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K2 Project Forwarding is a part of Peak Group and follows Peak Group's compliance policy.

1. Business philosophy and ethical principles

1.1 Company profile

Peak Group is an internationally renowned transport and logistics group with headquarters in Bergen, Norway. We handle a wide range of goods within the bulk, breakbulk and project industry.

Since the beginning, Peak Group has built a comprehensive international network through partnership and collaboration with some of the industry’s most respected and professional actors.

Peak Group’s business philosophy evolves around quality and flexibility.

Peak Group’s ambition is to become a strategic and preferred logistics partner for our customers by establishing itself as the foremost player in the global logistics solutions market.

The key to Peak Group’s success is the ability to develop innovative services and logistics concepts based on high expertise and advanced information technology.

1.2  Principles of values

Peak Group conduct themselves to the following principles of values:

  • Safety/confidence
  • Problem solver
  • Flexibility
  • Speed
  • Information
  • Accessible
  • Innovative
  • Not only price

1.3  Commitments

Peak Group aims to establish a standard of ethics and integrity, in accordance with the law. Peak Group’s own program for compliance with legal requirements and code of conduct are implemented completely internally and externally.

All employees, agents, vendors, and public authorities involved in our operations are required to abide by applicable laws and regulations, and execute their duties in compliance with the standards set out in these documents, thereby helping to safeguard our reputation and reduce risk to both the company and individual.

1.4 Principles

  • Peak Group aims to maintain a high ethical standard and is reliable and committed to the company’s goals and visions.
  • Peak Group places unequivocal demands on the honesty and the integrity in relation to activities carried out on behalf of the company.
  • Peak Group focus on security in all activities and will never compromise on security regarding employees, clients and agents.
  • Peak Group aims to maintain responsibility, ethical and healthy commercial activities throughout the group. This includes strict requirements on us, our impact on the environment and what is expected from the society in general.
  • Peak Group is an informal organization based on respect for each other, openness and involvement. Peak Group aims for a culture supporting our employees growth and working conditions.
  • Peak Group aims for equality and diversity in its organization. Discrimination and harassment is not tolerated.
  • Peak Group insists on integrity, honesty and fairness in all aspects of our local and global business, and we seek the same from those with whom we do regular business, directly and indirectly.
  • Peak Group strive to be an attractive, trustworthy and long-term partner.

1.5  Corruption and facilitation payments

Corruption is to bribe or receive bribes, in the form of money, gifts or services, in order for a person in power to give another person benefits beyond the rules. Corruption occurs when a person in a trusted position or office, privately or publicly, puts the responsibility and obligations attached to the position aside and abuse the power in the post or office and thereby achieves either a private benefit or reward, or improperly strives for an advantage to your own organization or company. This is the definition of corruption laid down by the Confederation of Norwegian Enterprise (NHO).

Peak Group recognize the value of networking is an important part of our activities, and our ethical standards are established to draw the lines between constructive working and bribery / corruption. Facilitation payments refer to relatively small payments or rewards made in order to expedite, or ensure the provision of services that would, or should, in any case be provided in the normal course of events. There is a very thin line between what may be a “facilitation payment” and what may be a bribe, and great care must be taken in deciding whether or not such payment is legal, necessary and justifiable. Peak Group is against making these payments, and expressly forbids them if they are illegal.

Peak Group will work to reduce and ultimately eliminate these forms for payments. Any employee who is uncertain and feeling that they are on the borderline, shall avoid such payments. If in doubt, the nearest manager shall be contacted to make sure that the Peak Group’s ethical guidelines are in place.

1.6  Gifts

The value of gifts shall be within the limits set under relevant tax rules. In some cases it will be appropriate to accept larger gifts / prizes, but only on behalf of the company. Gifts of significant value shall be handed over to the company at the first opportunity. Openness is important, and gifts / prizes / dinners offered or given, have to be formally reported to the management of the respective company. Bribes are treated as a deliberate attempt to put the organization or an individual in a situation where the individual / persons have no choice, and where reciprocal benefits are demanded. It is not allowed to accept bribes. No kind of bonus or gift that can be interpreted as a bribe may be accepted or offered.

1.7  Human Rights

Peak Group:

Oppose all forms of modern slavery, forced labor and child labor abuse.

Uphold freedom from discrimination and harassment, including but not limited to gender, race, color, religion, political views, union affiliation, ethnic background, disability, sexual orientation or marital status.

Uphold the principles of freedom of association and collective bargaining, including respect for each employee’s right to make an informed decision, free of coercion, about membership in associations or labor unions.

Uphold decent working conditions at a minimum according to applicable laws and industry standards, including for working hours, terms of employment, leave of absence and compensation.

We aim to uphold wages and benefits to cover basic needs and some discretionary income, as well as a family-friendly workplace. Uphold the right to health and safety for our employees and suppliers’ employees, at a minimum according to applicable legal workplace safety and industrial hygiene standards, and for communities, including environmental, climate and security impacts relating to human rights.

Uphold the right to privacy of those who entrust us with their personal information.

Will be attentive to the rights of vulnerable individuals and groups. These include:

  • Indigenous and tribal peoples, as well as traditional communities, and their rights to self-determination, to lands which they traditionally occupy, to their customs, traditions and institutions, and to their free, prior and informed consent (FPIC).
  • Women
  • Children and young people
  • Migrant workers
  • Minorities
  • Human rights, worker rights and environment defenders and their rights to freedom of expression, association, and peaceful assembly and protest against our business and operations.

Have zero harm to personnel and to the environment  as our main focus. Peak Group will only order vessels with zero emission technology from 2030. Peak Group will have a climate neutral fleet from 2050.

Have zero tolerance of corruption within our organization or conducted by our partners, suppliers or others conducting business on our behalf.

1.8 Relation with business partners

Peak Group expects the same commitment to legal and ethical conduct of subcontractors as Peak Group requires from its board members, managers and employees. A part of this compliance program includes evaluation and assessment our regular suppliers / agents with respect to compliance. This “due diligence process” requires specific information about our subcontractors, and the subcontractors may be asked to reply on questions regarding ethical guidelines as a part of this data collection.

2  Guidelines for bribery and corruption

Peak Group is committed to comply with laws designed to combat bribery of officials and corruption. As part its contractual commitment to our clients, Peak Group introduces the following policies and procedures to govern all aspects of work or services.

2.1  What are bribery and corruption?

Corruption (derived from corrupting, Latin corrumpere) is to bribe or receive bribes, in the form of money, gifts or services, in order for a person in a power to give another person benefits beyond the rules. Corruption occurs when a person in a trusted position or office, privately or publicly, puts the responsibility and obligations attached to the post or aside and abuse the power in the post or office and thereby achieves either a private benefit or reward, or improperly strives for an advantage to own organization or company. This is the definition of corruption laid down by Confederation of Norwegian Enterprise (NHO).

2.2   Basic conduct

Peak Group and/or their owners, directors, board members and employees are subject to local and international laws and regulations that forbid and punish bribery and corruption, and all Peak Group employees are expected to comply with all applicable laws and guidelines.

Any Peak Group employee who violate any applicable laws or this policy will immediately be reported to the respective management, which comes to an appropriate discipline, which may also include termination.

2.3 No improper payments

Owners, directors, officers, employees and any other parties acting for or on behalf of Peak Group will not support any offering, paying, promising or authorizing any bribe, or other thing of value to any government official, government employee, customer, or business associate, directly or indirectly through a third party, to secure any contract, concession or other favorable treatment for Peak Group or our clients. Any such action may be considered to be a bribe and may result in violation of applicable law.

Accordingly, Peak Group personnel shall comply to the Company’s policies on the provision of and reimbursement for gifts, representation, meals and travel expenses, and with the Company’s relevant provisions on accounting and retention of documents to ensure that such expenses are properly documented.

2.4 Who is a government official?

Laws prohibiting the bribery of “officials” typically define “official” broadly to include any appointed, elected, or honorary official or any career employee of a government, of a government owned or controlled company or enterprise, or of a public international organization, or any person acting in any official capacity. The definition encompasses officials in all branches of government: executive, legislative and judicial. It also includes political parties, party officials and candidates for political office.

2.5  Gifts, representation, meals and travel expenses

Peak Group employees shall not give inducements, including gifts, representation, meals or travel expenses, to holders of public offices, customers or business associates on a scale that might be perceived as creating an unreasonable obligation on that recipient or that violates any applicable law or government policy against bribery or corruption. Gifts, representations, meals or coverage of travel expenses provided to holders of public offices, customers or business associates must be approved by the respective manager after review for compliance with applicable laws value. When considering the reasonableness of the expense, Peak Group employees should consider the frequency with which such expenses are incurred for a particular recipient (such as regular gifts or dinners). Modest costs may amount to lavish and potentially improper payments when aggregated. Must not be greater in amount than the legitimate and customary expenditure for such activities and not exceed the normal business practice in the country, and must not fund improper entertainment activities. Must be connected to a legitimate business promotional activity or the performance of an existing contract, permitted under local law, and otherwise consistent with company business practices. Must comply with all applicable laws and tax regulations, including any applicable code of conductor or rules governing the receipt of benefits by government officials. Must be entered accurately in the accounting book and records of the Peak Group.

2.6 Engagement of third parties

Companies can be held liable for payment made by a third party, such as a sales representative, subcontractor, consultant, agent or partner, of anything of value to a holder of a public office, even if the third party is not subject to the law and even if the company actually do not know of the payment. Company personnel may be liable if they give, pay, promise or authorize such payment when the company knows or willfully ignorant of the risk that the amount paid will be used in whole or in part for payment to a public official. To protect Peak Group and any company that Peak Group offers shipments or services, from this risk, Peak Group employees must screen diligently monitor contractual or investment relationships with any third parties with who Peak Group is doing business.

When a third party is engaged, the Peak Group must ensure that:

The third party engaged only for bona fide and legitimate purposes and services.
Adequate due diligence regarding the third party’s reputation, ethics and qualifications is completed before a regular business relationship is established.
Any “red flag” indicating a risk that the third party might make improper payment or otherwise violate applicable laws are addressed both before and during the engagement.
Third party confirms Peak Group’s code of conduct.
Third party is aware of and commits to avoid conflicts of interest.
Any compensation paid to a third party is appropriate and justifiable remuneration for the legitimate service rendered.
Third party is adequately monitored during its provision of services, and any unusual charges by third party that could conceal improper benefits to government officials or other improper recipients are queried. Common “red flags” that may indicate potential corruption include:

  • Payment to shell companies
  • Payment to offshore bank accounts
  • «Donations» to individuals
  • Cash transactions

Doing business with people or entities that are known to engage in bribery or who are suspected of engaging in bribery.

If Peak Group personnel become aware of any of these situations or others that suggest the possibility of improper payments, they should report to their manager for compliance with legal requirements at Peak Group.

2.7  Political and charitable contribution

All contributions by Peak Group to political campaigns or organizations or to charitable organizations:

Must be approved by the top manager of the respective company
Must comply with all applicable laws and policies in Norway
Must not use company funds made in the name of individuals
Must not be in return for any improper official action by any government official
Must be properly recorded in the company’s books and records.

2.8. Documents and internal audits

Peak Group shall make and keep reasonably detailed books, records, and accounts that confirm with prevailing professional  standards of accounting and that in reasonable detail reflects all transactions, including all expenditures, invoices, expense reports, receipts,  disbursements, vouchers, and other disposition of monies or assets, all in according with Norwegian accounting rules.

Records of gifts, entertainment, meals and travel expenses shall include expense dates, the names and business association of all in attendance, and the reason for the expenditure. Valid and detailed third party receipts or invoices will support all records of such payments and expenses.

Peak Group will maintain a system of internal controls sufficient to reflect with reasonable accuracy of all transactions and the disposition of Peak Group assets. Relevant personnel shall be trained in the operation of such controls. The internal controls will be sufficient to provide reasonable assurance that:

Transactions are executed in accordance with management’s specific or general authorizations. Access to assets is permitted in accordance with management’s specific or general authorizations.

3   Anti-money laudering and anti-terrorism laws and regulations

Peak Group personnel must comply with all applicable anti-money laundering and anti-terrorism laws and regulations. Peak Group personnel shall not engage in financial transactions that, directly or indirectly, promotes or result from any criminal activity prohibited by the laws in any country.

Peak Group personnel and suppliers of Peak Group should be alert to the money flow in every transaction and to question any payment methodology outside the norm. Such transactions should be screened for any of the following red flags:

Purchases inappropriate to a counterpart’s business.
Large cash transactions
Large volumes of wire transfers to and from offshore banks/businesses, especially when there is no
connection to a counterpart’s business is obvious.
Loans secured by obligations to offshore banks
Counterparts is reluctant to provide adequate identification information
Businesses whose financial statements are inconsistent with similar businesses and (especially for large businesses) whose financial statements are not prepared by an auditor
Transactions that appear to be structured to evade reporting requirements (for example, a series of transactions below 10,000 USD).
Peak Group personnel shall not engage in or support any transactions, or otherwise facilitate, any activities by any terrorist person, activity, organization.

4 Compliance with economic sanctions

Peak Group shall comply with all applicable laws imposing economic and trade sanctions against certain countries designated nationals.Peak Group shall consult with any business partner regarding assistance with compliance of all economic sanctions laws applicable to such business partner.

5  Compliance with applicable anti-boycott laws

Peak Group shall comply with all applicable laws with regard country boycotts.

Peak Group shall consult with any business partner regarding assistance with compliance of all anti-boycott laws applicable to such business partner.

6   Compliance with export control laws and regulations

Peak Group shall comply with all applicable laws regarding controls over the exports of goods and services, including applicable laws and regulations covering re-exports.

Peak Group shall consult with any business partner regarding assistance with compliance of all export control laws comply with and regulations applicable to such business partner.

Peak Group’s ethical code of conduct is intended to foster a search for continuous improvements in all aspects of our performance. It will therefore be reviewed annually and will be referred to in Peak Group’s annual report and published on our website as part of our ongoing improvement program. Peak Group’s ethical code of conduct is communicated to colleagues and collaboration partners. Peak Group intend to maintain a focus on ethics when evaluating existing and potential collaboration partners.

Bergen, 06.04.2021

Jan-Petter Slethaug

CEO, Peak Group