Corporate
Governance

Corporate
Governance


Corporate Governance
Shearwater recognises that sound corporate governance is fundamental to commercial success and long-term value creation for our owners and other stakeholders.

Shearwater has established policies and procedures to ensure its organisation is governed in the best interest of all its stakeholders.


Ethical business conduct

Shearwater recognises that strong governance and risk management structures are fundamental to commercial success and long-term value creation for our employees, owners and other stakeholders. Sustainable governance requires good and healthy business practices, compliance with legislation and regulations, supported by transparent and reliable reporting and communication. Shearwater has established policies and procedures to ensure its organisation is governed in the best interest of all stakeholders.


Code of Conduct

Code of Conduct
Code of Conduct

Whistleblowing
Whistleblowing
Whistleblowing

Anti-bribery and corruption


Anti-bribery and corruption
Anti-bribery and corruption

Corporate Social Responsibility Policy
Corporate Social Responsibility Policy
Corporate Social Responsibility Policy



Trade Compliance Policy
Trade Compliance Policy
Trade Compliance Policy

Environmental, Social & Governance Policy
Environmental, Social & Governance Policy
Environmental, Social & Governance Policy



Information Security Policy
Information Security Policy
Information Security Policy



Quality, Health, Safety & Environment (QHSE) Policy
Quality, Health, Safety & Environment (QHSE) Policy
Quality, Health, Safety & Environment (QHSE) Policy

Enterprise risk management

Shearwater has an established policy for Enterprise Risk Management which describes the related processes, responsibilities and reporting structure from input to review and presentation. Risks and associated opportunities are identified and evaluated through input from various levels of the organisation and categorised in five main categories; Strategic and ESG, Operational, QHSE, Compliance and Financial risks. All risks identified are evaluated based on their severity and probability in a risk matrix approach.

The management performs periodic reviews of corporate risks identified by the organisation which are reported to the Board of Directors on a semi-annual basis. The risk reporting ensures management and Board dedication to initiatives introduced to reduce risks and provides the organisation with a reporting tool to increase attention to risks, initiate measures and monitor the development of risks.

New contracts, entry into new countries and engaging with new clients, agents or cooperating partners are considered by a Corporate Risk Committee to identify risks and mitigation efforts before project start-up. The Corporate Risk Committee consist of representatives from various departments in the organisation to provide a broad experience-based risk assessment before decisions are made.


Supply chain management

The standards and actions of Shearwater’s business associates have an impact on our own business. All business associates are expected to have implemented ethical standards corresponding to those of Shearwater.

Shearwater’s Business Associates and Sanctions Guidelines supplement Shearwater’s Code of Conduct and Anti-Corruption Guidelines and provide details on Shearwater’s commitment to comply with applicable laws and to ensure the ethical conduct of its business associates. Prior to entering into any form of business relationship, Shearwater assesses the level of risk associated with such a relationship. To conduct this risk assessment, business associates are subject to a Dow Jones screening, and suppliers, partners and agents must complete an on-boarding questionnaire. Subject to the responses and documentation received, this may result in further due diligence being required. Any “red-flags” or other findings of concern are bought to the immediate attention of the Legal Department to determine how to proceed.

During 2021, we implemented additional procedures for supplier onboarding, supplier management, and the tendering and selection of support and guard vessel to improve supplier compliance and the effective management of our suppliers. We require all our suppliers to acknowledge that they have read and will comply with Shearwater’s Code of Conduct. During the first half of 2022, Shearwater is implementing a monitoring tool available through Dow Jones that will allow us to monitor up to 1,000 suppliers on an ongoing basis.


Corporate Governance

As a Norwegian private limited group, Shearwater must comply with the Norwegian Private Limited Liability Companies Act and all other applicable laws and regulations. Shearwater endorses the Norwegian Code of Practice for Corporate Governance which is reflected in the Group’s corporate governance policy.

The policy is designed to establish a basis for good corporate governance to support the achievement of the Group's core objectives on behalf of its shareholders including sustainable profitability. How Shearwater is governed is vital to the value creation over time.

Shearwater believes that good corporate governance involves openness and trustful cooperation between all parties involved in the Group: the shareholders, the Board of Directors and executive management, employees, customers, suppliers, public authorities and the society overall.