Code of Conduct

Terminal Investment Limited S.à.r.l

TiL is committed to complying with all applicable laws and mandatory regulations, as well as also adhering to the highest ethical standards, throughout its worldwide business.

The TiL “Code of Conduct” establishes principles for its employees, to conduct TiL’s business in a legal and ethical manner at all times, including in their dealings with business partners including, suppliers, regulators, customers and shareholders. In addition, TiL requires the container terminals in which it has a participation to have their own code of conduct that provides for the same level of standards as TiL’s Code of Conduct, in compliance with their local laws and regulations.

The purpose of the TiL Code of Conduct is not to cover all circumstances or to anticipate every situation that may arise, rather it sets forth the basic principles and policies for the conduct of TiL’s business in an ethical manner. The Code of Conduct includes expectations and requirements related to communication, non-discrimination, harassment and other abusive conduct, data protection and privacy, forced and child labour, freedom of association, safety health and environment, anti-bribery and anti-corruption, conflicts of interest, money laundering, competitive practices, sanctions, whistleblower reporting, and other matters.

The TiL Code of Conduct is supplemented by TiL’s other compliance policies and procedures including its’ Anti-Bribery policy, Sanctions policy and Data Protection policy and TiL’s Human Resources guidelines.

TiL’s Board of Directors establishes, supervises and monitor’s TiL’s compliance and ethical conduct programme activities through the Board’s Audit and Risk Committee (ARC). The ARC has appointed a Chief Compliance Officer (a senior executive dedicated to compliance with appropriate experience and knowledge of TiL) who is responsible for implementing and overseeing the implementation of the Code of Conduct and associated compliance policies and procedures. The Chief Compliance Officer has direct access to the ARC and presents reports of compliance programme activities to, the ARC on a regular basis. The ARC tracks, among other things, the adoption status of compliance frameworks at each terminal in which TiL has an interest.

The Chief Compliance Officer is supported in her task by experienced Compliance and Legal resources within TiL headquarters and local compliance correspondent resources in the terminals.

TiL expects that employees raise concerns and complaints, or reports violations related to the Code of Conduct (or associated policies and procedures) topic areas or other issues that might negatively affect TiL or which would be in violation of any applicable law or regulation. TiL also prohibits retaliation against any employee who raises such issues. Instructions for raising concerns or filing reports are provided in the TiL Code of Conduct and in the relevant Code or whistleblowing procedures for each of the Terminals.

TiL’s Compliance team can be contacted on:

last updated on October 2022