Code of Conduct
The Code of Conduct describes Sarachin's commitment and requirements regarding business practise and personal conduct. It describes the behaviour Sarachin expects of you and what you can expect of Sarachin.
Sarachin shall conduct its business with integrity, respecting the laws, cultures, dignity and rights of individuals in all the countries where we operate. All Sarachin employees are expected to live by our values.
Together with Sarachin's values, this Code of Conduct constitutes the basis and framework for our performance culture and governing documents. Sarachin's governing documents consist of policies with associated standards and tools, that in some instances will address the below issues in more detail, but also addressing important issues that are complementary to the business integrity matters subject to this Code of Conduct (e.g. HSE).
We are fortunate that the scale and mix of our projects enables us to make significant positive impacts in the communities where we work.
Scope and Responsibility
Sarachin shall conduct its business with integrity, respecting the laws, cultures, dignity and rights of individuals in all of the countries where we operate. All Sarachin employees are expected to act in accordance with our corporate values.
This Code of Conduct describes Sarachin's commitments and requirements regarding ethical business practices and personal conduct. It describes the behavior Sarachin expects from you and what you, and our business partners, can expect from Sarachin.
It is important to be aware that some of Sarachin's policies provide more detailed information about what is acceptable behavior and what is not (some of those policies are noted in the sections of the Code that follow).
You shall always strive to exercise good judgement, care and consideration in your service for Sarachin. In the event that there are differences between applicable laws and regulations, and the standards set out in this Code of Conduct, the highest standard consistent with applicable local laws shall be applied. Violation of this Code of Conduct or applicable laws may lead to internal disciplinary actions, dismissal or even criminal prosecution.
If you have questions regarding the content of this Code of Conduct or the interpretation thereof, please contact Corporate Legal or Corporate Business Integrity and Compliance. If you require advice in the handling of a specific ethical dilemma, you shall consult with your manager or other appropriate authority. You can also contact the ethics helpline at: .
You are encouraged to consult with colleagues when you have issues or questions regarding compliance with the Code. You are also required to report any evidence of violations of this Code or applicable laws that you identify. Reporting violations will never serve as a basis for disciplinary action.
This Code of Conduct applies to all employees (including temporary personnel) and directors in Sarachin and its subsidiaries, corporate affiliates, and joint ventures that are majority owned or controlled by Sarachin (individually and collectively). It also applies to intermediaries, lobbyists and others who act on Sarachin's behalf.
Suppliers, subcontractors and other contracting parties of Sarachin, including companies in which Sarachin own a minority stake, are expected to adhere to standards which are consistent with applicable laws and Sarachin's Code of Conduct, and Sarachin shall do its best to ensure such adherence.
The Code of Conduct has been approved by the Board of Directors of Sarachin. All deviations, if any, must be approved by the President and CEO.
Bribery and Facilitation Payments
Sarachin expressly prohibits any provision, offering or accepting of bribes of any variety to any person, whether private or public, either directly or through any third party.
Bribery occurs when you offer, pay, seek or accept an improper payment, gift or advantage to influence a business or governmental outcome or decision. Engaging in bribery, or turning a blind eye to your suspicions of bribery, can result in liability for Sarachin and for you personally. Bribes can be in the form of money, or anything else of value, such as a gift or donation, travel benefits, employment benefits, or any other advantage.
"Facilitation payments" are small unofficial payments aimed at expediting or securing the provision of products or services to which you or the company is legally entitled. A facilitation payment is illegal under several anti-bribery laws relevant for Sarachin, and is considered by Sarachin to be a type of bribe. It is strictly prohibited for anyone representing Sarachin to offer or make facilitation payments.
No employee or business partner will suffer adverse consequences for refusing to engage in improper payment activity, even if this results in loss of business.
Conflict of Interest
A conflict of interest occurs when your personal relationships, participation in external activities or interest in another venture can influence or could be perceived to influence your decisions when acting for Sarachin.
Export controls and economic sanctions laws impose restrictions over the sale, shipment, electronic transfer, provision, or disclosure of information, software, goods, assets, funds, and services across national borders or involving parties subject to economic sanctions.
Exports include transfer electronically, through discussions or visual inspections, and not only through traditional shipping methods. Sarachin complies with all export control laws. Further guidance is provided in the Country Risk standard under the Corporate Governance policy.
A number of countries are subject to very stringent economic sanctions. It is Sarachin's policy to refrain from conducting any business involving countries classified as restricted on the Sarachin country watch list. Sanctions laws also prohibit dealings with certain parties, who are specifically designated by governments for sanctions restrictions. Before engaging in business with any party, it is important to confirm that those parties are not subject to sanctions.
Antitrust law protects free enterprise and prohibits behavior that limits trade or that restricts fair competition.
These laws apply to every level of business. They combat illegal practices like price-fixing, market-sharing or bid-rigging conspiracies, or behaviors that aim to achieve or maintain monopoly. Sarachin is committed to fair and open competition, and does not tolerate violation of antitrust laws and competition laws and regulations.
Gifts and Hospitality
Sarachin does not allow gifts and hospitality where giving or accepting them could influence business decisions or enforcement of regulations, or cause others to perceive such influence.
As a company we do not expect gifts or hospitality from any of our business partners. Gifts and hospitality may be accepted or offered when this is expected as common business courtesies, however, only when aligned with the precautions and regulations described below.
Sarachin supports and respects internationally proclaimed human rights including the UN Declaration and Convention on human rights, and acknowledge all employees right to form and join trade unions of their own choice.
Sarachin employees shall expect a workplace free from harassment and discrimination. Sarachin will not use child or forced labor, and will not tolerate working conditions or treatment that is in conflict with international laws and practices.
Sarachin shall ensure that the company, through its operations, does not cause any infringement of human rights. The company shall address and minimize risks of human rights infringements in the supply chain, in the projects where we contribute as a supplier and all other parts of our operations. Please consult the country risk standard for further information.
It is a criminal offence to trade in Sarachin shares or other securities on the basis of insider information. Further guidance is provided in Sarachin's Insider information procedure under the Corporate Governance Policy.
You are involved in insider dealing when you trade in public traded shares or other securities while in possession of specific information capable of affecting the price of shares or securities and which is not publicly available or generally known in the market or when you disclose this information to someone else or influence someone else who then trades in those shares or other securities.
Money laundering occurs when the criminal origin or nature of money or assets is hidden in legitimate business dealings or when legitimate funds are used to support criminal activities.
Sarachin is committed to complying with all anti-money laundering and anti-terrorism laws. We will conduct business only with reputable customers and business partners involved in legitimate business activities, with funds derived from legitimate resources.
Sponsoring and Donations
Sarachin may utilize sponsorships to promote the company and its business. All sponsoring relationships shall be strategic and aligned with Sarachin's values.
There must be documented tangible benefits for Sarachin associated with any sponsorship, such as commercial gain, professional development, enhanced profiling etc. All sponsoring relationships shall be structured as 'win-win situations' whereby both parties achieve some gain. All sponsorship shall follow the regulations in the company authorization matrix.
No religious or political groups or organizations may be sponsored. There shall be no personal conflict of interest involved in the decision to sponsor an organization. In situations where a conflict of interest exists, the individual with a conflict shall withdraw from any associated decision-making process.
Charitable donations - gifts - to organizations do not carry the same requirement for mutual benefit. However, no charitable donations shall be made to political or religious organizations. All charitable donations must be approved in advance by Corporate Business Integrity and Compliance.
Declaration of Compliance
All employees, suppliers, subcontractors, representatives and other contracting parties of Sarachin shall act in accordance with our Code of Conduct.
You as an employee (including temporary personnel) and/or director in Sarachin will be requested on an annual basis to confirm by signing the Annual Statement of Compliance that you have read and familiarised yourself with this Code of Conduct, and that you for the previous year have conducted your tasks and responsibilities in accordance with the requirements set forth in this Code of Conduct.
Suppliers, subcontractors, representatives and other contracting parties of Sarachin are expected to have ethical standards that are compatible with this Code of Conduct, and shall also sign declarations confirming compliance with the requirements reflected in this Code of Conduct.
Reporting / Notification of Breach
If you are aware of or have suspicions concerning any unprofessional conduct, said conduct shall immediately be reported to your manager, HR department or another Sarachin manager you trust.
If you fail to obtain a reaction or response to your notification or if you would prefer not to notify any of those identified above, you are urged to notify to Corporate Legal or Corporate Business Integrity and Compliance or through the whistle blower channel. The whistle blower channel can be reached by sending an email email to: or by reporting anonymously through our external webpage.
Sarachin will ensure that there will be no retaliation against you, nor any impact on your professional career, for reporting possible violations in good faith. Any employee knowingly making a false report for the purposes of harming another individual will be subject to disciplinary action.