During the year, the Company reviewed and updated key ethics and compliance policies to ensure continued relevance and alignment with regulatory requirements and organizational values.
This included formal approval, by the Board, for a new Whistleblowing Policy - to provide secure, confidential channels for reporting concerns without fear of retaliation.
Continuous refinements to the Code of Conduct and related policies cover issues such as conflicts of interest, anti-corruption, and responsible business practices.
To support effective implementation, we strengthened internal mechanisms, including clearer reporting lines, defined responsibilities for ethics oversight, and improved procedures for reporting, investigating, and resolving ethical concerns. These mechanisms were designed to ensure confidentiality, fairness, and protection against retaliation, thereby encouraging employees and stakeholders to raise concerns without fear.
We also continued to invest in ongoing ethics and compliance training during the reporting year to raise awareness and reinforce expected standards of behavior. Employees will receive targeted training sessions covering the Code of Conduct, ethical decision-making, and compliance obligations relevant to their roles, once the policy is approved by the Board of Directors.
Code of Business Conduct
SEDCO’s Code of Business Conduct is the cornerstone of ethical culture within the organization and its ecosystem. It guides employees at all levels in their daily operations, mandating adherence to relevant laws and policies, promoting ethical best business practices, and strictly prohibiting corruption and similar misconduct.
The Code addresses critical areas such as conflicts of interest, integrity, insider trading, gifts and entertainment, and anti-money laundering. It provides clear guidance on navigating ethical issues and offers confidential reporting channels for addressing unethical conduct internally. Applicable across all SEDCO activities, the Code extends to our suppliers, contractors, and consultants.
In 2025, the Company routinely reviewed and updated the Code of Conduct. As part of this ongoing review process, an Anti-Corruption Policy is expected to be incorporated into the Code of Conduct.
Implementation and oversight of the Code are a collaborative effort involving SEDCO’s Legal Department, Corporate Communication and Sustainability Department, and the Human Resources Department, which manages staff training and communication. The Code is readily accessible to all employees, outlining their rights and providing clear procedures for raising concerns, including anonymous reporting via a dedicated email channel.