Commercial in Confidence
Supplier Code of Conduct
Purpose
XOCEAN is committed to delivering safe, sustainable, and responsible offshore data solutions. We expect our suppliers, subcontractors, vessel operators, equipment providers, and service partners (“Suppliers”) to operate in alignment with our values and standards.
This Supplier Code of Conduct outlines the minimum requirements that all Suppliers must meet when conducting business with or on behalf of XOCEAN.
On this page
Legal & Regulatory Compliance
Suppliers must:- Comply with all applicable international, national, and local laws and regulations.
- Adhere to maritime, offshore, and port authority regulations.
- Maintain all required licenses, certifications, insurances, and vessel registrations.
- Comply with international maritime conventions where applicable (e.g., SOLAS, MARPOL, STCW, MLC).
- Comply with all applicable international trade sanctions, export control laws, and customs regulations, including those imposed by the United Nations, European Union, United Kingdom, United States, and other relevant jurisdictions.
- Suppliers must comply with all applicable laws relating to anti-bribery and corruption, modern slavery, human trafficking, and data protection, including (where applicable) the UK Bribery Act, Modern Slavery legislation, and the General Data Protection Regulation (GDPR).
- Not engage in business with sanctioned or embargoed individuals, entities, vessels, or jurisdictions where such engagement would violate applicable sanctions laws.
- Maintain appropriate internal controls to ensure compliance with sanctions and export control requirements, including screening of counterparties and vessels where relevant.
- Suppliers must maintain appropriate insurance coverage commensurate with the nature and risk of the services provided, including (where applicable) employer’s liability, public liability, and marine insurance such as Protection & Indemnity (P&I). Evidence of insurance must be provided upon request.
Suppliers must immediately notify XOCEAN of any regulatory breaches, investigations, sanctions issues, export control violations, or enforcement actions that may impact services.
Health, Safety & Environment (HSE)
Suppliers must:- Demonstrate leadership commitment to Health, Safety, Environmental Protection and Sustainability .
- Maintain an effective Health and Safety and Environmental Management System appropriate to the scope of work.
- Report all HSE observations, incidents, near-misses, and hazards immediately.
- Carry out investigations and report findings to XOCEAN promptly following a HS or E incident.
- Promote a “Stop Work Authority” culture without retaliation.
Health & Safety Management
Suppliers must:- Prepare Risk Assessments and Method Statements in advance of all works and provide these for review to their point of contact in XOCEAN.
- Carry out pre-work planning / toolbox talks before all operations and engage, where relevant, when these are facilitated directly by XOCEAN personnel.
- Provide safe working conditions and ensure there are appropriate welfare facilities in all workplaces (including marine vessels).
- Ensure PPE is provided and is appropriate to the scope of work.
- Manage occupational health risks
- Provide key information in relation to Health and Safety on request
Marine Safety Management
Suppliers must:- Ensure marine vessels are seaworthy, properly maintained, and certified.
- Ensure masters and crew are competent, certified, and medically fit.
- Monitor fatigue and working hours in accordance with maritime standards
- Maintain emergency response procedures (e.g. fire, man overboard, collision, pollution, abandonment).
- Conduct regular drills and safety briefings.
- Maintain safe navigation practices and collision avoidance systems.
Environmental Management
Suppliers must:- Take measures to prevent pollution (oil, fuel, chemicals, plastics, waste) and have spill response plans in place.
- Manage waste responsibly in line with the waste management hierarchy.
- Avoid harm to marine ecosystems and protected species.
- Manage and where reasonably practicable, reduce emissions (including greenhouse gas emissions) associated with services provided to XOCEAN
- Maintain records of environmental and emissions-related data (including fuel consumption and carbon emissions) in a verifiable and auditable format and provide such information upon request.
Corporate Social Responsibility (CSR)
Human Rights & Labour Standards
Suppliers must respect internationally recognized human rights, including:
- Prohibiting all forms of forced, bonded, or involuntary labour
- Prohibiting child labour.
- Freedom of association and collective bargaining (where legally permitted).
- Providing fair wages in compliance with local laws and maritime labour conventions.
- Ensuring equal opportunity and non-discrimination in employment
- Maintaining a workplace free from harassment, abuse, and intimidation
Suppliers must comply with the Maritime Labour Convention (MLC) where applicable.
Ethical Business Practices
Suppliers must:- Operate with integrity and transparency.
- Prohibit bribery, corruption, facilitation payments, and kickbacks.
- Comply with applicable anti-corruption and anti-money laundering laws.
- Avoid conflicts of interest and disclose any potential conflicts to XOCEAN.
Maintain accurate financial and operational records.
Whistleblowing & Non-retaliation
Suppliers must:- Establish or maintain a confidential reporting mechanism that allows employees, contractors, and crew to raise concerns regarding misconduct, legal violations, unsafe practices, human rights concerns, or breaches of this Code without fear of retaliation.
- Prohibit retaliation, harassment, or adverse treatment against any individual who raises a concern in good faith.
- Ensure that concerns relating to XOCEAN work may be escalated directly to XOCEAN through XOCEAN’s designated reporting channels where appropriate.
- Promptly investigate reported concerns and take appropriate corrective action.
Responsible Supply Chain
Suppliers must:- Ensure their subcontractors comply with this Code.
- Conduct due diligence on high-risk subcontractors.
- Promote responsible sourcing of materials and services.
- Avoid sourcing from sanctioned or embargoed entities.
- Flow down applicable sanctions, export control, climate reporting, data security, and whistleblowing requirements to relevant subcontractors.
Community & Social Impact
Suppliers operating in coastal or port communities must:
- Respect local communities and maritime users (fisheries, shipping lanes, offshore installations).
- Minimize operational disruption.
- Engage respectfully with local stakeholders.
- Support local employment and economic participation where possible.
Data Security & Confidentiality
Suppliers must:- Protect XOCEAN’s confidential information and intellectual property.
- Implement appropriate cybersecurity controls for offshore and remote systems.
- Comply with applicable data protection regulations.
- Immediately report data breaches or cybersecurity incidents.
In addition, Suppliers must implement and maintain proportionate technical and organisational cybersecurity measures, including at a minimum:
- Access controls based on least privilege principles and role-based access management.
- Strong authentication mechanisms (including multi-factor authentication where feasible) for remote or cloud-based system access.
- Encryption of sensitive data in transit and at rest using industry-recognized standards.
- Secure remote connectivity controls for offshore systems, vessels, and field equipment.
- Regular patching and vulnerability management processes.
- Incident detection and response procedures.
Where proportionate to the nature and risk of the services provided, Suppliers should align their cybersecurity practices with recognised industry standards or frameworks (such as ISO 27001 or the NIST Cybersecurity Framework).
Suppliers must notify XOCEAN without undue delay, and in any event within 24 hours, of any actual or suspected cybersecurity incident or data breach that may impact XOCEAN systems, data, operations, or clients.
Quality & Operational Excellence
Suppliers must:- Ensure they have in place a Quality Management System appropriate to the scope of work.
- Deliver services in accordance with agreed specifications and contractual requirements.
- Maintain quality control procedures.
- Ensure equipment is calibrated, certified, and fit for purpose.
- Suppliers must cooperate with XOCEAN in any audits, assessments, or investigations and implement corrective actions where non-compliance is identified.
- Maintain accurate and complete records relating to HSE performance, environmental data (including emissions), quality, and cybersecurity in a verifiable and auditable format, and make such records available to XOCEAN upon reasonable request.
Continuous Improvement
XOCEAN encourages suppliers to:
- Set measurable Health, Safety and Environmental performance objectives, including emissions reduction targets where appropriate.
- Invest in cleaner technologies and fuel efficiency.
- Enhance safety culture and training.
- Track and report HSE performance metrics.
Compliance
XOCEAN reserves the right to:
- Request documentation demonstrating compliance.
- Conduct supplier assessments or audits (with reasonable notice).
- Suspend or terminate relationships for material breaches.