1.             Introduction

1.1         This code of conduct (the “Code”) has been adopted by the board of directors of FLEX LNG Ltd. (the “Company”, and together with subsidiaries, the “Group”).

1.2         The purpose of the Code is to create a sound corporate culture and to preserve the integrity of the Company by helping employees to promote standards of good business practice. Further, the Code is intended to be a tool for self evaluation and a vehicle for development of the Company’s identity.

1.3         The Code applies to members of the board of directors, the chief executive officer, members of management, as well as others acting on behalf of the Company and Group companies. Compliance with these guidelines is the responsibility of every employee of the Company and companies in the Group.

2.             Ethics

2.1         The Company’s policy requires its directors and the employees of the Group to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Directors and employees must practice fair dealing, honesty and integrity in every aspect in dealing with other employees, business relations and customers, the public, the business community, shareholders, suppliers, competitors and government authorities.

2.2         When acting on behalf of the Company or the Group, directors and employees shall not take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair dealing practices.

2.3         The Company’s policy prohibits unlawful discrimination against employees, shareholders, directors, customers and suppliers on account of ethnic or national origin, age, sex or religion. Respect for the individual is the cornerstone of the Company’s policy. All persons shall be treated with dignity and respect and they shall not be unreasonably interfered with in the conduct of their duties and responsibilities.

2.4         No director or employee of the Group should be misguided by loyalty to the Company or desire for the Company’s profitability to disobey any applicable law or the Company’s policy.

2.5         Violation of the Company’s policy will constitute grounds for disciplinary action, including, when appropriate, termination of employment.

3.             CODE OF CONDUCT

3.1         The Company’s values

3.1.1   The Company strives to be a reliable partner achieved by quality operations, strict discipline, prioritising high quality solutions, predictable deliveries and a high level of service.

3.1.2   The Company shall act with a sense of urgency in all aspects of its business. This means that the Company shall meet commitments in the minimum time required, make decisions fast but based on facts, accept change and manage new challenges and also be proactive.

3.1.3   The Company shall exploit and develop skills in production, product development and management. In this respect, professionalism and use of best practice are key elements.

3.2         Rules and legislation

3.2.1   It is the Company’s policy to comply with all applicable laws and governmental rules and regulations in the country in which it is operating. It is the personal responsibility of each of the persons mentioned above to adhere to the standards and restrictions imposed by those laws, rules and regulations, including those relating to accounting and auditing matters.

3.3         Work environment

3.3.1   The Company and companies in the Group shall be a professional and positive workplace with an inclusive working environment.

3.3.2   The Company shall strive towards meeting, and preferably exceed, the requirements of all relevant legislation.

3.3.3   All employees in the Group shall help to create a work environment free from any discrimination, due to religion, skin colour, gender, sexual orientation, age, nationality, race and disability.

3.3.4   The Company does not tolerate behaviour that can be perceived as degrading or threatening.

3.4         Relations with customers, suppliers, competitors and public authorities

3.4.1   Customers shall be met with insight, respect and understanding.

3.4.2   Suppliers shall be treated impartially and justly.

3.4.3   Public authorities shall be met in an appropriate and open manner.

3.4.4   The Company desires fair and open competition in all markets, both nationally and internationally. Under no circumstances shall the Company or any of its employees be part of actions that breach applicable competition legislation.

3.4.5   The Company is a firm opponent of corruption in any form (bribery, “facilitating” etc). No employee of the Company or the Group shall directly or indirectly offer, promise, give or receive bribe, illegal or inappropriate gifts or other undue advantages or remuneration in order to achieve business or other personal advantage.

3.4.6   The Company is a firm opponent to money laundering in any form. The Company will take the necessary steps in order to prevent its financial transactions from being used by other to launder money.

3.5         Loyalty and conflict of interest

3.5.1   The Company will require all employees (of it or the Group) to be loyal to it, and to refrain from actions or to have interests that make it difficult to perform their work objectively and effectively.

3.5.2   All employees are responsible to notify the board of directors of a situation where he/she has a material direct or indirect interest in any transaction or other matter entered into by the company or binding on the company.

3.5.3   Conflicts of interests should be avoided. Should a conflict of interest arise, all employees will be required to evaluate the situation and notify the superior of the partiality or conflict of interest. A conflict of interest situation may involve, but are not limited to, customers, suppliers, contractors, present or prospective employees, competitors or relations.