James Fisher's Business Ethics policy aims to instil the highest standards of business behaviour across the group.

James Fisher is committed to ensuring the highest standards in its activities and is particularly concerned that appropriate and ethical policies and procedures are followed in all business dealings across the Group.

The Group strives for a culture of honesty, openness and accountability. The Group’s commitment to the highest level
of ethical conduct should be reflected in all our business activities including relationships with our stakeholders.

All employees and others must conduct themselves according to the language and the spirit of this Code and seek
to avoid any appearance of improper behaviour

James Fisher has zero tolerance for any form of bribery or corruption and is committed to complying with all applicable anti-bribery and corruption laws.

The Group has an established Anti-Bribery and Corruption Policy and has introduced a compliance programme which has the support of the Board and senior management within the Group. This includes communication of the statement and policy, training, risk assessment and ongoing monitoring. Employees assessed to be at risk are required to complete the training and to self-certify that they understand and agree to be bound by its provisions. On-going compliance is monitored by local compliance officers who are required to report to their local boards and to the Group Compliance Officer on at least a biannual basis. The compliance officers are responsible for ensuring that risk assessments, training and awareness are carried out where appropriate and are kept up-to-date.

In addition to ensuring that our people are compliant with the Group’s Anti-Bribery and Corruption Policy, we require that all third party agents and joint venture partners engaging with any Group entity comply with these policies in order to ensure compliance with applicable anti-bribery and corruption laws.

The policy is supplemented by due diligence on all third-party agent and joint venture relationships, enabled by a bespoke web-based platform available to all Group businesses. It provides a robust tool through which our businesses can risk assess agent and joint venture partners with whom they are considering doing business. It forms part of our internal control procedures and helps mitigate the business’ compliance risk. The platform was rolled out throughout the Group in 2020.

Code of Ethics