Business ethics

Our compliance and anti-corruption measures play a vital role as we work to protect the value we create for our customers, our investors, and society.

Why business ethics matter

Corruption is still considered one of our key compliance risks. It distorts opportunities for social and economic development and destabilises the business environment. It also adds to the cost of doing business while affecting external confidence and company morale.

Our ocean and logistics activities primarily face corruption risks in the form of facilitation payments at ports and borders. For terminals, risks may arise during negotiations on concessions or agreements to build and operate terminals as part of a country's infrastructure.

Business ethics matter

Progress 2021

Hassle free
Global compliance risk assessment completed
Engagement with Maritime Anti-Corruption Network (MACN) representing 50% of global ocean tonnage

Our ambition

We aspire to contribute to eliminating corruption in the industries in which we are active. This is possible through both multistakeholder collaboration and actions within our operations. We to be best-in-industry, above legal requirements, while meeting best international practices when operating in jurisdictions with high exposure to corruption, sanctions and export controls. 
Business ethics

Priorities and actions

We manage our business ethics risks through our compliance programme and collective actions to fight corruption and ultimately eliminate facilitation payments.

Our adoption of ESG, broadens the perspective on business ethics, and include both responsibility, opportunity and risk related to our work promoting sustainable trade and a better society.

Second global compliance risk assessment

In 2021, the second global compliance risk assessment was performed. The results of this will help guide our efforts towards defining meaningful risk-based mitigating measures and prioritise resources for training, transaction testing and spot checks.

The Maersk Code of Conduct course was completed by 36,691 employees (91% of employees in scope) in 2021. In 2022, we are expanding these activities, and will be developing dedicated training for seafarers and non-office workers.

Action on facilitation payments

We have reported on facilitation payments on our own vessels since 2015, but have seen around zero incidents with minor fluctuations since 2018. The reduction is not as stable on charted vessels due to less control. 

We continue to work with the chartered vessel owners to produce continuous progress and the goal still remains to eliminate all facilitations payments, also for the chartered vessels. 

Action on supply chain risks

We manage risks through our Third Party Management Process, which focuses on integrity issues relating to third parties interacting with officials or procuring business on our behalf, and our Sustainable Procurement programme. 

We perform integrity due diligence on our agents, joint venture partners, key suppliers and M&A targets prior to signing a contract or entering a new market.  

Our business ethics targets 
Our business ethics targets 


  •  Employees trained in the Maersk Code of Conduct
Our business ethics targets 


  • Of Maersk operations undergo bi-annual compliance and business ethics risk assessments
  • Continued implementation of related risk mitigation measures for any uncovered risks 

Code of Conduct

Our expectations towards our employees are clearly expressed in the Maersk Code of Conduct and Maersk Commit Anti-Corruption Rules and guidelines. These cover rules on travel, meals, hospitality, gifts and entertainment.  

All employees must complete an annual training on our Code of Conduct, and mandatory training on anti-corruption and sanctions. To ensure that we live by our values and Code of Conduct, we carry out transaction testing and spot checks on an ongoing basis to identify and address risks and gaps.
Maersk Code of Conduct

Maersk Sustainability Report 2021

Read more about our progress on environmental, social and governance dimensions in our latest Sustainability Report.
Maersk sustainability report

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Learn more about A.P. Moller - Maersk, our values, leadership, our history and more.