Our Code of Conduct contains a number of important guidelines of behavior and is intended to
guide all of us in our daily business but also in our strategic planning and our decision making
processes. Where appropriate, our Code of Conduct will be modified by local laws and standards.
Our Code of Conduct is not intended to be a static instrument. It will be continuously developed
and adapted to the ever changing legal and economic environments that affect the ways that we
conduct. With this in mind we have revised our Code of Conduct, the foundation of which is our
“Vision ”. The “Vision ” represent the fundamental principles to which YORK BUNKER B.V.
commits. Our vision is becoming a trusted Salesforce partner distinguished by a highly effective
team that delivers excellence.
YORK BUNKER B.V.’s image and reputation, as a company that operates in an ethically and
legally appropriate manner, is inseparable from the conduct of each of us as we perform our work,
everyday. We, the employees of YORK BUNKER B.V., are expected to respect laws and
regulations, avoid conflicts of interest, protect the Company’s assets, and show consideration and
appreciation for the local customs, traditions and social mores of the various countries and cultures
in which YORK BUNKER B.V. conducts business. In fulfilling our responsibilities within YORK
BUNKER B.V., we do not take ethical shortcuts. Improper conduct will never be in YORK
BUNKER B.V.’s interest.
Should you have any questions, or if you are uncomfortable with a decision or a course of action
being undertaken, take the issue to a higher level within the YORK BUNKER B.V. organization.
Make sure you get good advice. But what is most important: Observe our Code of Conduct and
never accept that others will violate it. We should be aware that our values define us to the world.
Therefore, YORK BUNKER B.V.’s image and reputation rests in each of our hands, everyday.
Contents
1. 2. Observing laws and social norms
Individual responsibility for the reputation of YORK BUNKER B.V.3. Respect for People
4. Safety, health and the environment
5. Conflicts of interest
6. Corporate citizenship and donations
7. Treatment of business partners, public officials and other representatives
8. Market and competitive behavior
9. Protection of assets and safeguarding of competitively sensitive information
10. Avoidance of contractual risk
11. Financial integrity
12. Reporting violations, enforcement, sanctions
1. Observing laws and social norms
YORK BUNKER B.V. is represented in many regions around the world and therefore operates
subject to the laws and regulations of different legal systems. Being a good corporate citizen means
that we, the employees of YORK BUNKER B.V., comply with all applicable laws, rules and
regulations in the communities in which we operate, while also respecting local traditions and other
social norms. A failure to do so could seriously damage YORK BUNKER B.V.’s reputation and
result in other negative consequences.
2. Individual responsibility for the reputation of YORK BUNKER B.V.
The regard in which YORK BUNKER B.V. is held is substantially determined by the behavior and
actions of each individual employee, irrespective of the position held within the YORK BUNKER
B.V. organization. Consequently, improper conduct, even on an isolated individual basis, can
significantly damage YORK BUNKER B.V.. Personal integrity and an elevated sense of
responsibility help all of us to decide which response is most appropriate in a given situation. We
should always ask ourselves:
• Is my action or my decision in keeping with relevant laws, standards and norms, and with the
values and standards of YORK BUNKER B.V.?
• Are my actions and decisions free from personal conflicts of interest in all cases?
• Will my decision withstand public scrutiny?
• Am I, through my behavior, contributing to the reputation of YORK BUNKER B.V. as a company
that maintains high ethical and legal standards?
3. Respect for people
YORK BUNKER B.V.’s continued success depends upon our commitment to develop and utilize
the diverse talents and energies of all YORK BUNKER B.V. employees, throughout the world.
Employees and prospective employees are assessed based upon principles of equality and fairness.The hiring, compensation and promotion of YORK BUNKER B.V. employees is conducted in
accordance with all relevant laws and regulations.
We strive to create an environment of mutual respect, encouragement and teamwork. We value a
sharing environment that provides the opportunity for open communications, continuous learning
and diversity: these are the sources of our strength, today and in the future. Our goal is to provide
a workplace environment that attracts and retains highly talented and motivated people, while
helping them to achieve their full potential, without regard to their differences or similarities. Each
of us is responsible for creating a workplace environment that rewards high performance and a
commitment to excellence, as well as an atmosphere of trust and respect: a productive work
environment. We also recognize our obligation to respect the personal dignity and guard the privacy
rights of all of our employees, customers, service providers and suppliers. YORK BUNKER B.V.
expects its employees, customers, service providers and suppliers to respect these principles.
4. Safety, health and the environment
YORK BUNKER B.V. and each of its employees play an active role in making the locations in
which we operate a good place to live and work. Protecting people and the environment, and
conserving resources, have long been counted among our core values. YORK BUNKER B.V. has
been and remains committed to sustainable and socially responsible development; the promotion
of safe and healthful working conditions; and striving for sustained progress in the fields of safety,
health and the environment.
Specifically, each of us must:
• conduct work and maintain his workplace in a safe manner;
• immediately report to the relevant internal departments any accidents, operational malfunctions,
dangerous conditions, chemical spills or other hazardous conditions that are detected so that
appropriate measures can be promptly taken to minimize damage and correct the problem.
5. Conflicts of interest
We demand of ourselves, and those with whom we associate, the highest ethical standards. Private
interests and the interests of YORK BUNKER B.V. must be kept strictly separate. Consequently,
all employees should avoid situations that may lead to a conflict between their personal interests
and those of YORK BUNKER B.V.. YORK BUNKER B.V. employees, during contacts with
existing or prospective customers, suppliers, clients and competitors, must act in the best interests
of YORK BUNKER B.V. to the exclusion of any personal advantage. The following situations can,
in particular, give rise to possible conflicts of interest:Business relationships
• Business relationships with a company in which an employee, a relative or a friend of an employee
has a direct or indirect stake in the form of a significant shareholding.
• A specific transaction with another company in which a relative or friend of an employee is
involved or has a financial interest on the side of the other company concerned.
• Transactions with former employees or that directly involve friends or relatives of an employee.
In the event of possible conflicts of interest, you must inform your manager and await a decision
by YORK BUNKER B.V. as to how you should proceed.
Private activities
Integrity and loyalty are also indispensable in relation to private employee activities that may have
an effect on YORK BUNKER B.V.. All employees must ensure that any second or additional
occupations, sideline activities or spare time work have been previously approved, in writing, by
your manager, or by the respective Human Resources Department, if:
• such activities or related work could adversely affect your operational and professional
performance;
• such secondary activities could potentially create a conflict or the appearance of a conflict
with the actual or contemplated business activities of YORK BUNKER B.V. and partners;
• YORK BUNKER B.V. facilities or equipment are to be used or a particular operational
experience or expertise gained while in the employ of YORK BUNKER B.V. is to be utilized.
Express, written approval from the respective Human Resources Department must also be obtained
where employees wish to perform functions in companies with which YORK BUNKER B.V. has
business relationships or is in competition.
Social involvement
YORK BUNKER B.V. welcomes the private involvement of employees in clubs, associations and
other social or cultural institutions that pursue generally recognized and legally permitted
objectives. Such involvement must not, however, jeopardize the fulfillment of your duties with
respect to YORK BUNKER B.V. as your employer. Nor may such involvement impact upon the
regard in which YORK BUNKER B.V. is held. When expressing private views within a public
arena, employees shall not make any reference to their position within YORK BUNKER B.V..6. Corporate citizenship and donations
As a responsible corporate citizen, YORK BUNKER B.V. makes financial and material donations
in support of social institutions, environmental initiatives, education, science, health, sport, art and
culture.
The criteria applied in relation to donations are essentially as follows:
• need;
• sustainable effect;
• transparency, i.e. the recipients and the specific purpose must be known to enable monitoring of
the proper appropriation of donations;
• no donations to political parties;
• no donations or support for organizations or institutions that do not pursue generally recognized
and accepted objectives.
7. Treatment of business partners, public officials and other representatives
We expect our suppliers and service providers to respect our ethical standards, and to act
accordingly.
Within the marketplace, YORK BUNKER B.V. enhances its standing through the quality and value
of its services. We make decisions on the basis of known economic criteria, within the bounds of
relevant laws, standards and norms.
We are honest in our dealings with others, obeying all applicable laws and corresponding
regulations governing fraud, bribery and corruption, and avoiding even the appearance of a conflict
of interest.
Acceptance and granting of incentives, gifts and favors
To retain the trust of others and sustain long-term relationships, we recognize the need to avoid
even the appearance of a conflict between personal interests and the interests of YORK BUNKER
B.V.. As employees of YORK BUNKER B.V., we acknowledge our responsibility to conduct
ourselves in a manner that ensures that no personal dependencies, obligations or commitments
arise. We may not permit ourselves to be influenced in our business decisions and actions by either
gifts or any other type of benefit or incentive. It is recognized that giving or accepting such gifts
could put YORK BUNKER B.V. at legal risk, while also undermining our customer relationships
and reputation.To this end, no employee of YORK BUNKER B.V. may, in the course of their business activity,
either directly or indirectly, demand, accept, offer or grant incentives or rewards that would be
unethical. This applies with respect to individuals, companies and also public institutions.
In particular, no inducements whatsoever may be offered or granted to any holder of public office,
either at home or abroad. This applies to all types of favor, benefit, gift and payment, or any other
consideration. The only recognized exception is that of generally accepted customary, occasional,
or promotional gifts of small value, in keeping with local mores and customs. Also permitted are
acts of hospitality and other favors provided they are legally permissible and of verifiable small
value. In order to preclude any suspicion of any attempt to influence business decisions, strict
standards are applied when judging the value of a consideration and when deciding whether the
consideration is in line with local mores and customs.
Approval
If employees intend to offer someone a gift or favor, and if they have even the slightest concern as
to whether this could influence a decision, they must ask the recipient to have acceptance approved
by the latter’s managers. If the recipient refuses to do this, this should be regarded as an indication
that they themselves find the gift inappropriate.
Employees of YORK BUNKER B.V. are likewise required to obtain approval from their managers
for the acceptance of gifts or favors where any doubts as to their propriety exist.
Money laundering
No employee shall, either alone or in concert with others, perform any activities that contravene
domestic or foreign regulations governing money laundering. In the event of doubts as to the
propriety of transactions that involve the transfer of cash, the relevant financial department should
be consulted at an early stage.
8. Market and competitive behavior
YORK BUNKER B.V. and its employees are unconditionally committed to the principles of fair
competition and must comply with the antitrust and fair competition laws of the countries in which
YORK BUNKER B.V. conducts business.
As accurate legal assessment depends on the complexities of the laws concerned and the individual
circumstances of each situation, an attorney from YORK BUNKER B.V.’s Law Group should be
consulted wherever doubt arises. Nevertheless, there are forms of conduct that typically constitute
a violation of competition laws:Relationships and interactions with competitors
Agreements with competitors and coordinated behavior aimed at or causing a restraint or limitation
on competition are forbidden. These include agreements to fix or set prices, quotations, terms and
conditions of sale, production or sales quotas, and also the apportionment or allocation of
customers, territories, markets or product portfolios. Not only formal agreements are forbidden, but
also coordinated behavior arising from, for example, informal talks or gentlemen’s agreements
aimed at or giving rise to such a restraint on competition.
In discussions with competitors, we must apply strict controls in order to ensure that we do not pass
on or receive any information that would allow conclusions to be drawn about the current or future
market behavior of the information donor. Thus, a Company attorney should always be consulted
prior to engaging in a joint activity that involves communications with competitors. Current or
future information regarding price, margins, costs, market share, internal proprietary practices,
sales terms and specific customer or vendor information should not be obtained from or exchanged
with a competitor.
Customer relationships
Relationships with our customers, suppliers and also patentees or licensees are governed by a
number of legal regulations relating to fair competition. In accordance with these laws and
regulations, YORK BUNKER B.V. employees will not act in any way that would restrict a
customers’ pricing freedom or interfere with supply relationships with their business partners
(geographical, personal or material restraints). YORK BUNKER B.V. employees will not
encourage illegal tying and resale arrangements.
Abuse of a dominant market position
Owing to its market position in relation to certain products, YORK BUNKER B.V. also has to obey
certain special rules. For example, abuse of a dominant market position may be deemed to have
occurred in the event of differentiated treatment of customers without material justification, refusal
of supply, the imposition of inappropriate purchasing/selling prices and terms and conditions, or
tie-in transactions without any material justification for the demanded additional counter
consideration.
The definition of a dominant market position is variable from case to case, as are the limits of
permissible behavior. In cases of doubt, early contact should be made with a YORK BUNKER B.V.
corporate attorney.
Trade and professional association meetings
While attendance at and participation in such meetings, on behalf of YORK BUNKER B.V., may
be important to further corporate objectives, it is also recognized that attendance at such meetings
can present a potential antitrust/fair competition risk due to contacts with competitors during thecourse of the meeting. YORK BUNKER B.V. employees shall attend only meetings of legitimate
trade and professional associations, conducted for proper business purposes. It is preferable that
meeting minutes be taken and made available. Any benchmarking or comparative information
supplied must be in full compliance with applicable laws and regulations. When in doubt, a YORK
BUNKER B.V. corporate attorney must be consulted.
9. Protection of assets and safeguarding of competitively sensitive information
Within their sphere of activity, all employees bear their share of responsibility for the protection of
the tangible and intangible assets of YORK BUNKER B.V.. Physical or tangible assets include
property such as Company products, equipment, facilities, vehicles, computers and software, bank
accounts, stocks and bonds, charge cards, files and other records. Intangible assets include
informational assets, such as information developed by employees or agents of YORK BUNKER
B.V. that is not generally known to the public (i.e. business secrets and/or know-how), industrial
proprietary rights, technologies, and other items of information that are of value, important and
thus needful of protection. Information provided by suppliers, customers and other business
partners might also require protection.
In this context, IT security plays an important part. All employees are requested to use the
information systems only in an ethical, legal and courteous manner and to use the provided security
tools e.g. encryption and security procedures e.g. password handling to protect the YORK
BUNKER B.V. data sufficiently.
Private use of corporate property
Installations, systems, facilities and equipment in offices and other corporate property of YORK
BUNKER B.V. may only be used by employees for non-Company purposes with the written
approval of appropriate levels of management or in accordance with special corporate
guidelines/rules.
Treatment of confidential information
Employees are obliged to treat as confidential all internal matters relating to YORK BUNKER B.V.
that have not been expressly approved for release into the public domain.
The communication of confidential internal information (for example, business strategies, research
results or contents of internal reports), to unauthorized personnel either inside or outside YORK
BUNKER B.V. is not permitted. This also applies to information that employees have received
from third parties on a confidential basis. If your job requires you to disclose certain confidential
information to third parties, specific manager approval is necessary and consideration should be
given to the need for a confidentiality agreement, approved by a Company attorney and signed by
the third party that will receive the confidential information.Employees who, on the basis of their association with YORK BUNKER B.V., learn of confidential
information not approved for release into the public domain shall not use this information for their
personal benefit nor for the benefit of any other person.
10. Avoidance of contractual risk
YORK BUNKER B.V. takes its responsibility to contractual partners seriously. To avoid
misunderstandings and unintended consequences, the risk management system of YORK
BUNKER B.V. requires that all employees who bear responsibility for the conclusion of
agreements and contracts shall, prior to such conclusion, perform a careful assessment of the
contractual duties and terms and of the risks that could arise from such agreement. Due to the
complexity and legal implications associated with commercial agreements, as well as the potential
for conflicts with other corporate relationships, it is the policy of YORK BUNKER B.V. that the
YORK BUNKER B.V. Law Group be involved in the preparation and review of all material
contracts as defined by the Company.
11. Financial integrity
In order to maintain the trust and respect of our shareholders, employees, business partners,
communities and government officials, our financial reporting must be correct and truthful at all
times. In addition to the invoices we will keep our Partner Business Org up to date.
Reporting system
All records and reports published for external consumption must be prepared timely and in line
with all relevant laws and regulations.
Accounting practice
In keeping with existing legal requirements, as well as internationally recognized accounting
standards, YORK BUNKER B.V.’s assets, financial transactions, operating positions, and cash
flows must be accurately recorded and openly reflected in the Company’s records and public
documents. We conduct business consistent with all applicable laws and regulations in every place
that YORK BUNKER B.V. conducts business. We, the employees of YORK BUNKER B.V., strive
to do the right thing.
12. Reporting violations, enforcement, sanctions
The provisions of this Code of Conduct represent the fundamental components of YORK BUNKER
B.V.’s corporate culture. This document should, however, not be misinterpreted as providing a basis
for demanding that YORK BUNKER B.V. adopt a certain mode of behavior. We, the employees of
YORK BUNKER B.V., acknowledge that employees who violate any laws, regardless whether
they are subject matters of our Code of Conduct or other Company policies may be disciplined up
to and including termination of employment. YORK BUNKER B.V. managers may also bedisciplined for failing to detect a violation in their area if, in the judgment of the Company, the
failure resulted from inadequate supervision of employees.
Advice
YORK BUNKER B.V. strives to provide its employees with the information and training needed
to assist employees in avoiding situations that might violate the law, our Code of Conduct or other
Company policies. However, in cases of doubt, employees may obtain advice from their line
managers or the Legal, Audit or Human Resources departments.
Reporting violations
Violations of the law, the YORK BUNKER B.V. Code of Conduct or other Company policies can
be raised with your manager, human resources or audit representative, or a Company attorney.
Any reports must be in line with the law. Anyone who consciously makes false statements regarding
another person may commit a criminal offense.
Reprisals
The Company will not discharge, demote, suspend, threaten, harass, or in any other manner,
discriminate against an employee who reports a violation. YORK BUNKER B.V. will also not
tolerate any attempts whatsoever to prevent employees from reporting such matters.
Vision & Values
Conflicts of Interest, Gifts and Entertainment, Bribery and Improper Dealings
All YORK BUNKER B.V. employees are expected to have undivided loyalty to the company. We
make decisions in our company’s best interest and seek to avoid situations where our personal
interests or outside influences would conflict or appear to conflict with those of the company.
1. Conflicts of Interest
A conflict of interest arises when an employee’s personal, social, financial, or political activity may
interfere, or has the appearance to interfere, with his or her loyalty or objectivity to YORK
BUNKER B.V.. Conducting YORK BUNKER B.V.’s business in an honest and ethical manner
requires an appropriate handling of real or parent conflicts of interest. If a conflict of interest has
arisen, or if the potential for a conflict of interest exists, the matter should be disclosed to your
manager.
Common Examples of Conflicts of Interests
• Employment and affiliations outside YORK BUNKER B.V..A second job providing services to or consulting with organizations doing business with or directly
competing against YORK BUNKER B.V. may create a conflict of interest and must be approved
by your manager. Activities or engagements of this kind would never be permissible if such work
or services were for a company you interact with as part of your job.
• Employment of Close Relatives.
If a close relative works for a customer, competitor or supplier of YORK BUNKER B.V., and if the
relative may be involved with you as part of your job responsibilities, you should promptly notify
your manager. As a rule, a relative should not have a business relationship with you in your capacity
as a YORK BUNKER B.V. employee, anyone working in your business unit, or anyone reporting
to you.
• Internal Employment of Relatives; If internal employment of relatives elsewhere in the company,
or a relationship of a personal nature may interfere with your duties or may raise a conflict of
interest, your manager or your Compliance Representative should be informed so that
management may change the reporting or working relationship or take further appropriate steps
to address the situation.
• Boards of Directors. Occasionally, accepting a position to serve on the board of directors of
another organization (including positions in non-profit organizations), may raise a conflict of
interest. Prior to accepting such a position, written approval from your manager.
• Investments. Employees’ investments may raise a conflict of interests if made in competitors,
customers, or suppliers of YORK BUNKER B.V.. Prior written approval of your manager is
required, if the investment is substantial and may influence your judgment as a YORK BUNKER
B.V. employee. Please note that these rules also apply to business contacts with potential suppliers
and potential customers accordingly.
General Guidance
Any apparent conflict of interest should be fully explained to your manager so that prior written
permission is obtained. If you are uncertain about priorities or about your conduct in a potential
conflict of interest situation or business relationship, you may consider what your answers would
be to the following questions, and approach your Compliance Representative for further advice, if
one of the answers is “Yes”:
• Would my activity affect or appear to affect any decision I will make for YORK BUNKER
B.V.?
• Might others inside the company or my co-workers think it could affect my judgment or
influence my job duties?2. Gifts and Entertainment
As employees of YORK BUNKER B.V., we are in contact with various suppliers and customers
vital to YORK BUNKER B.V.’s success. Accordingly, relationships with suppliers, customers and
other third parties require clear commitments to fair dealing and sound business decisions. The
exchange of gifts and entertainment of an excessive nature may have an impact on our ability to
make decisions free of any conflict of interest. Gifts and entertainment of a nominal nature
ordinarily would not create a conflict or create the appearance of impropriety provided that local
business practice and customs allow the offer and acceptance of inexpensive gifts or mementos and
modest entertainment. Extravagant gifts and entertainment are never acceptable. In the rare event
that a legitimate business reason or local business practice allows acceptance of a gift of significant
value, it becomes property of YORK BUNKER B.V. and must be delivered to the company for use,
display or other disposition. Upon his request, YORK BUNKER B.V. may decide to sell the gift to
the employee, who forwarded the gift to the company.
Gifts and Entertainment Definition
Generally, gifts and entertainment mean anything of value. The list of potential items may be
endless and the following examples are for illustrative purposes only:
• Gifts:
Cash or cash equivalent, discounts or favourable terms on products or service (except, if granted to
all YORK BUNKER B.V. employees), loans, prizes, transportation, use of vehicles, use of vacation
facilities, gift certificates, stocks, watches, calendars, pens or other promotional items and
accessories, etc.
Entertainment:
Business meals, sports events, hotel arrangements, etc.
• Appropriate or Inappropriate Gifts and Entertainment
YORK BUNKER B.V. has developed two general categories defining appropriate and
inappropriate gifts and entertainment. Gifts and Entertainment – customarily allowed or allowed
with Prior Approval Gifts and entertainment which are allowed and do not require special approval
must be nominal in value (estimated value up to € 50.–) and considered a matter of common
business courtesy under local business practice. Entertainment must be linked to a valid business
purpose. As a rule, the following modest expressions of goodwill, if consistent with local law,
industry, and business practice, are acceptable:
inexpensive promotional items, “logo” pens, calendars, caps and the like, flowers, a fruit basket, a
book or comparable items, a small collection of product samples, occasional meals, ordinary sport
event, theatre or other cultural event (any entertainment, but only if customer is in attendance).For any entertainment offered to you in excess of a market value of € 300.– in the single case (or
from any one source in a year) you may wish to get prior written approval from your manager. The
same applies if you are offered travel or entertainment lasting more than one day or a limited public
access/contingent special event entertainment (for example, “Soccer Worldcup”).
Generally, if you are considering accepting or approving a gift or entertainment, even if within the
limits mentioned above, you should always consider the following issues:
• Would the gift or entertainment likely influence your objectivity?
• Is the gift or entertainment linked to a business purpose?
• Would your acceptance/approval set precedents for other employees?
• Would you expect to receive negative feedback in case your acceptance/ approval were made
known to other YORK BUNKER B.V. employees or to the public outside your company, or to
your friends or your family?
Inappropriate Gifts and Entertainment
In a number of cases, the acceptance of gifts or of entertainment is inappropriate or wrong and
YORK BUNKER B.V. employees are requested to never accept or approve it:
• if the gift is cash or cash convertible or cash equivalent, for instance, any kind of money transfer,
bank check, loan etc; or
• if the gift or the entertainment would be illegal or would result in violation of laws; or
• if the acceptance of a gift or of entertainment would be – or could be regarded as – anything “quid
pro quo,” or
• if the gift or entertainment would embody an activity being regarded as immoral or would violate
mutually accepted principles of respect, religions or cultures (including, but not limited to,
sexually orientated activity); or
• if the gift or entertainment would violate the offering employer’s standards, rules or regulations.
• Procedure Upon Receiving an Inappropriate Gift
Any gift that you receive that would be wrong or inappropriate according to the principles described
above, must be returned immediately and your manager should be informed accordingly. Where
appropriate and in order to prevent further impropriety, a letter to the donor may be issued
addressing YORK BUNKER B.V.’s policy with respect to gifts.• Offering Gifts and Entertainment to Third Parties
YORK BUNKER B.V.’s rules for acceptance of gifts and entertainment described above are also
applicable when gifts and entertainment are offered by YORK BUNKER B.V. employees to
suppliers and customers, or other third persons having a business relationship to YORK BUNKER
B.V.. The guidelines just mentioned also apply to YORK BUNKER B.V. employees who make
gifts to third parties so that:
• no gift should be made in value in excess of the limits described above, and
• entertainment, if its nominal value exceeds € 300.– (or lower amount is consistent with local
business practise) in a single case or to any one person or organization in a year, should not occur.
Any exception to the foregoing requires prior written approval of your manager.
3. Anti-Corruption Compliance – Restrictions for Gifts, Entertainment or Other Favours
to Government Officials
As employees of YORK BUNKER B.V., we strictly restrain from offering money or anything else
of value, directly or indirectly, to government officials to avoid influencing, or appearing to
influence, official decisions and actions. Most countries around the world have adopted antibribery-
laws, providing fines, criminal penalties (including possible imprisonment) and costly enforcement
actions as well as high damage penalties against both the company and its employees found guilty
or being involved in bribery activity. Further, activities violating antibribery laws may severely
damage YORK BUNKER B.V.’s reputation and the reputation of YORK BUNKER B.V.’s
employees and may lead to the vicarious liability of innocent third parties. For the purpose of this
provision, the term “government official” shall include any individual working at a local, state or
national govern-mental entity or agency or other institution and having a status similar to
government officials by pertinent law, and their families in a broad sense.
General Guidance
• No YORK BUNKER B.V. employee may promise, offer or provide any gift or other contributions
of whatever value, kind and nature, to government officials, directly, indirectly or through an
intermediary.
• No YORK BUNKER B.V. employee may provide meals, travel and entertainment to government
officials, directly, indirectly or through an intermediary. The sole exception to the foregoing rule
may be those instances where the meal, entertainment and transportation is occasional and
• directly and in good faith linked to a valid business event involving the government official in his
or her official activity,
• is of reasonable, moderate value, and• upon careful consideration, if strictly consistent with local laws and local practice. Any such offer
to government officials or employees will always require prior written approval of your manager.
• YORK BUNKER B.V. and its employees may not, directly or indirectly, make donations and
cannot promise, offer or provide any kind of gifts, individual entertainment, travel or meals to
politicians, political parties, political organizations or to trade unions and their representatives,
except where explicitly allowed or provided by local law, and then only in compliance with local
law and upon written approval of the Compliance Representative. YORK BUNKER B.V.’s books,
records and accounts will duly reflect these transactions and dispositions.
4. Protection of YORK BUNKER B.V. Funds and Assets, “Internal Gifts”
YORK BUNKER B.V. employees are committed to protect and manage the company’s funds and
assets with uncompromising honesty. We do not misuse our position at YORK BUNKER B.V. or
its funds or assets to privately enrich ourselves or others inside or outside of YORK BUNKER
B.V.. Accordingly, YORK BUNKER B.V. funds and assets are never available for unauthorized
donations or other benefits such as personal or private purposes, and must be used for “company
purpose” only, such as:
• if in YORK BUNKER B.V.’s name, as giving entity; or
• if provided by individual or collective employment contract; or
• if linked to a valid business case or to a company event; or
• if linked to individual or collective official proceedings at YORK BUNKER B.V.; or
• if individual or collective incentive and had been properly rewarded and recorded.
5. Commercial Bribery and Improper Business Dealings
In most countries, commercial bribery is illegal and subject to criminal prosecution and penalties,
not to mention loss of reputation and high civil or criminal penalties. Even worse, commercial
bribery undermines fair trade and fair market competition. YORK BUNKER B.V.’s goal is to win
customers and consumers for its products by virtue of the product quality and value, not by illegal
and unfair means.
Accordingly, any personal payment, bribe, kickback or similar received by Triforcia IT
Consulting employees, or any offering of personal payments, of bribe or similar by YORK
BUNKER B.V. employees to customers, suppliers or other third parties doing business with YORK
BUNKER B.V., is strictly prohibited. This prohibition to offer or receive such payments extends
even to those localities where such practices are tacitly condoned, or where local law may provide
lower ethical standards.In order to support the establishment of fair market conditions and to address the situation, YORK
BUNKER B.V. employees should without delay report the offer of any improper payment to their
manager, or a member of YORK BUNKER B.V. Law Group. For the avoidance of doubt, improper
payments, bribes or similar include any and all benefits, including cash, cash equivalent, any kind
of valuable services or other benefits of value, wrong fully offered to the employee, his family, or
relatives.
When you observe some behavior that you believe violates our Code of Conduct, we expect you to
report it. Ideally, you should bring any concerns forward to your direct manager, or other member of
our management team.
+31 6 151 31691
info@yorkbunker.com