Corporate Policies

Effective Date: January 2, 2020

Operating in a socially responsible and sustainable manner is important to NCS SubSea (NCS), and to that end we are committed to understanding, monitoring and managing our social, environmental and economic impact in order to contribute to society’s wider goal of sustainable development. NCS SubSea is specifically committed to the 17 Sustainable Development Goals adopted by the UN General Assembly in September 2015 (summarized in the infographic below) and emphasizes a holistic approach to achieving sustainable development for all.

Corporate Social Responsibility (CSR)

NCS SubSea is committed to:

• Conducting business in an ethical and socially responsible manner;
• Protecting the environment and the safety of people;
• Supporting human rights; and
• Engaging, learning from, respecting and supporting the communities and cultures within which we work.

All NCS SubSea operations will ensure conformance to all applicable local, national and international sustainable development directives and our project planning addresses legal, ethical, commercial and social expectations to ensure fair decision making at all times. Specifically, all company operations will diligently strive to:

• Reduce our carbon footprint – NCS SubSea will invest in technologies, processes and equipment that strive to reduce our carbon footprint daily.
• Improve labor policies and embrace fair trade – All operations will strive to pay a fair wage for work performed for all personnel both nationally and internationally. At no time will child, slave or indentured labor be used, regardless of the local customs or laws. NCS SubSea and its companies will deal fairly and honestly with the highest levels of integrity with all stakeholders, at all times.
• Integrate environmental considerations with all corporate policies – We are the stewards of this earth, and as stewards, we will treat it with respect and honor. All corporate policies and operational documents will consider environmental impact and strive to reduce that impact at all levels.

Effective Date: January 1, 2020

NCS SubSea Inc (NCS) is committed to promoting environmental harmony and sustainability while advancing technologies that support safety and security and contribute to society.  Based on the principles outlined below, we shall conduct our business with integrity and transparency to broadly benefit societies around the globe.

Fundamental Philosophy: We prepare for the challenges of the future by embracing science, advancing safe, sustainable, and environmentally conscious technologies while maintaining the utmost integrity.

1. Challenge – Making the impossible possible

1.1. Rethink the possibilities

1.1.1. Anything is possible when we work together and persevere.

1.2. Cultivate new markets and new ideas

1.2.1. We pursue new markets, new technologies, and new methodologies
1.2.2. We contribute to sustainable development goals (SDGs) with business initiatives that aim to solve social problems.
1.2.3. We cultivate markets in which our technologies can provide continuing value to society.

1.3. Develop novel technologies

1.3.1. We respect diversity and originality. We discover value in cultivating and sharing new ideas.
1.3.2. We are open to any and all feedback, from all sources, including the market and customers

1.4. Forge innovations that transcend boundaries

1.4.1. We create value by collaborating, exchanging ideas, and engaging in co-creation

2. Evolution – Building beyond past successes

2.1. Look to the future, not the past

2.1.1. In an ever-changing business environment, we must learn to move beyond the past and look to the future. Our past achievements do not guarantee our future success. Relying on the past can impede our future. Always look for better ways of doing things, be open to new ideas, and evaluate the past with a critical mindset.
2.1.2. Every failure presents a learning opportunity – analyzing root causes of failures and building upon setbacks will pave the way for future successes.

2.2. Be committed to growing as a company

2.2.1. We are committed to growing as a company by continuing to invest in technological innovations, investing in our people, and keeping abreast of market expectations.

2.3. Actively utilize outside resources

2.3.1. We aim to maintain a broad perspective and actively utilize all available resources to grow and continuously create the best solutions and services for the customers and regions that we serve.
2.3.2. We keep abreast of market needs, elevate and communicate innovations, and aim to solve large-scale societal problems with innovative and sustainable solutions.

2.4. Adapt to change

2.4.1. We welcome and embrace change and adapt accordingly in order to stay strong, survive and thrive.
2.4.2. We are interested in innovations from all fields in addition to our own and we welcome the opportunity to interact with and learn from everyone in order to evolve and adapt as necessary.

3. Integrity – Sincere regard for stakeholders

3.1. Always keep stakeholders in mind

3.1.1. We engage in our work with fervor and integrity, be mindful of all stakeholders including customers, shareholders, trading partners, and the societies which we serve.
3.1.2. We strive to enhance the quality of results and always improve operations to exceed customer expectations.

3.2. Observe all laws and regulations

3.2.1. We act in accordance with laws, regulations, social norms, and all company rules to earn and keep the trust of all stakeholders.
3.2.2. We act with fairness and integrity, maintain the highest ethics in our work, and contribute to the creation of sustainable solutions.

3.3. Engage in thorough risk assessment and risk management

3.3.1. We regularly evaluate and assess risks to the Company, establish preventative measures, and verify the status of those efforts. We diligently protect and manage all Company intellectual property and information as well as that of our customers and trading partners.
3.3.2. In the event of emergencies such as large-scale natural disasters, we mobilize all available resources including the entire Company to support business continuity and also regional recovery and reconstruction.

3.4. Avoid any and all illegal activities and associations with any and all groups or individuals who seek to profit from illegal activities including violence, force, and fraud (“anti-social forces”)

3.4.1. We will have no dealings whatsoever with any groups or individuals that seek to profit from illegal activities such as violence, force, and fraud. Such groups include criminals, organized crime groups, and any and all other groups or individuals that have the potential for violence and/or illegal social unrest (“anti-social forces”).
3.4.2. We will work with and coordinate as necessary with any and all requisite agencies, including law enforcement authorities and legal counsel, to protect our Company and employees from antisocial forces and their potential harm and damages.
3.4.3. We will never engage in backroom deals or open ourselves to undue demands or influences by anti-social forces.
3.4.4. We will always ensure the safety and wellbeing of any employees who come under threat of anti-social forces.

4. Diversity – Respecting diverse values and contributing to society

4.1. Respect Human Rights

4.1.1. We respect and value the rights of individuals of all origins and diverse backgrounds. We value and applaud diversity and celebrate our differences. We pledge to never discriminate against anyone on the basis of race, gender, age, nationality, religion, disability, or any other protected class.
4.1.2. We pledge to create a workplace in which all individuals, of all backgrounds and ideologies, can support and nurture one another and thrive together.

4.2. Incorporate diverse values and ideas

4.2.1. We actively seek diverse opinions and challenge existing methods and solutions in search of better ones. Incorporate diverse values and ideas into all aspects of our work so that we can continually evolve in order to meet the challenge of a changing world.

4.3. Create a pleasant workplace

4.3.1. We prioritize health and human safety above all else and work to prevent accidents and injuries in the workplace and at the job site.
4.3.2. We work to create a pleasant workplace in which every employee respects one another, and everyone is fully cognizant of respecting and adhering to all applicable laws and regulations.
4.3.3. We support work-life synergy by optimizing work hours and encouraging strong physical and mental health for all employees.
4.3.4. We prohibit any and all forms of harassment in the workplace including harassment of any individual or group based on national origin, race, color, religion, age, gender, sex, sexual orientation, pregnancy, appearance, disability, sexual identity, marital status, or any other protected status.

4.4. Establish a rewarding workplace

4.4.1 We increase employee motivation and create a workplace that inspires a sense of achievement. We develop appropriate evaluation methodologies and ensure commensurate pay.

Effective Date: January 1, 2019

Introduction

NCS SubSea Inc (NCS) is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act (UKBA) and similar laws in other countries that prohibit improper payments to obtain a business advantage. This document describes NCS’s Policy prohibiting bribery and other improper payments in the conduct of NCS business operations and employee responsibilities for ensuring implementation of the Policy. Questions about the Policy or its applicability to particular circumstances should be directed to the Compliance Officer.

Policy Overview

NCS strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in the world, whether involving government officials or other commercial enterprises. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and NCS to possible criminal prosecution, reputational harm or other serious consequences. This Policy applies to everyone at NCS, including all officers, employees and agents or other intermediaries acting on NCS’s behalf. Each officer and employee of NCS has a personal responsibility and obligation to conduct NCS’s business activities ethically and in compliance with all applicable laws based on the countries wherein NCS does business. Failure to do so may result in disciplinary action, up to and including dismissal.

Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an undue business advantage. These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the conduct of NCS’s business.

NCS has developed a comprehensive program for implementing this Policy, through appropriate guidance, training, investigation and oversight. The Compliance Officer has overall responsibility for the program, supported by the executive leadership of NCS. The Compliance Officer is responsible for giving advice on the interpretation and application of this policy, supporting training and education, and responding to reported concerns. The prohibition on bribery and other improper payments applies to all business activities, but is particularly important when dealing with government officials. The U.S. Foreign Corrupt Practices Act and similar laws in other countries strictly prohibit improper payments to gain a business advantage and impose severe penalties for violations. The following summary is intended to provide personnel engaged in international activities a basic familiarity with applicable rules so that inadvertent violations can be avoided, and potential issues recognized in time to be properly addressed.

Common Questions About Anti-Bribery Laws

What do anti-bribery laws prohibit?

The FCPA, UKBA and other anti-bribery laws make it unlawful to bribe a foreign official to gain an “improper business advantage.” An improper business advantage may involve efforts to obtain or retain business, as in the awarding of a government contract, but also can involve regulatory actions such as licensing or approvals. Examples of prohibited regulatory bribery include paying a foreign official to ignore an applicable customs requirement. A violation can occur even if an improper payment is only offered or promised and not actually made, it is made but fails to achieve the desired result, or the result benefits someone other than the giver (for example, directing business to a third party). Also, it does not matter that the foreign official may have suggested or demanded the bribe, or that a company feels that it is already entitled to the government action.

Who is a “foreign official”? A “foreign official” can be essentially anyone who exercises governmental authority. This includes any officer or employee of a foreign government department or agency, whether in the executive, legislative or judicial branch of government, and whether at the national, state or local level. Officials and employees of government-owned or controlled enterprises also are covered, as are private citizens who act in an official governmental capacity. Foreign official status often will be apparent, but not always. In some instances, individuals may not consider themselves officials or be treated as such by their own governments but nevertheless exercise authority that would make them a “foreign official” for purposes of anti-bribery laws. Personnel engaged in international activities are responsible under this Policy for inquiring whether a proposed activity could involve a foreign official or an entity owned or controlled by a foreign government and should consult with the Compliance Officer when questions about status arise.

What types of payments are prohibited?

The FCPA prohibits offering, promising or giving “anything of value” to a foreign official to gain an improper business advantage. In addition to cash payments, “anything of value” may include:

• Gifts, entertainment or other business promotional activities;
• Covering or reimbursing an official’s expenses;
• Offers of employment or other benefits to a family member or friend of a foreign official;
• Political party and candidate contributions;
• Charitable contributions and sponsorships.

Other less obvious items provided to a foreign official can also violate anti-bribery laws. Examples include in-kind contributions, investment opportunities, stock options or positions in joint ventures, and favorable or steered subcontracts. The prohibition applies whether an item would benefit the official directly or another person, such as a family member, friend or business associate.

Under the law, NCS and individual officials or employees may be held liable for improper payments by an agent or other intermediary if there is actual knowledge or reason to know that a bribe will be paid. Willful ignorance – which includes not making reasonable inquiry when there are suspicious circumstances – is not a defense, and it also does not matter whether the intermediary is itself subject to anti-bribery laws. All employees, therefore, must be alert to potential “red flags” in transactions with third parties.

NCS and its affiliates must keep accurate books and records that reflect transactions and asset dispositions in reasonable detail, supported by a proper system of internal accounting controls. These requirements are implemented through NCS’s standard accounting rules and procedures, which all personnel are required to follow without exception. Special care must be exercised when transactions may involve payments to foreign officials. Off-the-books accounts should never be used. Facilitation or other payments to foreign officials should be promptly reported and properly recorded, with respect to purpose, amount and other relevant factors. Requests for false invoices or payment of expenses that are unusual, excessive or inadequately described must be rejected and promptly reported. Misleading, incomplete or false entries in NCS’s books and records are never acceptable.

NCS has established detailed standards and procedures for the selection, appointment and monitoring of agents, consultants and other third parties. These standards and procedures must be followed in all cases, with particular attention to “red flags” that may indicate possible legal or ethical violations. Due diligence ordinarily will include appropriate reference and background checks, written contract provisions that confirm a business partner’s responsibilities, and appropriate monitoring controls. Personnel working with agents and other third parties should pay particular attention to unusual or suspicious circumstances that may indicate possible legal or ethical concerns, commonly referred to as “red flags.” The presence of red flags in a relationship or transaction requires greater scrutiny and implementation of safeguards to prevent and detect improper conduct. Appointment of an agent or another third party ordinarily requires prior approval by an appropriate senior manager, description of the nature and scope of services provided in a written contract, and appropriate contractual safeguards against potential violations of law or NCS policy.

This Policy imposes on all personnel specific responsibilities and obligations that will be enforced through standard disciplinary measures and properly reflected in personnel evaluations. All officers, employees and agents are responsible for understanding and complying with the Policy, as it relates to their jobs. Every employee has an obligation to:

• Be familiar with applicable aspects of the Policy and communicate them to subordinates;
• Ask questions if the Policy or action required to take in a particular situation is unclear;
• Properly manage and monitor business activities conducted through third parties;
• Be alert to indications or evidence of possible wrongdoing; and
• Promptly report violations or suspected violations through appropriate channels.

Any employee who has reason to believe that a violation of this Policy has occurred, or may occur, must promptly report this information to his or her supervisor, the next level of supervision, or the Compliance Officer. Alternatively, information may be reported in confidence by calling the company hotline administered by Lighthouse Services Inc.

Retaliation in any form against an employee who has, in good faith, reported a violation or possible violation of this Policy is strictly prohibited. Employees who violate this Policy will be subject to disciplinary action, up to and including dismissal. Violations can also result in prosecution by law enforcement authorities and serious criminal and civil penalties. When seeking guidance and/or reporting concerns, please refer to our Whistleblower Policy for further details and additional resources.

Effective Date: January 2, 2020

Operating in a socially responsible and sustainable manner is important to NCS SubSea (NCS), and to that end we are committed to understanding, monitoring and managing our social, environmental and economic impact in order to contribute to society’s wider goal of sustainable development. NCS SubSea is specifically committed to the 17 Sustainable Development Goals adopted by the UN General Assembly in September 2015 (summarized in the infographic below) and emphasizes a holistic approach to achieving sustainable development for all.

Human Rights

NCS SubSea and its holdings will apply the protections provided in the Bill of Rights and the US Constitution to ALL NCS SubSea operations, regardless of location. Additionally, NCS SubSea recognizes the Universal Declaration of Human Rights (UN General Assembly resolution 217 A) to supplement areas not specifically addressed in US Law.

The following guidelines will be applied at all times, to all operations:

• Respect all people and treat them with dignity, without distinction of any kind, such as race, color, sex, language, religion, political or other opinion, national or social origin, property, birth or other status. Furthermore, no distinction shall be made based on the political, jurisdictional or international status of the country or territory to which a person belongs, whether it be independent, trust, non-self-governing or under any other limitation of sovereignty.
• Embrace individuality and all peoples’ right to freedom of choice and opinion.
• Endeavor to respect peoples’ differences, life experiences, skills and feedback; and place value on their input, at all times.

Effective Date: January 1, 2019

NCS SubSea, Inc (NCS) is committed to protecting your privacy. We want you to be familiar with and understand how we collect, use and disclosure your Personal Information. This Privacy Policy describes how we collect and process your Personal Information. This Privacy Policy relates to the NCS SubSea corporate websites (the “Site”), which includes: www.ncs-subsea.com and www.pcable.com.

These websites are operated by NCS SubSea from its facilities in the United States.

If you are a California resident, this Privacy Policy also informs you about the management of your Personal Information and your rights in accordance with the California Consumer Privacy Act of 2018.

What Personal Information do we collect about you?

“Personal Information” is information that identifies a particular consumer or device, or is information that is capable of being associated with or could reasonably be linked to a particular consumer or device.

When you contact us via the Site or download product manuals and software, we may collect from you, either directly from the information you provide us or through the use of cookies, the following categories of information:

• Identifiers such as your name, your email address, your postal address, your telephone number, your IP address, device identifier, or other similar identifiers.
• Personal Information described in Cal. Civ. Code § 1798.80(e), such as name, address, telephone number, credit card number, debit card number, employer, and other personal information. Some personal information in this category may overlap with other categories.
• Commercial Information, including products or services that you have purchased or considered.
• Internet of other similar network activity, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, applications, or advertisements.
• General geolocation data.

We do not collect Personal Information about you from any third-party sources.

Do not track

The Site does not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to the Site, and we do not alter any of our data collection and use practices upon receipt of such a signal.

How do we use your Personal Information?

We may use your Personal Information for the following business purposes:

Communications with You

• To reply to inquiries or comments that you send us;
• To contact you with information regarding services, newsletters, marketing or promotional materials and other information that may be of interest to you;
• To provide you with information about the services we provide.

Note that you may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

To Manage and Improve Our Business Operations

• To serve the functions of the Site and improve its performance;
• To manage everyday business needs, such as administering and improving the Site;
• To analyze how you use the Site;

To Ensure a Secure Online Environment and Comply with Legal Obligations

• Protect against and detect fraud, abuse, or other unlawful activity;
• Enforce our corporate policies and industry standards; and
• Comply with all applicable laws and reporting obligations.

Who do we transfer your Personal Information to?

We share information within the NCS SubSea company, including future affiliate/subsidiaries.

We employ third-party service providers to assist us in analyzing how our Site is used. We engage these service providers to assist us with the maintenance of the Site, and management of the storage of data necessary for the operation of the Site. The information used for this purpose cannot be used to identify individual uses of the Site, and therefore does not constitute Personal Information.

We do not sell, trade, or otherwise transfer your Personal Information to other outside parties for marketing or other commercial purposes.

We may also disclose your Personal Information:

• If we are required to do so by law or legal process including laws outside of your country of residence;
• To law enforcement authorities or other government officials, as necessary, including outside of your country of residence;
• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or suspected or actual illegal activity;
• If necessary to protect the vital interests of a person;
• To protect our property, services, and legal rights;
• To prevent fraud against us, our affiliates, business partners, or related third parties;
• To support auditing, compliance, and corporate governance functions; or
• To comply with any and all applicable laws.

Business structure changes

We reserve the right to disclose and transfer all information related to the Site, including Personal Information:

• To a subsequent owner, co-owner, or operator of the Site; or
• In connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

Personal Information Disclosed within the Past 12 Months

Consistent with our policy of never selling your Personal Information, we have not sold any Personal Information in the preceding 12 months.

To promote the business purposes described above, we have disclosed the following categories of Personal Information to our service providers in the previous 12 months: personal identifiers, commercial information, internet or other electronic network activity, and general geolocation data.

How long do we retain your Personal Information?

Personal Information that we collect from you through your use of the Site will be kept for one year after the purpose of which we collected the data has been fulfilled. For example, if you contact us with a question about our services, we will retain your Personal Information for one year following the completion of the correspondence.

Cookies

This section explains how and why cookies, web beacons, pixels, clear gifs, and other similar technologies (which we will refer to as “cookies” in this Policy) may be stored on and accessed from your device.

What are cookies?

A cookie is a small text file that can be stored on and accessed from your device when you visit the Site to the extent you agree. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use the Site. This allows the Site to recognize your device from those of other users of the Site. The information provided below about cookies also applies to these other tracking technologies. You can find more information at www.allaboutcookies.org.

How does the Site use cookies?

We use “first-party cookies,” which are cookies that belong to NCS and that NCS places on your device. NCS uses cookies to identify you and your interests, to remember your preferences, and to track your use of the Site. We also use cookies to control access to certain content on the Site, protect the Site, and to process any requests that you make of us.

Third-party service providers use cookies to analyze how the Site is used and how it is performing. We do not use any third-party cookies, which would be placed on your device by other parties through the use of our Site.

Notice to California Residents: Your Privacy Rights

As a resident of California, you have certain rights over the Personal Information that we collect and disclose to third parties. These are summarized below.

Right of Access. You have the right to request that we disclose to you the Personal Information that we may have collected about you or disclosed to third parties in the previous 12 months. Such information will be provided to you in a portable and readily usable format. To help protect your privacy and security, we will take reasonable steps to verify your identity.

Deletion Request Rights. You have the right to request that we erase Personal Information that we hold about you, subject to certain conditions.

Right to Non-Discrimination. We will not discriminate against you for exercising your privacy rights.

Exercising Your California Privacy Rights. If you would like to submit an access request, please contact us at 281.491.3123 or www.ncs-subsea.com. You may make a request for access twice within a 12-month period. To help protect your privacy and security, we will take reasonable steps to verify your identity. Any personal information provided to us for verification purposes will only be used for that purpose.

How we protect Personal Information

We maintain administrative, technical, and physical safeguards to protect against the loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide when visiting or using the Site.

Please note that the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the safety of your personal information transmitted via the internet and any such transmission is at your own risk.

Caching

This Site uses page caching and browser caching in order to facilitate a faster response time and better user experience. Caching potentially stores a duplicate copy of every web page that is on display on this Site. All cache files are temporary and are never accessed by any third party, except as necessary to obtain technical support from the cache plugin vendor. Cache files expire on a schedule set by the Site administrator, but may easily be purged by the admin before their natural expiration, if necessary.

Children’s Privacy

Our website does not address anyone under the age of 16 (“Children”).

We do not knowingly collect Personal Information from Children. If you are a parent or guardian and you are aware that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children, we take steps to remove that information from our servers.

Privacy Policy

This online Privacy Policy applies to information collected through our website and not information collected offline. By using our Site, you consent to our Privacy policy. Please read these documents carefully.

We reserve the right to change these policies at any time. If we make material changes to this Privacy Policy that increases our rights to use Personal Information we have previously collected about you, we will first obtain your consent where required by law. If we intend to further process collected personal information for a purpose other than that for which the personal information was collected, prior to that further processing, we shall provide you with information on that other purpose and with additional information necessary to ensure fair and transparent processing.

Please contact us at info@ncs-subsea.com if you have any questions about the above information.

QHSSE Policy Statement

QUALITY

Our aim is to meet or exceed customer expectations and applicable requirements. We commit to providing the highest standards of technology and service to ensure customer satisfaction.

We will:

• Monitor and measure key performance of quality objectives
• Embrace a first-time right approach to eliminate re-work and wasted effort
• Employ structured project planning and execution methodologies to consistently deliver high quality services
• Foster a quality mind-set that promotes continuous improvement of all our business processes
• Solicit and act upon customer feedback to foster continuous improvement of our technology and services

HEALTH AND SAFETY

Our aim is zero injury to people. We commit to preventing injuries and illness and to provide safe and healthy working conditions for all.

We will:

• Act responsibly and be accountable for our actions
• Promote safe behavior and empower our colleagues to lead by example
• Stop any unsafe work and welcome intervention
• Prohibit the possession and consumption of illegal substances and alcohol at worksites
• Promote good health and well-being for all employees

SECURITY

Our aim is zero harm to our personnel and assets because of criminal or terrorist activity. We commit to proactively monitoring and mitigating security risks.

We will:

• Continually monitor global security risks
• Assess and mitigate security risks for all operations
• Never operate unless the security risk has been mitigated to an acceptable level
• Promote security awareness among all employees
• Be prepared to manage emergency response and crisis situations professionally and responsibly

ENVIRONMENT AND CLIMATE

Our aim is zero spills and marine pollution in our offshore operations, with minimum harm to the environment. We commit to protecting the environment and preventing pollution.

We will:

• Plan and conduct our work to minimize the impact of our activities on marine life, marine habitats, and the environment
• Ensure the responsible use of energy and minimize the emission of CO2 and other greenhouse gases to help limit climate change
• Minimize waste and ensure safe handling and responsible disposal of all waste products
• Encourage the implementation of technologies that minimize our environmental impact

For all aspects of our QHSSE management system we will work in accordance with the principles of the ISO 9001 and ISO 45001 standards and commit to eliminating hazards whenever possible and reducing QHSSE risks. We will comply with all applicable legal and regulatory requirements and will continuously improve our management system and performance based on feedback from our customers, employees, vendors, and other stakeholders. We are committed to stopping any unsafe or non-compliant work and welcome intervention to prevent harm and to minimize risks for everyone involved in our operation

Larry Scott, President and CEO

Effective Date: January 1, 2019

NCS SubSea Inc (NCS) is committed to the highest possible standards of ethical, moral and legal business conduct. In conjunction with this commitment and NCS’s commitment to open communication, this policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith. However, if an employee feels that their anonymity is not required then a written complaint may be emailed or filed by that employee with the Compliance Officer, directly to OYO, USA or by using the Hotline, which is accessible via telephone or fax or online.

The Whistleblowing Policy is intended to cover serious concerns that could have a large impact on NCS such as actions that:

• Are unlawful
• May lead to incorrect financial reporting
• Otherwise amount to serious improper conduct
• Are not in line with company policy, including the Employee Code of Conduct

Regular business matters that do not require anonymity should be directed to the employee’s supervisor and are not addressed by this policy.

Lighthouse Hotline

Toll–Free Telephone:

• English-speaking US and Canada: 844.600.0064
• Spanish-speaking US and Canada: 800.216.1288
• French-speaking Canada: 855.725.0002
• Spanish-speaking Mexico: 01.800.681.5340

AT&T USA Direct:

• All other countries: 800.603.2869 (Must first dial country access Click here for access codes and instructions.)

Additional Resources:

• Website: lighthouse-services.com/ncs-subsea
• Email: reports@lighthouse-services.com (Must include NCS SubSea name with the report.)
• Fax: 215.689.3885 (Must include NCS SubSea name with the report.)