Corporate Governance

A/S Dampskibsselskabet TORM
Whistleblower Policy

TORM's Whistleblower Policy is an integral part of the TORM compliance program.

TORM is committed to fostering a workplace conducive to open communication regarding its business practices and to protecting employees from retaliation and discrimination for their having properly disclosed or reported illegal or unethical conduct.

Reporting under the TORM Whistleblower Policy is available for concerns affecting

- employees and officers of TORM
- a person who has a business relationship with TORM (supplier, customer, broker etc.); and
- an employee of a person who has a business relationship with TORM.

Where to report
Concerns should initially be raised within the TORM hierarchy.

TORM employees should initially (and promptly) discuss any concerns with their superior or supervisor.

Other people should first raise concerns with their contact officers in TORM, usually the TORM employee who manages the account.

If the concern is not satisfactorily addressed within the hierarchy, or if the person is reluctant to report within the TORM hierarchy, the WSP should be contacted. TORM has appointed an external independent Whistleblower Service Provider (WSP) who can be contacted by telephone, facsimile, e-mail and mail. Contact details of the WSP are available by contacting TORM by telephone +45 39179200.

What to report
Generally, TORM encourages employees and other stakeholders to pursue the following issues:

a. fraud, including the provision or the endorsement of false or misleading statements about the Company's affairs;

b. criminal offence (actual or imminent);

c. violation of laws and regulations (actual or imminent);

d. actual or imminent intentional provision of incorrect information to public bodies;

e. unlawful behaviour in connection with accounting, internal accounting controls or auditing matters, including but not limited to

(i) fraud or deliberate error in the preparation or maintenance of any financial statement or financial records of the Company;
(ii) non-compliance with internal accounting controls;
(iii) misrepresentation or false statement to or by an employee or accountant regarding a matter contained in the financial records, financial reports or audit reports of the Company; or
(iv) deviation from full and fair reporting of the Company's financial condition.
f. actual or imminent violation of rules of conduct applicable within the Company; or

g. actual or imminent intentional suppression, destruction or manipulation of information regarding the matters detailed in a.-f.

If a person has any doubts as to whether his concerns fall within the matters the WSP has power to investigate, the matter can be discussed informally with the WSP.

How to report
The report form attached to this Whistleblower Policy indicates the information which would normally be useful in assessing the relevance and seriousness of concerns raised. It is not necessary to use the report form - a report may be filed by telephone, letter or e-mail.

The person making the report may remain anonymous. However, reports made anonymously may be difficult to investigate.

Protection of whistleblower
TORM forbids any member of its staff from penalising any person who contacts the WSP to make disclosures within the scope of this policy. This includes any reprimand, reprisal, change in work duties, change in employment amenities, change in reporting requirements, damage to career prospects or reputation, threats to do any of these or deliberate omissions which damage the person.

TORM is committed to protecting the identity of people who contact the WSP. However, there will be occasions when this is not possible, e.g.

- where the investigation leads to charges being made in court;
- where the nature of the allegations is such that the identity of the person can be deduced from the information made available to the WSP; or
- where the person is given special treatment such as leave of absence during an investigation.

As soon as possible after the first contact by a person, the WSP will discuss the issue of confidentiality and the degree of risk that the identity will become known. The WSP will advice the person promptly if matters change in a way that affects TORM's ability to protect the person's identity and will give the person as much warning as reasonably possible if the appears likely to the WSP that the person's identity will become known.

The WSP's duty to ensure a fair investigation overrides the obligation to protect the identity of the person who made disclosures. A person whose reports to the WSP was not made in good faith, with the intention to harm another person or abuse the whistleblowing policy, will not be protected by this Whistleblower Policy. The WSP is entitled to discuss such person's conduct with the TORM management for disciplinary action.

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This version of the policy was approved by the Board of TORM on 7th March 2006.