Guidance on Social Responsibility

International Standard ISO 26000 – October 2018 –

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Table of contents

Introduction 2

Self-declaration 5

1. Subscribing to and applying the seven principles of social responsibility 5

2. Identifying and engaging stakeholders 8

3. Addressing the seven social responsibility core subjects and 37 social responsibility issues 9

4. Integration of social responsibility throughout the organization 11

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Introduction

Globalization and stakeholders’ demands have resulted in the increased importance of sustainability in the

logistics industry. The dimensions of sustainability are three-fold, consisting of environment, economy and

society (planet, profit, people) – the triple bottom line. We see that organizations in fast moving consumer

goods or energy sectors already experience pressure from the end of the supply chain, mostly from end-

consumers. Naturally in our business we are not directly connected to these end-users, but are part of the

chain between producers and their final consumers. It is just a matter of time before those demands move

further upstream to the beginning of the supply chain.

An analysis has been carried out at Steinweg Rotterdam with the goal to create a central overview of all the

CSR activities while using the “ISO 26000 standard: A guidance on social responsibility”. The ISO 26000

standard consists of answering 40 questions on the subject of social responsibility and sustainability.

Methods of analysis include interviews and the study of available company information and documentation.

Firstly, Steinweg’s position on the seven principles of social responsibility were evaluated and a stakeholder

analysis was performed. Thereafter, a relevance-significance-priority matrix was executed based on the 37

CSR-issues identified by ISO 26000 standard. We have limited the scope to C. Steinweg Handelsveem B.V. in

the Netherlands, excluding subsidiaries.

To discuss sustainability matters, please contact us through our office in Rotterdam.

C. Steinweg – Handelsveem B.V.

Parmentierplein 1

3088 GN Rotterdam

The Netherlands

Tel: +31-10-4879555

Fax: +31-10-4879278

E-mail: rotterdam@nl.steinweg.com

Website: www.steinweg.com

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C. Steinweg – Handelsveem B.V.

C. Steinweg is a well-known logistics service provider in the field of warehousing, forwarding, stevedoring,

and chartering in various locations in Europe, Asia, Africa and the America's. Rotterdam is the head-office of

the C. Steinweg organization ever since the company was founded in December 1847 as a shipping agent.

Handelsveem B.V. was created in 1895 by Constantin Steinweg, which resulted in C. Steinweg - Handelsveem

B.V. and has always remained a privately owned company.

When looking at the recent history of the C. Steinweg Group, we have developed in three dimensions:

- Geographically: from Rotterdam towards a global organization

- Commodities handled: from metals and softs towards a wider set of commodities including

chemicals, ferro-alloys, general cargo and project cargo

- Services provided: from warehousing, forwarding and stevedoring towards added value

services such as crushing, screening, packing, blending and so on

Our equipment is modern, environmentally friendly and maintained according to high standards, meeting

high safety levels and approved by international certification organizations. In the port of Rotterdam

Steinweg operates ocean terminals and warehouses at multiple locations with more than 2,000,000 m2 of

available space.

Warehousing

The core business of Steinweg is warehousing. Our Rotterdam warehouses are approved for the storage of

commodities traded on the London Metal Exchange (LME) and Intercontinental Exchange (ICE/NYBOT) and

by the Minor Metals Trade Association (MMTA), whereas other warehouses are specifically suited for

storage of specific commodities in temperature and/or humidity controlled spaces or high security vaults. All

the warehouses are in very good condition and up to the high standards of the above mentioned

institutions.

Stevedoring

Like elsewhere in the world, we are active in loading and unloading of liner vessels and / or charter vessels.

Apart from our normal commodities this also includes bulk minerals, granite, wood and project cargo. We

load and unload multi-purpose, breakbulk and bulk deep sea vessels and barges with experienced gangs in

the most efficient and professional way. Our stevedoring operations are available 24 hours 7 days a week.

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Other logistic services

In conjunction with our warehousing and stevedoring activities we also offer other services such as

Chartering, Forwarding, Ocean Freight booking, Shipping Agency & Customs Clearance. All of these services

are coordinated by our skilled staff in close contact with the physical handling of the products, which gives

our customers the one-stop-shop high-quality service value that they are looking for.

Value Added services

In order to facilitate our customer’s requirement we also offer a variety of value added services that are

closely linked to the logistics process. The services are among others: Blanching, Blending, Cleaning,

Crushing, Cutting, Packing and Screening.

Global Headquarters

Rotterdam is the head office of the C. Steinweg Group, which spans all over the globe with warehousing

activities in more than 100 locations in Europe, Asia, Africa, the Middle East and the America’s.

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Self-declaration

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1. Subscribing to and applying the seven principles of social responsibility Accountability

Steinweg is accountable for its impact on people, planet and profit. The company puts a large extent of its

accountability efforts in its contact and communications towards stakeholders. Furthermore, Steinweg

accounts for its actions and impacts through our annual report and via the corporate website.

Transparency

Steinweg is open about the goal, nature, and locations of its own activities on its corporate website and

through its communications to stakeholders. At the same time confidentiality about our customers’ business

is one of our most valued assets within the market. Sharing such information could have an influence on

market prices. Relevant stakeholders and authorities, however are informed in stakeholder meetings and

dialogues.

Ethical behavior

To promote conformity with ethical behavior, we have set up non-disclosure agreements (NDAs) and general

terms and conditions; these are widely accepted throughout the market. Existing roles are structured in such

a way to ensure appropriate separation of functions, and are currently being formalized by means of our

control manual. Additionally, all our principles are clearly stated in the code of conduct, easily accessible for

all employees via the corporate intranet. Issues covered by the code of conduct include standards of

behavior, complying with the law, our public role, the environment, commercial integrity, and more.

Steinweg strongly relies on its reputation which has been built over the last 170 years. Due to this history,

integrity is considered one of our most valued assets and is mutually shared among employees.

Respect for stakeholder interests

Steinweg respects the interests of their stakeholders and responds to meet their concerns. Customers are

served by dedicated teams and each employee has the responsibility for a range of tasks from beginning to

end which requires a broad educational background for each staff member as well as familiarity with a

diversity of stakeholders. Steinweg carries a reliable and respectable name throughout the world of logistics.

We have good mutual understandings with regulators, authorities, customers and suppliers.

Respect for the rule of law

Steinweg must be compliant to all (inter)national regulatory standards. As all laws and regulations together

embody our “license to operate”, our group compliance and audit team based in the headoffice make sure

that we comply with standards.

Operation wise, Steinweg is an Authorized Economic Operator (AEO) which is a status that is granted by EU

Member States to economic operators established in the EU that meet the following common criteria

stipulated in customs law:

- An appropriate record of compliance with customs requirements

- A satisfactory system of managing commercial and, where appropriate, transport records, which

allows appropriate customs controls

- Proven financial solvency

- Where applicable, appropriate security and safety standards

Also, because we are AEO-certified and we have a history of being a trustworthy partner to the government,

we entered the so called ‘Horizontal Monitoring’ covenant, which gives us the space to perform many VAT-

related issues ourselves.

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Our warehouses are approved and recognized as delivery points by the most important and leading

exchanges and associations dealing with industrial and agricultural commodities like the LME, LIFFE and the

MMTA (in the UK), ICE/NYBOT, CME and the CMAA (in the USA), the SMX (in Singapore) and the DMCC and

DTTC (in the UAE).

For hazardous and non-hazardous chemicals we follow the Commodity Markets Rules and the legislation

related to handling, storage and transportation such as IMO, ADR/RID and ICAO. For food and food-related

products we operate warehouses that are HACCP and AIB approved. We are also accredited for Skal

Biocontrol which is dedicated to proving the reliability of organic products in the Netherlands, assigned to do

so by the Ministry of Economic Affairs in the Netherlands. This also includes approved warehouses as part of

a secured supply chain traceability of organic products.

For most previously named accreditations and certificates we actually over-comply to the standard because

we aim to work in the safest way and with the highest quality level as required by our customers.

Respect for international norms of behavior

Steinweg respects the international norms of behavior. We reconsider our relations and activities in case

these would be in conflict with our own standards and international norms. In case our operational activities

require this, we are looking for solutions with local authorities. However, in each specific case, Steinweg

reviews whether we strictly want to comply with a certain law or regulation or that we would like to take an

additional step according to our company philosophy. This is usually the case in situations where safety (for

our people or other stakeholders) is one of the primary concerns or where national regulation is not meeting

our standards sufficiently. In such cases we do not only comply with the rules that are obliged, but we will

take it a couple of steps further.

Respect for human rights

Steinweg has issued a code of conduct which contains the rights mentioned in the universal declaration of

human rights and also complies with international norms of behavior. The code of conduct is valid for the

worldwide organization of Steinweg.

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2. Identifying and engaging stakeholders

Identification

Stakeholders are currently identified on case-by-case basis per job functionality. Therefore, the information

is known within the organization per division manager and subsequent account holders. Many of our

stakeholders have a record in our global CRM system. In addition, Steinweg recognizes many other

stakeholders, even though these have not been documented at one location. Steinweg attaches great value

to maintaining good relationships and dialogue with its stakeholders.

Who?

Internal stakeholder

subtype

Customer subtype Subcontractor subtype Supplier subtype Other stakeholder

subtype

Employees Bank (Financing) Airfreight Bank (Treasury) Charity

Labor safety council

(Arbo commissie)

Broker Barge operator Construction Competitors

Shareholders Forwarder (customer) Chartering broker Consultancy Customs

Subsidiaries Producer Customs broker Courier services Event organizers

Supervisory board Receiver Forwarding (bookings) Educational

institution

Exchange

Works council (OR) Shipping line (owner) Inspection / Surveyor Equipment Government

Trader Lashing Facility services Graduates

Packing Financial services HARC-team

Rail operator HR services Labor union

Shipping agent Insurance Media

Shipping line (bookings) IT Member organization

Stevedore Legal Police

Trucking Office supplies Port authority

Warehouse Publicity Rijnmond

Environmental Service

(DCMR)

Real estate Society

Travel & hospitality Tax authority

Engagement

Steinweg is engaging its stakeholders in matters which are relevant for that particular stakeholder. Extensive

stakeholder dialogue takes place on a daily basis, but also during meetings or customer visits.

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3. Addressing the seven social responsibility core subjects and 37 social

responsibility issues

The ISO 26000 guidelines identifies seven social responsibility core subjects and accompanying 37 social

responsibility issues of which the below only includes those which have been considered as a priority by

Steinweg. The reader should picture this selection process as a funnel in which the identified relevant issues

are marked significant (or not) and significant issues are marked a priority (or not) - as can be seen from the

picture below. The selected priorities are:

Organizational governance

Resolving grievances

Health and safety at work

Human development and training in the workplace

Prevention of pollution

Sustainable resources use

Anti-corruption

Health

Core subject: Organizational governance

- Organizational governance

Our ‘Authority Framework’ template and related directives aim to give more structure to decision making on

investments, e.g. intended to be used when Steinweg initiates new projects which have impact on several

domains such as operations, commercial, IT, HR, finance and organizations.

Furthermore, in order to evaluate results, the company is engaged in change management whereby various

business processes have been documented and are amongst others continuously monitored by our internal

audit and all QHSE departments.

Core subject: Human rights

- Resolving grievances

One of the mechanisms to manage this is the whistleblowing procedure. This procedure provides the

support to our employees to report unethical practices without repercussions.

Core subject: Labor practices

- Health and safety at work

Safety at work is one the highest priorities on all agendas within Steinweg. With a dedicated safety

department, several safety trainings and a software program specialized in registering, monitoring en

evaluating (safety) incidents, Steinweg has broad variety of tools in place in order to manage safety at work.

- Personnel development and training in the workplace

At Steinweg, each employee has the opportunity to develop themselves and a wide scale variety of

educations, both fit for the job as well as to broaden personal development.

Core subject: The environment

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- Prevention of pollution

Steinweg takes the environment into consideration while making (investment) decisions. For example, at the

end of 2017, when Steinweg finalized the construction of a new shed at the chemicals terminal, negative

impacts on pollution were analyzed carefully and taken into account during the construction.

- Sustainable resource use

Steinweg installed solar cells on rooftops which are currently built at our premises. Also, the amount of EV

charging stations in front of the office, has multiplied. Furthermore, calculations have been made on the

applicability of wind energy.

Core subject: Fair operating practices

- Anti-corruption

Steinweg has developed and implemented its own anti-bribery and corruption (ABC) policy which

counteracts bribery and corruption. This has been based on the ISO standard on anti-bribery and corruption.

Core subject: Community involvement and development

- Health

Research on health and lifestyle has been done with all employees by an external agency. These results have

been benchmarked by the agency against national averages and medical examinations. The outcomes have

led to employees now actively participating in sport-, stop-smoking, and healthy-lifestyle programs offered

by Steinweg free of charge. Employees can also vaccinate themselves via the company.

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4. Integration of social responsibility throughout the organization

One of the desires and goals of Steinweg is to embed CSR in the organization and to also formalize this into a

policy.

Plan

There are control processes in place to make sure employees are working in a compliant way within a safe

environment. This is partly done by prescribing certain guidelines and rules in the code of conduct, personnel

manual and safety plans.

Do

A control manual has been created in which the internal control requirements have been defined for key

processes that all Steinweg entities should strive to adhere to through a process of providing a group

standard, implementation, (internal) audit and improvement plans. Also, the finance and compliance

departments are structured in a way that fraud and misconduct have been minimized by controls and

segregations.

Check

In order to monitor the standards of conduct a control is performed yearly across the company entities in

which branch managers receive a compliance letter and questionnaire for them to state actual compliance.

Internal audits are regularly conducted. We have our quality, health, safety and environment system in place

as well as a risk policy and a control manual.

Act

Besides the company having several internal checks in place to ensure we are up-to-date about certain

developments, there is also regular contact between our business and external intermediaries within a

variety of fields to be informed on recent developments and to implement those suggestions within the

organization.

Do

Check

Act

Plan