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We value transparency and integrity in our business operations.


I ) Compliance with laws and rules of society
Compliance with the law is the basic principle underlying the Portunus’policies. All personnel are expected to respect and comply with laws and regulations. We want to be a good corporate citizen in each jurisdiction we operate in. We value transparency and business integrity and recognize that economic, environmental and social performance together form the basis for endorsing sustainability in our business operations. Portunus supports the protection of human rights, freedom of association, elimination of forced labor, abolition of child labor, elimination of discrimination in the field of labor and sustainable development.

II ) Business Conduct
Conflicts of interest; A conflict of interest exists when a person’s private interest is in conflict with the interests of the Company. Portunus’ personnel and Board members are expected to act in the company’s best interests. Consequently, each employee must prevent conflicts of interest situations by avoiding permanent financial interest with a competitor, client or supplier of the company outside of its professional activities. The establishment of business relationships must be based on objective criteria. Therefore, no gift, payment or other benefit should be received by an employee and an officer from a competitor, client or supplier of the company. 
Insider management; Any non-public information should be kept in strict confidence until publicly released by authorized persons. To use non-public information for personal financial benefit or to share them with others who might make an investment decision on the basis of this information is not only contrary to the company’s rules of conduct but also illegal. Insider trading and use of inside information is regulated by insider legislation and monitored by financial supervision authorities. Portunus expects all persons possessing and dealing with inside information to follow the rules mentioned in Portunus Insider Regulations.Insider management; Any non-public information should be kept in strict confidence until publicly released by authorized persons. To use non-public information for personal financial benefit or to share them with others who might make an investment decision on the basis of this information is not only contrary to the company’s rules of conduct but also illegal. Insider trading and use of inside information is regulated by insider legislation and monitored by financial supervision authorities. Portunus expects all persons possessing and dealing with inside information to follow the rules mentioned in Portunus Insider Regulations. 
Fair competition; Competition is necessary to achieve economic efficiency and constitutes as such a key element of free enterprise which Portunus believes in. We respect the rules governing free and fair competition and are committed to comply with applicable antitrust and other laws regulating competition. 
IPR and other assets; We respect intellectual property rights and engage in transferring technology and know-how in a manner that protects these rights. Furthermore we are responsible for the proper use of the company’s assets and resources and their protection. Each person should endeavor to protect the company’s assets against any deterioration, alteration, fraud, loss or theft. 

III ) Customer relations
The success of our customers is key to our own success. We provide a long-term commitment to our customers in order to be able to continuously meet and exceed their expectations. We strive to be the preferred supplier to current and new customers. Mutual trust is built through the integrity of words and actions. Therefore commitments provided to our customers shall be truthful and correct. This behaviour is what we expect also from our customers.

IV ) Supplier relations
We choose our suppliers with care and on the basis of objective factors such as quality, reliability, delivery and price, without preference for personal reasons. Suppliers are expected to conduct their business in compliance with international human rights and environmental laws and practices. Further, in their actions and operations suppliers and sub-contractors are expected to follow national laws of the countries they operate in. We promote the application of this Code of Conduct among our suppliers and endeavour to monitor their actions in this respect. 

V ) Work environment
IPR and other assets; 
To ensure the health and safety of its personnel is a company priority. All personnel are entitled to work in a safe and healthy environment and are expected to participate in such efforts by acting in a responsible manner. Each personnel must perform their duties consistently with the heath and safety rules applicable at the workplace and participate in such training programs that may be organized from time to time. We also endeavor to minimize health and safety risks related to the use of our products and services by developing innovative systems and methods. 
Non-discrimination; The diversity of personnel and cultures represented within the company is an important asset of Portunus. Hence we are committed to equal opportunity in employment policies, procedures and practices. Furthermore, we are committed to a non-discriminatory work environment that values diversity regardless of gender, race, religion, nationality, age or physical ability or any other aspect of diversity. We do not tolerate harassment of any kind. We respect the freedom of association of our personnel. Portunus does not act partially, does not speak out nor commit to political parties or religious groups.

VII ) Implementation
The purpose of this Code of Conduct is to set principles for Portunus’ way of working. We expect all our personnel to comply with the standards set in the Code. Portunus promotes the Code’s implementation through training and performance programs organized in relation to these topics. 
Members of personnel should contact their manager with any questions or seek advice from the Corporate Compliance Officer or other relevant corporate offi cers. There will be no adverse work- or career-related consequences as a result of a member of personnel reporting possible violations. Portunus will take disciplinary action, up to and including termination of employment, against members of personnel who violate the law and regulations, this Code of Conduct, or other Portunus policies.