Norwegian transparency act

Ocean Yield AS (“Ocean Yield” or the “Company”) is fully committed to respecting fundamental human rights and human rights due diligence in its business operations and value chain. The Company recognises its obligations to human rights both related to international conventions, principles, and guidelines as well as national law, such as the Norwegian Transparency Act.

This report has been developed to comply with the legal requirements as stated in the Norwegian Transparency Act of July 2022. Ocean Yield AS is a Norwegian limited company and a shipowner that has investments in vessels on long-term charters. The Company focuses on modern vessels and currently has investments in car carriers, chemical tankers, product tankers, crude tankers, container vessels, dry bulk vessels, oil-service vessels, and gas carriers.

Ocean Yield has offices in Bærum, Norway, and in Malta and as of year-end 2022, the Company had 15 employees. The operations of the Group’s bareboat fleet are managed from Malta and the vessel owning companies are primarily owned and controlled by Ocean Yield Malta Limited.

The Company’s business strategy is to enter into long-term charters, which gives visibility with respect to future earnings of the Company. The main focus has primarily been on bareboat charters, which means that Ocean Yield has no operational control of most of its vessels. The duration of the bareboat charters is from ten to fifteen years and the vessels are chartered to reputable clients around the world. However, the Company may also enter into time-charter contracts with shorter duration. The Company’s ambition is to continue to grow and further diversify the portfolio of vessels on long-term charters.

Policies and governance
Ocean Yield supports and respects the protection of internationally proclaimed human rights as set out in the fundamental principles of the Universal Declaration of Human Rights and the core international human rights treaties. Ocean Yield strives to avoid causing or contributing to adverse human rights impacts through our business activities and address such impacts if and when they occur. Key policies and governance principles are adopted by Executive Management and the Board.

Ocean Yield also supports and respects internationally recognized labour rights as set out in the fundamental International Labour Organization (ILO) conventions, including the freedom of association and the right to Collective Bargaining Agreements within national laws and regulations, and we support i) the elimination of all forms of forced and compulsory labour; ii) the effective abolition of child labour; iii) the elimination of discrimination in respect of employment and occupation.

Ocean Yield ‘s Code of Conduct outlines the Company’s commitment to ethical and compliant business practices, including human rights, and it is valid for all employees and the Board of Directors. It gives us the framework for upholding Ocean Yield’s core values in our daily work. The Code of Conduct is available on the Company’s website.

One of Ocean Yield’s goals is to develop relationships with business partners that share similar corporate values as the Company and conduct their business in an ethical and compliant manner. The Company has established and is in the process of communicating its Supplier Code of Conduct for Ocean Yield’s business partners which outlines the obligations, and the integrity standards Ocean Yield expects its business partners to uphold. It includes requirements related to the most salient human rights issues in this context: child and forced labour, discrimination, safe and healthy work environment, freedom of association and collective bargaining, equal pay and working hours, and indigenous peoples. The Supplier Code of Conduct for Ocean Yield’s business partners is available on the Company’s website.

Risk assessment
The Company has conducted a human rights risk analysis of its business operations and value chain, to map and understand human rights risks and to identify potential actions required.

The overall human rights risk analysis of the Company’s business operations and value chain were conducted in accordance with the steps of the UN Guiding Principles for Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises and national laws, such as the Norwegian Transparency Act. The purpose of the analysis was to map and better understand the human rights risks we are facing, and to determine the need for further follow-up measures in addition to general measures already implemented, such as revising our Code of Conduct and further strengthening our focus on human rights in our risk assessments and business partner screenings. The analysis enabled us to distinguish two prioritized human rights risk areas going forward, which are:

  • With regards to the vessels: Construction, maintenance, and recycling
    These are labour-intensive activities that may concern a series of human and labour rights issues, both when it comes to risks of accidents and injuries and when it comes to risks of worker exploitation.
  • With regards to the operations: Crew
    There are several human and labour rights risks related to seafaring. The working environment on a ship, with extended periods offshore, can create limited oversight and weak law enforcement. This increases the risks of worker exploitation, for example by excessive working hours or poor wage levels.

In general, Ocean Yield considers that the Company’s risk of violating such human rights is limited. The operational control and responsibility of our vessels and related operations is held by third parties that lease the vessels on predominantly long-term bareboat charterparties. In the client selection processes, Ocean Yield puts significant emphasis on partnering with reputable international shipping companies committed to ESG policies and consequently human rights.

For a very limited number of vessels, Ocean Yield does however have operational responsibility both of vessel and crew. For these few vessels, the management and supervision of the vessels are outsourced to third parties. To address risks related to human rights, Ocean Yield focuses on collaborating with reputable ship managers carefully selected through thorough due diligence and assessment. Their supplier code of conducts and active oversight should contribute to mitigate human rights risks. Going forward, the Company’s main focus on human rights issues will be to monitor and collaborate with relevant parties related to the construction and operations of these vessels.

Other significant suppliers of Ocean Yield are leading international banks, law and audit firms. Based on our human rights risk analysis, we consider the associated risk related to these counterparties to be low.

In summary, we strive to ensure that our business partners and suppliers share our human rights commitment and standards.

Ocean Yield has established a whistleblower channel where employees, business partners and other stakeholders can raise concerns about improper activities or misconduct and report instances of potential non-compliance with our values without fear of retaliation. Such improper activities or misconduct may include HSE violations, harassment, insider trading, money laundering, fraud, bribery and kickback arrangements, or other breaches of Ocean Yield’s Code of Conduct

Under our whistleblower procedure, complaints can be reported directly to our Board of Directors, or through our whistleblower hotline available on the company website. Reports received through the integrity channel are initially received and handled by an independent third party; PwC Law. PwC is dedicated to maintaining high ethical standards and handles all submissions confidentially.