WALC CODE OF CONDUCT

Business Ethics, Safety & Responsible Operations

Version 1.0 | 16 April 2026

1. Our Commitment

At WALC, we believe that professional integrity, safety and responsible business conduct form the foundation of successful operations and long-term business relationships.

As a Finland-based company providing marine and cargo surveying, port logistics, project logistics consulting and industrial site logistics management services, we are committed to maintaining high ethical and professional standards in all our activities.

This Code of Conduct establishes the principles that guide our operations, business relationships and everyday decision-making.

The Code applies to WALC's management, employees and personnel acting on behalf of the company. We also expect our subcontractors and business partners to follow equivalent principles when working with us.

2. Compliance with Laws & Regulations

WALC conducts its business in accordance with applicable laws, regulations and contractual obligations in the countries where we operate.

We respect relevant maritime, transportation, occupational health and safety, environmental and other regulatory requirements applicable to our assignments.

We recognize the importance of international trade restrictions, sanctions and export control regulations and do not knowingly participate in activities that violate applicable requirements.

We are committed to conducting our operations lawfully, responsibly and transparently.

3. Business Ethics & Anti-Corruption

WALC maintains a zero-tolerance approach to bribery, corruption, fraud and other forms of dishonest business conduct.

We do not offer, promise, request or accept improper payments, benefits or advantages intended to influence business decisions.

Gifts, hospitality and business entertainment must remain reasonable, lawful and transparent and must never improperly influence professional judgment or commercial decisions.

Facilitation payments are prohibited.

We conduct business fairly, respect applicable competition laws and seek to establish long-term partnerships based on trust, competence and integrity.

4. Independence & Professional Integrity

Independence, objectivity and professional judgment are particularly important in our marine surveying, cargo inspection and logistics consulting activities.

Our inspections, assessments, observations and reports are based on actual findings, available evidence and professional expertise.

We do not knowingly alter, conceal or misrepresent information to satisfy commercial interests or external pressure.

Potential conflicts of interest must be identified, disclosed and appropriately managed to maintain professional integrity and trust.

We are committed to providing accurate, objective and reliable information that supports our clients' decision-making.

5. Health, Safety & Wellbeing

Safety is a fundamental priority in all WALC operations.

Our assignments frequently take place in ports, onboard vessels, along transportation routes and at industrial construction sites, where operational risks must be carefully identified and managed.

We are committed to:

• Complying with applicable occupational health and safety requirements

• Identifying hazards and assessing risks before starting work

• Using appropriate personal protective equipment

• Following site-specific safety instructions and operational procedures

• Maintaining the necessary competence and training for assigned tasks

• Reporting incidents, near misses and unsafe conditions

• Intervening when unsafe practices are identified

• Stopping or refusing work when conditions present an unacceptable safety risk

We encourage open communication regarding safety concerns and continuously seek to improve our working practices.

No operational deadline or commercial objective justifies knowingly compromising safety.

6. Environmental Responsibility

WALC recognizes the environmental impacts associated with maritime transportation, road logistics, industrial activities and construction projects.

We aim to minimize unnecessary environmental impacts through practical planning, efficient coordination and responsible working methods.

Our approach includes:

• Optimizing logistics and transportation arrangements

• Reducing unnecessary cargo handling and vehicle movements

• Supporting efficient use of equipment, resources and storage areas

• Utilizing digital planning and reporting methods where appropriate

• Preventing pollution and unnecessary waste

• Reporting environmental incidents and identified risks

• Complying with applicable environmental regulations

We seek to support practical and environmentally responsible solutions while considering the operational requirements of each project.

7. Human Rights & Fair Working Conditions

WALC respects internationally recognized human rights and supports fair, safe and respectful working conditions.

We do not tolerate discrimination, harassment, bullying, forced labour, human trafficking or child labour.

We are committed to treating all individuals fairly, regardless of nationality, gender, age, religion, disability, ethnic background or other characteristics protected by applicable law.

We respect workers' rights, including lawful working conditions, appropriate compensation, working hours, rest periods and freedom of association.

We expect our subcontractors and business partners to uphold equivalent fundamental principles.

8. Quality, Accuracy & Transparent Reporting

Reliable reporting, professional competence and service quality are essential parts of WALC's operations.

Our services are based on practical operational experience, appropriate technical knowledge, clear communication and careful documentation.

We aim to:

• Meet agreed client and project requirements

• Maintain accurate inspection and operational records

• Provide factual, objective and transparent reports

• Communicate significant observations and identified risks

• Document operational deviations and relevant corrective actions

• Address errors responsibly and without unnecessary delay

• Continuously improve our services and working methods

We utilize modern digital reporting applications, photographic documentation and planning tools where appropriate to support efficient communication and reliable project documentation.

9. Confidentiality, Data Protection & Information Security

WALC respects the confidentiality of information entrusted to us by our clients, business partners and other stakeholders.

Commercial, technical, operational and personal information must be handled responsibly and used only for legitimate business purposes.

We comply with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR) where relevant.

Project documentation, inspection reports, cargo information, photographs, drone imagery and other confidential materials are shared only with authorized parties.

We take reasonable measures to protect information against unauthorized access, misuse, disclosure or loss.

10. Responsible Business Partners & Subcontractors

WALC cooperates with subcontractors, transport providers, technical specialists and other business partners according to project requirements.

We expect our partners to conduct their business lawfully, ethically and safely, while respecting fundamental human rights and environmental responsibilities.

When selecting business partners, we consider relevant competence, reliability, operational suitability and responsible business practices, taking into account the nature and requirements of each assignment.

Where concerns regarding business conduct, safety or compliance arise, we seek appropriate clarification and corrective action and may reconsider cooperation when necessary.

11. Conflicts of Interest

Business decisions must be made professionally and without improper personal influence.

WALC personnel must disclose actual or potential conflicts of interest that could compromise their professional judgment, independence or responsibilities.

Conflicts of interest shall be assessed and appropriately managed to maintain transparency, objectivity and trust.

12. Reporting Concerns & Continuous Improvement

WALC encourages employees, subcontractors, clients and business partners to raise concerns regarding unethical conduct, unsafe practices, misconduct or suspected violations of this Code of Conduct.

Concerns may be reported directly to WALC management through the company's published contact channels.

Concerns reported to WALC management are treated seriously and handled with appropriate discretion. Where necessary, we take reasonable steps to assess the situation and address identified issues.

Retaliation against individuals raising concerns in good faith is not tolerated.

We are committed to continuously improving our operations, professional practices and responsible business conduct.

13. Implementation & Management Responsibility

WALC management is responsible for communicating, implementing and maintaining this Code of Conduct.

All personnel acting on behalf of WALC are expected to understand and follow the principles outlined in this document.

The Code is reviewed periodically and updated when necessary to reflect changes in legislation, business activities and operational requirements.

Our commitment is to maintain a working culture based on safety, professional competence, ethical conduct, transparency and mutual respect.

We act with integrity, work safely, respect people and the environment, and deliver reliable professional services in every assignment.

WALC Oy
Finland
www.walc.fi

Document: Code of Conduct
Version: 1.0
Document date: 16 April 2026
Approved by: WALC Management
Approval date: 16 April 2026