Prosperity
Business conduct and corporate culture
Anti-corruption
Höegh Autoliners is dedicated to conducting business in accordance with the highest ethical standards outlined in our Code of Conduct and Anti-Corruption Policy. With a global presence and operations spanning the globe, we actively strive to foster a compliant culture and oppose corruption, as well as non-ethical business practices such as fraud, bribery, and facilitation payments.
Our stance is one of zero-tolerance for any form of corruption, applicable to all employees and external parties working on our behalf. We align our policies and processes with the Norwegian anti-corruption law, as well as other pertinent international anti-corruption legislation, including the UK Bribery Act, the US Foreign Corruption Practices Act, and local laws in the regions where we operate.
As a co-founding member, we take pride in our active membership in the Maritime Anti-Corruption Network (MACN), contributing to its collective action effort towards a maritime industry free of corruption, enabling fair trade for the benefit of society at large.
In 2023, Höegh Autoliners continued implementing awareness programs related to our “Say No” campaign. We emphasised the prompt recording and reporting of corrupt demands involving our vessels, providing seafarers with essential materials such as anti-corruption posters, and reporting hotlines. Specialised training and workshops were conducted for vessel masters and officers to equip them in their front-line battle against demands for bribes or facilitation payments.
Employee training is a crucial tool for fostering a compliant culture at Höegh Autoliners. We offer various training courses on our Code of Conduct, covering topics such as anti-corruption and other compliance areas. In 2023, we relaunched an in-person training and workshop called “Integrity Day”, underscoring the importance of ethics and integrity in the workplace and our business operations.
Höegh Autoliners encourages employees to “Speak Up” as vital part of our compliance program. To promote the reporting of misconduct, we have established an anonymous whistleblowing system to ensure that incidents or complaints are reported and addressed correctly and ethically. The same system is accessible to both employees and external stakeholders and is specifically intended for reporting concerns related to ethics and integrity.
| Year | 2023 | 2022 | 2021 |
|---|---|---|---|
| Calls at ports or net revenue in countries that have the 20 lowest rankings in Transparency International’s Corruption Perception Index | 4 | 8 | 21 |
| Number of incidents where bribes / facilitations payments have been requested | 16 | 25 | 5 |
| Total monetary value of significant fines and total number of non-monetary sanctions for non-compliance with laws and / or regulations | 0 | 0 | 0 |
| Whistleblowing complaints registered | 2* | 0 | 0 |
| Employees taking anti-corruption training | 301 | 339 | 86 |
| Total number of confirmed incidents in which employees were dismissed or disciplined for corruption | 0 | 0 | 0 |
| Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption | 1 | 0 | 0 |
| Public legal cases regarding corruption brought against the organisation or its employees during the reporting period and the outcomes of such cases | 0 | 0 | 0 |
| *Non-material reports received. |
Supplier Assessment and Compliance
At Höegh Autoliners, we take supplier assessments seriously. Before entering into a relationship with a new supplier, we employ a robust third-party sanction screening tool. This tool covers a range of criteria, including environmental and social sanctions. Our commitment to compliance extends to all entities we engage with in our business operations.
For the year 2023, 100% of new suppliers was covered by the assessment using this screening tool. Additionally, all suppliers are required to sign Höegh Autoliners’ Supplier Code of Conduct, as it serves as a minimum requirement, ensuring that our partners adhere to responsible business practices and comply with relevant global laws and regulations.
To follow up on our supplier code of conduct, and enhance our ESG risk assessment across our supply chain, we’ve continued to assess existing suppliers through our ongoing supplier assessment program. Please refer to our separate Transparency Act Report, published on our webpage, for further information on our supplier due diligence work.
Customer privacy
As we navigate through the continually evolving landscape of information and cybersecurity challenges, privacy and personal data protection stand as key component of our compliance program in Höegh Autoliners.
Thus, we continue to be committed to comply with laws related to privacy including the European General Data Protection Regulation (GDPR). As data privacy is important to us, we ensure that all information is secure even outside the European Economic Area (EEA).
In addition, we have prioritised the following measures in relation to data privacy:
- On data security, we have fully-working Anti-Ransomware system aimed at preventing data loss and/or data breaches resulting from ransomware attacks.
- We have strengthened our end point (users) protection via securing not just laptops but also mobile devices via implementing device management systems. This will effectively allow us to wipe data from the device once its lost or stolen.
- We have also instituted security awareness training and phishing simulations to train users regarding the dangers of cyberthreats.
- Constant vulnerability management is fully operational while patch management is fully integrated as part of the monthly boot weekend activity.
In the next two (2) years we aim to further strengthen and maintain our system integrity and resilience to ensure protection of the privacy data processed.
| 2023 | 2022 | 2021 | |
|---|---|---|---|
| Complaints received from outside parties and substantiated by the organisation | 0 | 0 | 0 |
| Complaints from regulatory bodies | 0 | 0 | 0 |
| Identified leaks, thefts, or losses of customer data | 0 | 1 | 1 |
| If the organisation has not identified any substantiated complaints, a brief statement of this fact is sufficient | N/A | N/A | N/A |
Responsible taxation
Our ambition is to act responsibly and with integrity in all tax matters, ensuring full compliance in every jurisdiction across the world. We will conduct and manage our tax affairs in accordance with our tax policy, which are closely aligned with our core values, Code of Conduct and business strategy, and are prepared in line with the B Team’s Responsible Tax Principles.
Given the increased public focus on the taxation of international shipping income, it is ever more relevant to continue to ensure transparency on the taxation of our business activities. Well-functioning tax systems, both locally and internationally, help finance education, healthcare, transport, infrastructure and other public services that support the sustainable development of societies, businesses and trade. We recognise the need for companies to support the local economies in which they do business.
Since 2017, we have publicly disclosed the tax we pay in key countries, in accordance with the OECD Country by Country Reporting (CBCR) principles to the Norwegian tax authorities, in accordance with our legal obligations.
Höegh Autoliners’ shipowning entities are subject to the Norwegian Tonnage Tax Scheme. The scheme is approved by the ESA (EFTA Surveillance Authority). According to the system, net operating revenue derived from the shipping industry will not be taxed and can be distributed without taxation. Instead of paying tax on income derived from the shipping operations, companies within this system have to pay a tonnage fee based on the size of the vessels. Financial income is taxed according to the ordinary Norwegian tax scheme, however only a portion of interest expenses and net currency gain/loss is tax deductible. Höegh Autoliners also has one shipowning company in Singapore, which is taxed under a tonnage tax scheme where shipping related earnings are tax free.
Höegh Autoliners supports effective tax reforms for avoidance of base erosion and profit shifting.
OECD BEPS Pillar two model rules are designed to ensure that large multinational enterprises pay a minimum effective tax rate of 15% on income arising in each jurisdiction where they operate. Höegh Autoliners will be covered by the future OECD Pillar two regime, with a partial exclusion for international shipping income.
Climate-related financial disclosures and governance
Predicting how climate change might affect our organisation in the future is not an easy task, but this serves as a firm example of how physical climate risks can have a real impact on our operations. As we continue our decarbonisation journey, contributing to the green energy transition, physical climate risks, along with transitional risks and opportunities, will play an important role in the coming years.
