G1 Business conduct
Material impacts, risks and opportunities and their interaction with strategy and business model
| Location in the value chain | Time horizon | ||||||
| Upstream | Own operations | Downstream | Short-term | Medium-term | Long-term | ||
| Continued occurrence of bribery and facilitation payments in shipping | Potential negative impact | ⚫ | ⚫ | ⚫ | ⚫ | ||
| Severe breaches of the code of conduct can significantly harm corporate culture | Potential negative impact | ⚫ | ⚫ | ||||
| Potential adverse effects on whitleblowers | Potential negative impact | ⚫ | ⚫ | ⚫ | ⚫ | ||
| Political engagement may contribute to broader decarbonisation efforts within the maritime sector | Potential positive impact | ⚫ | ⚫ | ⚫ | ⚫ | ⚫ | |
| Consistently late invoice payments may negatively impact suppliers | Potential negative impact | ⚫ | ⚫ | ||||
Corporate culture and business conduct policies
Promoting the culture of compliance, ethics, and integrity
Höegh Autoliners promotes its business conduct policies and corporate culture by ensuring that policies are in place, conducting trainings, and clearly communicating the message from the top to all employees. The company strives to deliver the best possible service to its clients and stakeholders while ensuring compliance with ethical business principles, applicable laws, and environmental and community norms through its compliance programs, thereby fostering a culture of compliance, ethics, and integrity.
The Board of Directors is responsible for the governance of Höegh Autoliners. This means that the strategic direction and oversight emanate from the Board, ensuring the company’s activities are organized prudently in accordance with its purpose, strategic goals, core values, and compliance framework.
The Audit Committee acts as a preparatory working committee and supports the Board’s supervisory roles with respect to financial reporting and the effectiveness of the Company’s internal control and risk management systems including compliance.
The Executive Management team of Höegh Autoliners is responsible for the day-to-day operations of the company, implementing the Code of Conduct, and fostering a culture of integrity.
The Legal Department oversees the implementation of the company’s compliance program, including its Anti-Corruption Policy and Whistleblowing system. Leaders of local offices are appointed as Compliance Ambassadors, serving as local resources for compliance-related communication and coordinating activities between their respective offices and the Legal Department.
To further foster the culture of compliance, an Integrity Day is celebrated annually across all of Höegh Autoliners offices worldwide, facilitated by the Compliance Ambassadors. Throughout the year, employees can access a gamified training platform via their mobile phones, designed to make learning of key compliance policies engaging and interactive. This platform encourages employees to explore important Code of Conduct topics while enjoying fun, game-based activities. Periodically, a company-wide campaign, known as “Attensi Hour,” is launched to boost engagement and participation. These campaigns include incentives such as prizes and recognition for top-ranking employees on the leaderboard, reinforcing Höegh Autoliners’ commitment to fostering a dynamic and ethical workplace culture.
The Code of Conduct
Our Code of Conduct is the heart of how we do things at Höegh Autoliners and combines our values, behaviours, way of working and culture. The Code underpins our commitment to behave in a manner consistent with our values. In other words – it is our moral compass when we are challenged, are in difficult circumstances or face uncertainty. Our Code of Conduct states how all employees shall act to comply with our values, standards, and commitments. These include, among others, our policy against bribery and corruption, our whistleblowing system, and our relationship with our suppliers.
Responsibility for policy development and implementation is a joint responsibility between the Chief Legal Officer and the Chief HR and communication officer. The policy is applicable to all employees in the HA group, and is accessible to all employees via the internal document management system.
Whistleblowing policy
Speaking up is a crucial aspect of our compliance program. To encourage the reporting of misconduct, we have established an anonymous whistleblowing system hosted by a third-party online platform. The system is accessible to both employees and external stakeholders, specifically for reporting concerns related to ethics and integrity.
We work actively to enhance awareness of the importance of speaking up, and to communicate that the whistleblowing channel is available to all employees. A link to the whistleblowing platform is available on both Höegh Autoliners’ external webpage and intranet, and trainings are provided during onboarding through Attensi and recurrently highlighted during Integrity Day.
Incidents reported on our Whistleblowing system are evaluated and investigated by our Legal Department and Human Resources. Our Whistleblowing Policy ensures the availability of reporting anonymously and protects the whistleblowers from retaliation for raising concerns and violations. In line with that, our policy assures that there will not be any disciplinary action against notifiers.
Policy development and implementation is overseen by the Chief HR and Communication Officer, and it is accessible to all employees via our internal document management system.
Training and awareness
Höegh Autoliners offer various training courses on our Code of Conduct, covering topics such as anti-corruption and other compliance areas. To engage a broader part of the organization in compliance-related work, Höegh Autoliners has developed a gamified compliance training program through an app called Attensi, which employees can access through their phones. All trainings on the Code of Conduct and compliance topics are mandatory to all employees.
Additionally, an annual, in-person training and workshop called Integrity Day is conducted globally with the help of our Compliance Ambassadors. A focus is placed on the importance of ethics and integrity in the workplace and our business practices.
Management of relationships with suppliers including payment practices
Höegh Autoliners is dedicated to conducting operations in accordance with internationally recognized principles of business ethics, human rights, and corporate social responsibility. Although we have not implemented a specific policy to prevent systematically late payments to our suppliers, our code of conduct commits us to promoting responsible business practices. Our procurement and payment processes are detailed in respective procedural documents, ensuring fair behaviour from our business partners throughout the value chain.
The standard payment terms vary depending on the nature of the goods or services procured and the related spend categories. Höegh Autoliners diligently aligns payments with prevailing payment terms to meet regulatory requirements and supplier expectations as part of our responsible business practices. Metrics related to our payment practices are currently not available.
Höegh Autoliners Supplier Code of Conduct
Consistent with its commitment, Höegh Autoliners expects the same ethical standard from its suppliers and subcontractors. This expectation is communicated through our Supplier Code of Conduct, which we require suppliers to sign and adhere to, ensuring compliance with our sustainability requirements and reflecting our dedication to ethical practices. Policy development and implementation is overseen by the Chief Executive Officer, and it is accessible to all employees via our internal document management system.
We show our commitment to compliance by carefully evaluating all new business partners and entities we engage with.
In 2024, our supplier registration procedure has been updated and standardized across the organization. Before working with a new supplier, we utilize a comprehensive third-party sanction screening tool. This tool evaluates a wide array of criteria, including environmental and social sanctions, to ensure alignment with regulatory and ethical standards.
Moreover, the Supplier Code of Conduct is translated into selected languages to facilitate clear understanding of and adherence to the code by suppliers across different regions.
Prevention and detection of corruption and bribery
Zero-tolerance policy towards corruption
Höegh Autoliners is committed to the principles of the UN Convention Against Corruption (UNCAC) and maintains a zero-tolerance policy towards corruption, bribery, and facilitation payments, as outlined in our Group-wide Anti-corruption Manual. We ensure our policies and processes comply with Norwegian anti-corruption laws, as well as other relevant international legislation, including the UK Bribery Act, the US Foreign Corrupt Practices Act, and local laws in the regions where we operate.
Höegh Autoliners recognizes the importance of collaborative efforts across industries, governments, and civil society as essential to achieve the profound change required to combat corruption effectively. Höegh Autoliners is a co-founder member of the Maritime Anti-Corruption Network (MACN) and continues to participate in initiatives aimed at reducing corruption in maritime trade, including providing data of corrupt demands in ports, providing training to our crew and employees, and implementing a “Say No” campaign. Through MACN, we engage in sharing best practices, raising awareness, and supporting transparent business conduct across the sector.
Starting in 2023, we strengthened our anti-bribery and anti-facilitation measures onboard all vessels by prominently displaying anti-corruption posters in strategic locations where authorities are received during inspections. Alongside our long-standing “Say No!” campaign, we reinforced our commitment to crew safety through extensive capacity-building sessions and training programs designed to equip them with the skills to effectively resist corrupt demands.
Incidents of corrupt demands or corruption incidents are reported via Höegh Autoliners’ Improvement System (HIS). All crew and employees are encouraged to report facilitation payment demands and or gifts and exchanges. All information sent through HIS are managed and evaluated by the Legal Department based on our Anti-Corruption policy by individuals separate from the chain of management involved in the matter. Incidents are regularly communicated to both the management team and the Board of Directors.
Policy development and implementation is overseen by Chief Legal Officer, and it is accessible to all employees via our internal document management.
Anti-corruption training
Höegh Autoliners requires all employees, including all members of the executive management team, to complete mandatory code of conduct training, which includes anti-corruption training through our learning management system. Our seafarers are also provided with training on anti-corruption which includes concepts of corruption, our zero-tolerance policy, and procedure for prevention and reporting incidents.
Our anti-corruption training program covers legal requirements, policies and procedures, as well as practical scenarios to help employees recognize and address potential corruption or bribery situations.
In 2024 63% of our seafarers successfully completed anti-corruption training.
They are required to complete this anti-corruption training every second year. Our seafarers are considered functions-at-risk of corruption demands ranging from bribery to facilitation payments.
Accounting policies - Anti-corruption training
Anti-corruption training:
Höegh Autoliners provides a set of mandatory training courses to its employees. The trainings are related to our Code of Conduct, including anti-corruption. Completion data is recorded in Höegh Autoliners' internal learning platform.
Function-at-risk:
Höegh Autoliners’ seafarers are determined to be most at risk for bribery and corruption.
Confirmed incidents of corruption or bribery
In 2024, we received six (6) reports through HIS of demands for bribes or facilitation from our fleet. These demands varied, including requests for cigarettes, crew provisions, and even cash. Our crew consistently responded by politely rejecting these demands, citing our zero-tolerance policy towards corruption. There is a risk that seafarers are underreporting incidents. Therefore, we have throughout the year issued guidelines to vessel masters visiting ports where the MACN Local HelpDesk is available. Additionally, we updated the onboard Computer-Based Training on Anti-Corruption to include the latest strategies for effectively combating bribery and facilitation payment demands.
Höegh Autoliners did not receive any convictions or fines for violations of anti-corruption or anti-bribery law in 2024, nor has it been subject to any legal action relating to corruption and bribery.
Accounting policies - Incidents of corruption or bribery
Demands for bribes or facilitation payments corresponds to the actual number demands for bribes and/or facilitation payments reported through HIS.
Number of convictions for violation of anti-corruption and anti-bribery laws
refers to the number of convictions for violation of anti-corruption and anti-bribery laws, considering all convictions resulting from legal proceedings against any entity within the Höegh Autoliners Group in the reporting year.
Amount of fines for violation of anti-corruption and anti-bribery laws relates to the amount of fines for violation of anti-corruption and anti-bribery laws, considering all convictions resulting from legal proceedings against any entity within the Höegh Autoliners Group in the reporting year.
Number of legal proceedings outstanding for late payments refers to the number of legal proceedings outstanding for late payments includes all legal proceedings against any entity within the Höegh Autoliners Group in the reporting year for outstanding payments at the end of the reporting year.
Political influence and lobbying activities
During the 2024 financial year, Höegh Autoliners has advocated for a regulatory framework that ensures a global level-playing field and supports first mover efforts in their efforts to decarbonise shipping. By pushing for this, the company seeks to ensure that shipping can decarbonise in line with the IMO target of net-zero by 2050.
Our efforts include engaging with international regulatory bodies, participating in industry coalitions, and collaborating with governments to shape policies that support sustainable shipping practices. These initiatives are designed to incentivize the long-term adoption of green technologies and reduce the overall carbon footprint of the shipping industry. Through these efforts, the company aims to drive systemic change that benefits both the climate and the environment as well as the industry’s long-term viability. The Chief Operating Officer is responsible for the oversight of these activities.
Currently, there is no specific policy in place regarding political engagement. However, our code of conduct addresses political contributions, emphasizing that special caution must be exercised when evaluating such contributions. Such contributions must comply with public disclosure requirements and be reported according to internal processes.
The company is registered in the EU Transparency Register (registration number 971383591538-27) and the German Transparency Register (registration number R007089).
No financial or in-kind political contributions have been made during the reporting year, and no members of the company’s management team or Board of Directors held comparable positions in any public administration in the two years preceding their appointment in the current reporting period.
Accounting policies - Political engagement
Financial contributions refers to political contributions in which financial support is provided directly to political parties, their elected representatives or persons seeking political office. ‘Financial contributions’ can include donations, loans, sponsorships, advance payments for services, or other similar practices.
In-kind political contributions refers to political contributions in which financial or in-kind support were provided directly to political parties, their elected representatives or persons seeking political office. ‘In-kind contributions’ can include advertising use of facilities, design and printing, donation of equipment, provision of board membership, employment or consultancy work for elected politicians or candidates for officer.
