the economy, and the environment. We are dedicated to managing risks prudently and adopting a comprehensive perspective on their impacts on both people and the environment. We firmly believe that this approach enhances our resilience during times of crisis and ensures the sustainable progression of our company.
Our Values
At Traderoad, we consistently operate with unwavering honesty and integrity, fostering enduring, trust-based relationships with our global stakeholders. This commitment not only creates a competitive edge for our company but also establishes an inclusive workplace that welcomes all individuals.
The purpose of our Code is to serve as a compass, offering guidance and insight for ethical conduct aligned with Traderoad's strategy and values. It also directs us on when and where to seek answers and assistance. We hold all Traderoad team members to the same high ethical standards.
Our Commitments
At Traderoad, our collective success hinges on our unwavering commitment to doing what is right. Regardless of our job titles, we all assume leadership roles in upholding the principles of ethics and integrity. As Traderoad individuals, we pledge to:
Adhere to the guidelines outlined in our Code.
Cultivate a positive and inclusive work environment while fostering a robust ethical culture.
Contribute to the company's environmental, social, and governance commitments.
Abide by all relevant regulations and certifications.
Promptly report any suspected violations of the law or our Code.
Refrain from engaging in workplace retaliation.
Report any instances of known or suspected retaliation.
Actively cooperate with investigations.
Together, we are the custodians of Traderoad's ethical foundation and the architects of its sustainable success.
Traderoad Relies on Each of Us
Traderoad people encompass all employees, officers and directors, regardless of their role within the organization. Additionally, this term may extend to non-employee third-parties, which includes but is not limited to:
Sales agents
Representatives
Consultants
Contract workers
Joint venture partners
Distributors
Converters
Suppliers
Outside counsel
In essence, Traderoad people include anyone whose actions and conduct have a bearing on the operations and reputation of Traderoad.
Exemplary Leadership with Unwavering Integrity
In our pursuit of an ethical culture at Traderoad, each one of us plays a vital part. However, if you hold a managerial, trading, or supervisory role, additional responsibilities are entrusted to you. As a leader within Traderoad, your role entails:
Establishing the ethical standard and serving as an exemplar of ethical conduct for all those you influence.
Cultivating an environment that fosters open dialogue, encourages questions, and welcomes the expression of concerns.
Contributing your share to foster a workplace that is equitable and characterized by mutual respect.
Attentively listening to and appropriately reporting any concerns, ensuring they are escalated when necessary, in accordance with the stipulated escalation procedures.
Establishing Resilient Internal Operations
To ensure the enduring sustainability and growth of our company, we diligently uphold and continually enhance our business model and governance structure. It is the expectation of Traderoad that every member of our organization adheres to all relevant laws, regulations, as well as internal policies, standards, and procedures, while dedicating themselves to their work. Furthermore, we encourage all employees to voice their concerns and actively contribute to the Company's prosperity.
Do not hesitate to embrace the role of a positive catalyst for change, which is essential for our collective success.
People stand at the core of our achievements and future prospects. Consequently, we are committed to upholding all applicable labor laws, closely monitoring our well-being, and nurturing our potential. Recognizing that office work carries certain health implications, we provide a range of services aimed at monitoring and promoting the health of all employees. These services encompass regular eye examinations and posture assessments, as well as the availability of products designed to mitigate these health-related concerns. Should you have any questions or wish to learn more about these products and services, please feel free to approach your supervisor or designated HR manager for further information.
Delivering Excellence in Product Quality
In our operational framework, we place significant reliance on a network of trusted suppliers, who are regarded as integral members of the Traderoad community. Therefore, as a supplier, you are expected to adhere diligently to all laws, regulations, as well as internal policies, standards, and procedures governing the quality and safety of our products. Should you come across any concerns related to quality or safety, it is imperative that you promptly report them. Furthermore, in line with global and industry-specific sustainability trends, we anticipate our suppliers to commit to risk assessment, management, and transparent reporting.
If you hold a managerial, trading, or supervisory role, you bear additional responsibilities in this realm. You should be prepared to address any safety or quality concerns that are brought to your attention, and you must ensure that your direct reports receive adequate training on all relevant laws, regulations, and internal policies, standards, and procedures. In doing so, you actively contribute to fostering a culture characterized by ethics and compliance, wherein all Traderoad individuals can align themselves with our company's core values.
Upholding High Ethical Standards
People: In addition to our unwavering commitment to comply with all relevant labor and human resource laws, we pledge and anticipate our suppliers and partners to share in our commitment to safeguarding the human rights of workers. This commitment entails treating all workers, including temporary, migrant, student, contract, direct employees, and any other type of worker, with the utmost dignity and respect, as defined by the international community. Furthermore, we encourage and have the expectation that our suppliers and partners foster a culture centered on well-being, transparency, and a "Safety First" approach. This culture will not only benefit them but also extend its positive impact to local communities.
Environment: Recognizing the vital role of our environment in our individual and societal well-being, we emphasize the importance of adhering to local environmental laws. Additionally, we commit to and anticipate our partners and suppliers to incorporate environmental impacts and risks into their strategic planning and everyday decision-making processes. This ensures that we collectively uphold a deep sense of responsibility toward our environment and its preservation.
Dedication to Enduring Partnerships
Our success thrives through collaboration with our partners. We foster robust relationships within and beyond Traderoad, deliver exceptional customer service, and embrace a solutions-oriented mindset.
Our objective is to forge trust-filled, long-lasting partnerships that span across our entire value chain, encompassing both upstream and downstream connections. We are steadfastly dedicated to participating in a sustainable, equitable business environment. Therefore, it is incumbent upon all Traderoad individuals to conduct themselves with unwavering honesty, integrity, and fairness. This commitment serves as the cornerstone of our business strategy and daily operations.
Unwavering Adherence to Laws and Regulations
Traderoad's fundamental business strategy revolves around unwavering compliance with all laws and regulations, forming the bedrock of our commitment to the sustainability and ongoing development of our operations. This encompasses, but is not limited to, the following areas:
Global Trade Compliance: In every facet of our business activities, it is imperative that we possess an intimate knowledge of and adhere to the international trade compliance laws that pertain to our operations. This includes compliance with laws governing imports and customs activities, exports and export controls, trade embargoes and economic sanctions, anti-boycott regulations, and more.
Forced Labor and Human Trafficking: Traderoad is dedicated to the full compliance with all applicable laws and employment regulations and unequivocally refrains from engaging in or endorsing forced labor. We extend these same expectations to all vendors engaging in business with us. Our stance is clear: we do not tolerate human trafficking or any illicit business practices. We are committed to implementing robust systems and controls aimed at preventing human trafficking from occurring anywhere within our business operations or supply chains.
Rigorous Adherence to Legal and Regulatory Compliance
Workplace Safety: As Traderoad People, our diverse roles encompass a range of environments, from offices to industrial and transportation facilities. Irrespective of our workplace setting, we are bound by the safety standards that are pertinent to our tasks. This means we must diligently follow all applicable laws, regulations, and company policies and procedures that govern our work. This includes guidelines for handling hazardous and flammable materials, as well as protocols for working with tools and machinery.
Bribery: Our core values of fairness and integrity serve as the linchpin for our sustainable global business expansion. We adamantly refrain from securing or retaining business through unethical practices, such as bribes, kickbacks, or any form of corrupt payments—regardless of any local business customs. We are fully compliant with international and local anti-corruption laws that are applicable to us. It is imperative that we neither offer, promise, give, nor accept bribes, with particular vigilance when engaging with government officials. Offering, promising, giving, or accepting anything of value that could potentially corruptly influence a Business Partner or government official is strictly illegal.
Unwavering Commitment to Legal Compliance
Fair Competition: Our success is driven by our commitment to providing high-quality products and dependable services while engaging in vigorous competition, without resorting to market manipulation. In the marketplace, we steadfastly adhere to both the letter and the spirit of antitrust and competition laws that are applicable to our operations. These laws are designed to foster healthy competition, ensuring that customers have access to products at competitive prices.
Upcoming Regulations: At Traderoad, we have a series of internal policies and initiatives on the horizon in the short to medium term. These measures are aimed at ensuring our compliance with national and international standards, such as the Corporate Sustainability Reporting Directive. We are fully dedicated to taking proactive actions to foster and facilitate compliance throughout our entire value chain.
Data Protection
We place our trust in our team members to responsibly manage data and information.
Personal Information: Integral to our commitment to respect is the responsible handling of personal information, which may include data about fellow Traderoad individuals, customers, patients, or Business Partners. We must always seek permission before collecting, using, or disclosing such information. Those of us who have access to personal information bear the responsibility of safeguarding it, utilizing it in accordance with the law and ethical standards, and refraining from sharing it with unauthorized individuals. Data privacy laws can differ from one country to another, so if there are any inquiries about the appropriate procedures for handling such information, it is advisable to consult our Traderoad legal advisors.
Personal Information - Information that, either on its own or in conjunction with other data, can be used to identify an individual. This may encompass contact details, health records, national identification numbers, marital status, or similar information.
Data Protection and Confidential Information
To nurture our company's competitive edge, we heavily rely on the safeguarding of our proprietary information, which stands as one of our most invaluable assets. At Traderoad, information is categorized according to the guidelines outlined in the Information Classification and Handling Standard. It is imperative that we are well-versed in the classification of Traderoad information that we generate or have access to. All information, except for publicly available data, must be treated with the utmost confidentiality. Under no circumstances should confidential information be disclosed outside of the Company without explicit approval and the implementation of appropriate confidential disclosure agreements. Even within Traderoad, the sharing of confidential information should be restricted to individuals with a genuine "need to know."
Confidential information encompasses a broad spectrum, including product details, financial data, organizational insights, and customer and business partner information. This category encompasses any information that is considered secret or restricted and pertains to our Company, our customers, our Business Partners, or our competitors.
Data Protection and Trade Secrets
Trade Secret: Trade secrets constitute a form of intellectual property, possessing substantial value that demands rigorous protection through maintaining strict confidentiality. Trade secrets typically exhibit the following characteristics: 1) they hold economic significance, 2) they are not generally known beyond the confines of Traderoad, and 3) Traderoad makes reasonable and appropriate efforts, given the circumstances, to safeguard their confidentiality.
Social Media: Numerous Traderoad team members utilize social media platforms for personal connections, staying in touch with family and friends, or staying informed about global events. It is incumbent upon all of us to exercise prudence when discussing our Company or its business on social media channels. Your conduct on social media not only mirrors your own image but can also reflect upon the Company as a whole. Only a select few individuals are authorized to represent the Company and speak on its behalf. It is imperative not to overstate your authority to speak for Traderoad.
The Company has designated spokespersons who are authorized to convey Traderoad's official stance on specific matters. In the event you are contacted by the media, your best course of action is to redirect them to a responsible individual within Traderoad's Corporate Communications department.
Data Protection and Insider Trading
Insider Trading: In the course of our work for Traderoad, we may come into possession of inside information*. Importantly, this inside information need not pertain solely to Traderoad; it might also encompass material non-public information concerning other entities, such as Traderoad's customers or suppliers. Regardless of the company to which this information relates, the expectation remains consistent: we must never engage in the trading of that company's stock or other securities while we possess material non-public information. Even after this information becomes publicly available, we are obliged to wait for a period of two full trading days before buying or selling stock or other securities related to that company. Insider trading is not merely unethical—it is also illegal. Those who trade on material non-public information may face severe legal consequences, including potential imprisonment.
Insider Information - Also referred to as material non-public information, this refers to data that is not accessible to the general public and has the potential to influence someone's decision to buy, sell, or hold stock.
Mutual Trust and Responsible Asset Management
We place our trust in each member of our team to exercise responsible stewardship over the assets of the Company.
Traderoad's assets stand as integral pillars of our company's triumph. Irrespective of the assets we employ or have access to in the course of our duties, our obligations remain consistent:
To protect and safeguard Traderoad's assets.
To restrict personal utilization of Traderoad assets.
We should exercise judiciousness when it comes to the prudent use of Traderoad's electronic resources. In order to uphold the security of Traderoad's information and maintain our Company's competitive edge, it is imperative that we exercise caution when utilizing electronic resources in public settings.
Mutual Trust and Transparency
Conflicts of Interest: At Traderoad, it is incumbent upon each of us to prioritize decisions that serve the best interests of the company. Transparency is key when it comes to personal interests and activities that might create potential conflicts of interest. When you disclose a potential conflict of interest to your manager, trader, or supervisor, you not only protect yourself but also safeguard Traderoad's integrity.
Conflicts of Interest manifest in situations where your personal interests or relationships have the potential to influence—or could reasonably be perceived to influence—the decisions you make on behalf of Traderoad. Such conflicts have the potential to tarnish Traderoad's reputation and impede our business success. If you suspect that you are confronted with an actual or potential conflict of interest, it is imperative to disclose it promptly. Timely disclosure of conflicts of interest aids in upholding our culture of integrity.
Building Trust and Managing Conflicts of Interest
Common Scenarios Leading to Conflicts of Interest:
Engaging in Traderoad business with a former Traderoad employee.
Conducting Traderoad business involving a family member, significant other, or close friend. We must diligently avoid situations where personal relationships intersect with business matters.
Pursuing external employment. We must refrain from accepting outside employment that could detrimentally impact or interfere with our responsibilities at Traderoad, such as working for a competitor or establishing a business that competes or engages with Traderoad.
Investing in other companies. To sidestep conflicts of interest, it is advisable to steer clear of significant stakes in companies that serve as competitors, suppliers, or customers of Traderoad. However, having minor investments in publicly traded companies is typically permissible.
Serving on a board of directors. If you are approached to serve on the board of directors of a charitable, educational, non-profit organization, or trade association, it is crucial to consult with your manager or supervisor before accepting the role to ensure that it does not give rise to a conflict of interest.
Embrace Change and Drive Progress
At Traderoad, we are steadfast in our commitment to cultivate a culture of transparency, both on an individual and company-wide level, to foster a thriving, inclusive, and sustainable environment. We urge all our team members to wholeheartedly embrace this objective and actively participate in advancing our ESG (Environmental, Social, and Governance) agenda.
Here at Traderoad, we acknowledge and embrace the ongoing changes around us, demonstrating our dedication to being active participants in this transformation. We stand ready to vigilantly monitor, adhere to, and adapt to contemporary laws and regulations, ensuring that we remain aligned with the times and maintain the sustainability of our operations, both in the present and future.
At this juncture, we embark on a journey to lay the groundwork for compliance and reporting in accordance with Sustainability Development Goals (SDGs), the Corporate Sustainability Reporting Directive (CSRD), and the ESG framework, with a short to medium-term vision, as well as the Corporate Sustainability Due Diligence Directive (CSDDD) in the long term. Consequently, all Traderoad People, including our upstream and downstream partners, will be informed and encouraged to uphold and contribute to these commitments, both professionally and personally. Together, we strive to be a force for positive change and progress.
Fostering a Culture of Open Communication
We wholeheartedly embrace transparency, candid conversations, and active participation. By posing questions and bringing potential issues to light, you play an integral role in Traderoad's success. Moreover, if you ever find yourself in a situation where the right course of action isn't apparent, remember that you are not on your own. Traderoad is here to provide guidance and support whenever you need it.
Should you encounter or become aware of any misconduct, it is your responsibility to report the matter, unless local law explicitly prohibits you from doing so. You have two primary avenues for reporting:
- Your manager, trader, or supervisor.
- Your designated Human Resources Manager.
If you are a partner or any other stakeholder, we strongly encourage you to report any misconduct directly to the Traderoad office. We believe that a "Speak Up" culture is essential for the well-being of our organization and the communities we serve.
Guidelines for Acceptable Business Courtesies
Business partners encompass those individuals or entities engaged in business arrangements, contracts, or transactions with Traderoad, whether they provide or purchase products or services. This includes distributors, suppliers, customers, healthcare professionals (HCPs), sales agents, representatives, consultants, contract workers, joint venture partners, and outside counsel. Acceptable Gift Criteria:
Value: Gifts should possess modest value, avoiding extravagance.
Frequency: The exchange of business courtesies should be infrequent.
Timing: Gifts should not coincide with business deals or contract extensions.
Cash or Equivalents: Cash or cash equivalents are not deemed acceptable.
Examples of Acceptable Gifts: Occasional business lunches, company-branded merchandise, small tokens like a drink or chocolates, but not high-value items such as an iPad.
It is imperative to adhere to local business courtesy regulations and laws, particularly when engaging with government officials and healthcare professionals. Compliance with these guidelines ensures ethical and lawful conduct in all business interactions.
Promoting Inclusive Workplace Behavior
At Traderoad, we celebrate the diverse backgrounds and experiences each of us brings to the workplace, recognizing this diversity as a valuable asset. To honor and uphold our commitment to diversity, it is incumbent upon all of us to demonstrate respect and foster an inclusive atmosphere in our work environment. Consequently, we categorically reject any form of unlawful discrimination rooted in any protected characteristics. These protected characteristics may vary by region, but typically include:
Age
Race or color
Gender
Religion
Disability
Other characteristics
At Traderoad, we uphold the principle of treating every individual equally, and we vehemently oppose any form of harassment, discrimination, or exclusion in relation to work-related activities. For example, we do not discriminate on the basis of factors such as marital or family status. Discrimination, harassment, and any form of disrespectful behavior are unwelcome and strictly prohibited at Traderoad. We are united in fostering an environment where every individual feels valued and respected.
Promoting Positive Workplace Behavior
Our behaviors and the way we interact with one another are pivotal in shaping a productive and inclusive workplace. It is imperative that we consistently treat each other with fairness and respect, refraining from any form of harassment, bullying, or unprofessional conduct. This encompasses threats and acts of violence, as well as intimidation, the use of abusive language, any form of threatening behavior, and attempts to instill fear in others.
If you believe you have personally experienced or witnessed discrimination, harassment, or bullying at Traderoad, we strongly encourage you to speak up. You can voice your concerns with your manager, supervisor, or any other resource listed in our Code of Conduct. Traderoad unequivocally condemns and prohibits any form of retaliation against individuals who ask questions, report incidents, or participate in investigations.
Harassment is characterized by unwelcome conduct based on a protected characteristic, which results in creating an intimidating, hostile, or offensive work environment for an individual. Such behavior may also negatively impact work performance or impede job opportunities. We are steadfast in our commitment to cultivating a workplace where all individuals are treated with dignity and respect.
Addressing Environmental and Social Concerns
Our commitment extends to the conservation of natural resources, the mitigation of our environmental and social footprint to the greatest extent feasible, and conducting business in a manner that prioritizes the health and safety of Traderoad People, the communities in which we operate, and those who utilize our products.
Our objectives are straightforward: we aim to adhere to the latest social and environmental regulations while simultaneously safeguarding the sustainability of our operations, securing the long-term prosperity of our Company and its stakeholders. We are unwavering in our dedication to these principles, striving for responsible and ethical business practices that benefit not only our organization but also the broader society and environment in which we operate.
Be Accountable, Show Respect, and Exude Passion for Our Business
These three principles—accountability, respect, and passion—are the cornerstones of our ethical foundation. By embodying them, we can collectively prosper while upholding the highest standards of integrity and responsibility.
Together, let's thrive ethically and make a positive impact on our business, our people, and the world around us.
