Compliance function

Our Compliance Enhancement Programme (CEP) is based on our Code of Conduct. It aims to continuously enhance our compliance measures in line with external guidelines and changing legislation to ensure the company maintains a consistent approach.

Van Oord has a Compliance Director to monitor governance and management of compliance risks, with a dedicated team overseeing and further developing the compliance programme. The team consists of 8 people, all specialists in various compliance topics (including data privacy). The Compliance Team regularly liaises with external experts. The Compliance Director reports to the Executive Committee and to the Supervisory Board where appropriate. The final responsibility for compliance matters lies with the CEO.

At the business unit level, a Compliance Contact Person provides additional support to ensure the local implementation of the CEP. Furthermore, the larger Van Oord offices outside of the Netherlands have a local Compliance Contact Person as a first point of contact for local staff and the compliance department at the group level.

Agents and agent policy

Van Oord operates around the world, including in countries with an increased risk of fraud and corruption. The company uses local expertise from intermediaries and agents in many countries to secure and execute projects. They perform a range of services for which they receive a percentage of the contract value, a success fee, or both.

Van Oord has a contractual right to audit the disbursement of these funds. The use of agents contributes to the success of the company but also poses an inherent heightened compliance risk. Van Oord has an Agent Policy in place with appropriate policies, procedures and controls to prevent and minimise compliance risks. In 2025, Van Oord exercised its right to audit.

Reporting of Concerns Policy

Van Oord is committed to maintaining a good working environment and an open culture where concerns about possible misconduct can be discussed and addressed. Van Oord has a Reporting of Concerns Policy that deals with concerns of a general nature that can have an impact on Van Oord and society in general. As part of this policy, we appointed 3 internal Trusted Persons, one of whom is the Compliance Director.

Employees may approach the Trusted Persons to discuss concerns and request assistance. We also have an independent external point of contact to safeguard anonymity of reporters and to create a reporting route outside the Van Oord organisation.

Employees can report concerns to their manager, the Trusted Persons, the External Independent Person and the Compliance Director, who have been designated to fulfil this role within the company. Van Oord guarantees that anyone reporting concerns properly and in good faith will be protected against negative consequences.

We launched Safecall, a new external reporting service designed to improve the accessibility, confidentiality and compliance of our reporting channels. Safecall offers a secure way for staff to report concerns 24/7.

Sanction and Export Policy

Van Oord is committed to complying with all applicable trade control laws and regulations of the jurisdictions in which we operate. We continuously review our Sanctions and Export Policy. Present circumstances demand that we monitor sanctions very frequently.

Code of Conduct for Supply Chain Partners

Our Code of Conduct identifies the values, responsibilities and rules of behaviour that all our employees, subsidiaries and joint venture partners must uphold. We expect our suppliers to adhere to a similar set of principles. Therefore, we have established a Code of Conduct for Supply Chain Partners, which describes our standards and requirements for suppliers and their supply chains.

We also request that suppliers have management systems in place that support compliance with applicable laws and regulations and our Code of Conduct.

Due diligence checks

To remain compliant, we also perform due diligence checks within our supply chain. The process is risk based and is applied to agents, new suppliers, new subcontractors and new partners. We perform monthly sanctions due diligence checks of approximately 100,000 suppliers. Van Oord also performs environmental, social and governance (ESG) due diligence and risk management. Our well-documented ESG Due Diligence process is an integral part of the Van Oord Management System, ensuring compliance with the OECD Guidelines for Multinational Enterprises.

Dilemma meetings

In the highly demanding and complex climate in which we operate, our staff can face dilemmas where there is no obvious right answer. Van Oord maintains an established programme of dilemma meetings in appropriate parts of the world. Dilemma meetings are standard practice in Van Oord’s CEP. Participants include senior managers and the Compliance Director. In 2025, we held 5 dilemma meetings.

Anti-Bribery and Anti-Corruption Policy

Van Oord is committed to conducting business honestly and refrains from using corrupt practices or engaging in bribery. By doing so, Van Oord aims to ensure adherence to applicable anti-bribery and anti-corruption standards. Our Anti-Bribery and Anti-Corruption Policy defines what constitutes bribery and corruption and which rules apply. The policy applies to all Van Oord employees, as well as its representatives and business partners.

ISO 37001 Anti-Bribery Management Certification

In 2025, Van Oord had its second successful surveillance audit for ISO 37001:2016. ISO 37001 is an international standard for anti-bribery management systems. It sets out requirements and provides guidance to help us prevent, detect and respond to bribery and comply with anti-bribery laws applicable to our activities. We also expanded the scope of this ISO certification to our Indonesian and Singaporean offices and entities.

ISO 37301 Compliance Management Certification

In 2025, Van Oord had a successful surveillance audit for its ISO 37301:2021 certificate. ISO 37301 is an international standard for compliance management.

Privacy Policy

Van Oord takes the privacy and protection of personal data seriously. In the policy, we explain how and why we process personal data in accordance with privacy laws and regulations. We apply the principles of the EU General Data Protection Regulation (GDPR) as our baseline.