LNG services
Norconsult
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Client:
Client’s Contact Person:
Consultant: Norconsult AS, Vestfjordgaten 4, NO-1338 Sandvika
Assignment Manager:
Technical Advisor:
Other Key Personnel:
01 20150106 Issued for IDC hhe tb sce
Version Date Description Prepared by Checked by Approved by
This document has been prepared by Norconsult AS as a part of the assignment identified in the document. Intellectual property
rights to this document belongs to Norconsult AS. This document may only be used for the purpose stated in the contract
between Norconsult AS and the client, and may not be copied or made available by other means or to a greater extent than the
intended purpose requires.
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Contents
Introduction 4
Norconsult LNG competence 5
LNG process overview 5
LNG terminals 7
Flat bottom tanks, atmospheric tanks 8
Pressurized tanks 9
Multi discipline engineering 10
Risk Management, HSE and technical safety 12
Floating LNG 13
Project execution 15
Norconsult AS general information 17
General 17
Location 17
Management system 17
Quality policy 20
Health, Safety and environmental internal control 21
Health, Safety and protection of the environment 22
Health, Safety and environmental internal control policy 23
Code of ethics 24
List figures: Figure 1, Main process block diagram, pre-treatment, liquefaction, storage and import/export ............................... 5
Figure 2, Typical LNG loading block diagram .......................................................................................................... 7
Figure 3, Typical LNG off-loading and export, truck and vessel .............................................................................. 8
Figure 4, Norconsult double compartment LNG storage tank, 30 000 m3 tall design ............................................... 9
Figure 5, Norconsult double compartment LNG storage tank, 30 000 m3 low design .............................................. 9
Figure 6, Pressurised LNG bullet tanks with vapour system ................................................................................... 9
Figure 7, Pressurised LNG bullet tanks with vapour system ................................................................................. 10
Figure 8, Small scale LNG terminal with import/export facilities ............................................................................ 10
Figure 9, Static and dynamic process simulations. Graphs shows boil of gas at tank filling .................................. 12
Figure 10, LNG liquefaction plant with 30 000m3 storage tank with LNG export facilities by truck and vessel ..... 13
Figure 11, FLNG unit with export facilities of LNG, LPG and condensate ............................................................. 14
Figure 12, Typical process block diagram FLNG with export facilities ................................................................... 14
Figure 13, Norconsult general LNG/gas engineering services .............................................................................. 15
Figure 14, Typical work package/contract breakdown of LNG terminal ................................................................. 16
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Introduction
Norconsult has during the last 20 years executed a large number of LNG projects including
liquefaction, storage, export terminals and regasification. Norconsult has been working in all execution
phases of projects from early phase studies to construction follow up and plant handover to Client.
All experiences gained during the project execution phases and in depth knowledge of different
liquefaction technologies are carefully processed and added into Norconsult LNG project experience
database.
Norconsult provides multi discipline services within the following fields of engineering and project
follow up:
LNG Regasification terminals
Ship loading/ unloading
Boil-off compression
Vapour handling
LNG vaporisation
LNG storage and export
LNG liquefaction plants
Gas metering
Condensate removal
Mercury removal
Acid gas removal
Dehydration
Liquefaction
Refrigeration
LNG storage and loading
Site layout and utilities
LNG export terminals
Primary and secondary pumping
LNG storage and export
Ship loading and jetty
LNG peak shaving plants
Gas metering
Acid gas removal
Dehydration
Liquefaction
Storage and export?
Boil off and gas recovery
Gas vaporisation
Truck loading and unloading
Fire protection
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Norconsult LNG competence
LNG process overview
Production of Liquefied Natural Gas (LNG) requires the application of a broad range of technologies
and design expertise. The block flow diagram identifies the main processes and utility facilities that are
required to produce LNG. The diagram also include LNG storage and necessary terminal facility for
LNG import and export.
Figure 1, Main process block diagram, pre-treatment, liquefaction, storage and import/export
Feed gas to the plant can be taken from a gathering system or gas pipeline. This gas may contain
liquid hydrocarbons, which will be removed in the inlet reception/separator systems. It is necessary
also to remove CO2, H2S, water and mercury if the feed gas contain such elements as this will cause
damage to downstream process equipment.
The clean and dry gas is sent to the liquefaction process where the LNG is produced. The liquefaction
system is the heart of the processing plant. Norconsult has developed advanced process simulation
tools to make the client able to select the optimum liquefaction process and technology based on the
plant limitations and volume flow.
The LNG from liquefaction process is stored in large tanks at near atmospheric pressure, or in
pressurized bullet tanks if found optimum based on Client’s needs. Vapour from the storage and LNG
boil off is used for plant fuel or for export to other consumers of gas, alternatively fed back into the
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liquefaction system. Norconsult has extensive experience with the LNG storage and export systems
for both the liquefaction plants and in LNG terminals
In addition to the main process units, the liquefaction facility requires many key utility systems. These
systems must be properly integrated into the overall process scheme for the project to be successful.
Norconsult has extensive experience in design and construction of gas processing facilities, which
include all of the necessary utility and product handling systems.
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LNG terminals
LNG terminals involve the application of cryogenic engineering expertise including high cost
components. In addition to our terminal experience many of the liquefaction plants involve the storage
and export of LNG product including LNG vaporization and gas supply to local gas grid and industry.
A typical terminal set-up is presented in the figure below. The LNG is unloaded from LNG tankers at a
high rate, typically 1,000 – 12,000 m3/hr. This allows unloading to occur in about 12 hours. The LNG
is sent directly to storage, usually involving multiple pressurised tanks or to a larger flat bottom
atmospheric pressure tank. During unloading process, a large quantity of vapour is generated. Vapour
is returned to the tanker for replacement of LNG, and the surplus vapour is compressed in the boil-off
system for use as fuel or re-liquefied and returned as a LNG product in the tanks.
At gas export facilities the LNG is pumped to export pressure by submerged motor LNG pumps. The
LNG will be vaporized back to natural gas at the export pressure. The vaporization system can be
based on several different technologies conditioned the necessary capacity and environmental
conditions. The vaporisation process can be based on systems with fired equipment, seawater or air
vaporizers as well as intermediate fluid (propane) systems.
Figure 2, Typical LNG loading block diagram
Norconsult has experience from several terminals projects including import and export facilities. The
LNG terminals involve the same know-how in cryogenic systems that applies to liquefaction units. Our
experience in terminal designs covers all major systems and a variety of types of equipment, which
may be employed.
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Figure 3, Typical LNG off-loading and export, truck and vessel
Flat bottom tanks, atmospheric tanks
Norconsult has since 2009 been involved in the development of downstream LNG distribution hub’s
and terminals. The larger terminals has normally a storage unit based on a flat bottom atmospheric
LNG tank in the range of 10 000 m3 to 50 000 m3.
Norconsult has gained valuable experience in design of atmospheric full containment LNG storage
tanks with a cryogenic nickel steel inner tank and concrete outer tank with insulation in between. The
design is competitive both regarding cost and construction period, and will fulfil the standards EN 1473
and EN 14620. The design life specified is 50 years.
The LNG tank design meets the requirements given by the authority with respect to construction
standards, environmental actions also including earthquake and is designed to withstand fire and
impact from flying objects.
LNG tanks based on the full containment principals are favourable regarding risk and safety. The
safety distance reduces significantly compared to other types. The LNG plant covers less area as well
as the neighbour areas are less influence regarding restriction related to future use.
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Figure 4, Norconsult double compartment LNG storage tank, 30 000 m3 tall design
From a design point of view it is important that the tank is not evaluated as a separate item, but part of
a complete system. All individual equipment and components are part of an integrated complete
system with internal dependencies.
Norconsult has it’s own design of such tanks approved by third party like DNV-GL and DEKRA.
Norconsult services cover all phases of a project cycle from the earliest pre-investment evaluations
and feasibility studies, through planning and design, tendering and construction supervision, to project
implementation, operations and maintenance. Our company can provide the Client with multidiscipline
engineering resources that are required to deal with all aspects for development of new LNG
loading/unloading terminals including storage tank solutions.
In addition to services within tank design and engineering, Norconsult can offer engineering of
pipelines, jetties, civil process design, procurement, HSE, emergency preparedness, safety and
automation systems, instrument and telecommunication, authority handling, construction management
and owner’s engineer.
Figure 5, Norconsult double compartment LNG storage tank, 30 000 m3 low design
Pressurized tanks
Satellite terminals based on Pressurized LNG tanks
Figure 6, Pressurised LNG bullet tanks with vapour system
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For the downstream distribution, Norconsult has been involved in a number of terminals ranging from
80 m3 to 6 500 m3 storage capacity of LNG. The terminals are designed according to the standard EN
14645, and based on pressurized vacuum insulated tanks. The most of the pressurised tank terminals
have regasification based on ambient air heat exchangers. In addition to regasification, the terminals
very often have export facilities through truck loading facilities and bunkering facilities for vessels.
Norconsult has executed project management and technical management as owners engineer for a
number of these projects. This also includes the authority permitting process.
Figure 7, Pressurised LNG bullet tanks with vapour system
Multi discipline engineering
Norconsult provides full range of multi discipline engineering resources within the field gas processes
and matters related to LNG. We are using state of the art process simulation tools in order to design
and verify the process design. We are further using full-computerised 3D layout systems, allowing us
to optimise the plant layout with respect to equipment location, pipe and cable routing. Norconsult has
high focus on health, safety and environmental aspects of the plant design together with good
solutions within technical safety. This is crucial for documenting and getting all the necessary
approvals from national authorities before final investment decision is made and for final start-up
approval.
Early phase services
● Evaluation of LNG as energy source
● Investment analysis
● Concept evaluations and development
● Plant or terminal capacity assessments
● Process simulations of plant/terminal
● Site evaluation
● Hazard and risk identification
● Initial environmental assessment
● Requirements and GAP analysis
● Development of policies, goals and
acceptance criteria for HSE and quality
performance
● Advisory services related to hazardous materials, major accidents and emergency
preparedness
Figure 8, Small scale LNG terminal with import/export facilities
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● Technology qualification studies based on international recognised standards
Detail design
● Philosophies for design, operation & maintenance
● Design documents for all disciplines
● System descriptions, process and main utility systems
● Process simulation static and dynamic
● Sizing of process equipment and piping
● Fabrication drawings
● Civil
● Instrumentation and automation
● Electro
● Layout and safety
● Infrastructure and interface management
● Assistance in application processes HSE authorities
● Development and implementation of management systems (HSE, quality)
Construction Services
● Supplier and fabrication follow-up
● Construction management
● Site supervision
● HSE management and follow-up
● Mechanical Completion
● Commissioning
● Final documentation
Design in Europe is based on the following international norms and standards
● EN 1473 - Installation and Equipment for liquefied natural gas Design onshore installations
● EN 13645 - Installation and equipment for LNG , Design of onshore installations with storage
capacity between 5 t and 200 t
● EN 13458 - Cryogenic vessels
● NS-EN ISO28460_2010 Installation and equipment for liquefied natural gas -- Ship-to-shore
interface and port operations
● ATEX directive -on equipment and protective systems intended for use in potentially explosive
atmospheres (ATEX)
● Seveso III directive - control of major-accident hazards involving dangerous substances
● National laws and other regulations (B&E, NFPA, CSA, LNGA2010-MSB)
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Figure 9, Static and dynamic process simulations. Graphs shows boil of gas at tank filling
Risk Management, HSE and technical safety
Designing safe and reliable technical solutions for our clients has been Norconsult’s highest priority
goal. As the society we live in is in constant change and is growing ever more complex, global and
open. As a result, society’s vulnerability is also increasing. This means that risk assessments,
preventive measures and emergency response are becoming increasingly important elements for all
players – from public authorities to private businesses.
Norconsult has been involved for a long time in work to create a safe and well-functioning society.
With respect to LNG these aspects is crucial as consequence of LNG spill or gas leak could be
damaging and have large consequences for the workers on the plant, the plant itself and it’s
surroundings. If not properly designed fire or large gas leaks could occur.
Norconsult provide consultancy and engineering services/advices within:
Risk Management
● Working environment assessments
● Emergency preparedness
● HSE management systems
● Quality Management Systems
● Risk Management, including risk quantitative and qualitative risk analysis
● Technical safety
● Monitoring
HSE and Risk Management in development phases
Process simulations
25
● Aspen One Engineering
Includes
• Process modeling analysis and design tools integrated in Hysys
• Optimization of process designs
• Equipment sizing for layout and weight estimates
• Flare System Analyzer, including PSVsizing
• Depressurisation modelling
• Dynamic simulation for support of design and operational challenges
• Natural gas acid gas cleaning templates for rigorous design
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● Development of policies, goals and acceptance criteria for HSE and quality performance.
● Hazard identification and risk assessments.
● Risk Analysis
● Development and implementation of management systems (HSE, quality).
● Design reviews and layout reviews
● Assistance in application processes towards HSE authorities.
● HSE management and follow-up in projects.
HSE in Construction and Commissioning
● HSE management and follow-up in construction projects.
● Hazard identification and risk assessments at site
● Risk Analysis
● Inspections and audits
● Accident/incident investigation.
● Advisory services related to hazardous materials, major accidents and emergency
preparedness.
Figure 10, LNG liquefaction plant with 30 000m3 storage tank with LNG export facilities by truck and vessel
Floating LNG
Norconsult has during the last 8 years participated in 4 large floating LNG (FLNG) projects including
floating gas pre-treatment, LNG liquefaction, offshore storage of condensate, LPG and LNG, and
offshore terminals for export and import of the same products.
The applicable codes and standards for floating terminals/plants are different for the land based
facilities. The marine codes and standards must be adhered to. There is also different certifying bodies
involved in the third party evaluation of the design and construction. Typical certifying body is DNV-
GL, Lloyds and American Bureau of Shipping (ABS).
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Figure 11, FLNG unit with export facilities of LNG, LPG and condensate
During these projects, Norconsult gained valuable experiences reflecting the special considerations
necessary for the design and equipment selection when the foundations is moving in 3 directions with
variable frequency and magnitude. The design included further the complicated operation analysis of
such installation, as it shall be able to operate as a ship, as a production unit and as an export
terminal. All different modes of operation should be certified against different codes and standards.
The Norconsult contract was an Owners Engineer (OE) contract where Norconsult had the technical
coordination responsibility within the Clients organisation versus different engineering contractors of
hull, topside processes and technology owner of different technologies.
Figure 12, Typical process block diagram FLNG with export facilities
Inlet GasFacilities
DehydrationGas
TreatingLPG
Extraction
SolventRegen
Regen
GasReception/Compression
Liquefaction
LNG
Off-loading
Utilities
LNGStorage
CO2,H2S
H2O
LPG/C5+Storage
C3/C4's Condensate
Dry Gas
LPG/Cond.Off-loading
To Ships
To Ships
Feed Gas Pre-
Treatment
LNG Liquefaction
Utilities
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Project execution
Norconsult is an independent, multi-discipline engineering company giving services to all types of
engineering projects in all phases of a project life. This experience has given Norconsult an unique
position and experience for project execution follow up as partner to our Clients team. We have
experience in playing a separate or defined role in the follow up team during the construction period
and we have good experience in participating as partner in integrated follow up team headed by the
Client (Owner).
As Norconsult has no economical or financial interests in any other companies, we will act as 100%
independent consultant to our Clients, always recommending the optimum solution for the task/project
under the governing conditions.
Norconsult service will concentrate at optimum engineering solutions in the early phases and prepare
all necessary documentation to utilise the market competition to achieve the best price for
construction, mechanical completion, start-up and handover of the facilities. After having placed the
turnkey contract or placed several specialised contracts the Norconsult service will change character,
join the Clients team for contractor follow team, and establish a project task force.
Our services can be summarised in the below slide:
Figure 13, Norconsult general LNG/gas engineering services
In order to control the project with respect to contract strategy, work break down packages and time
line it is important to have a well proven management system. Some LNG projects have experience
significant budget overrun and project delay in start up. Norconsult is therefore focusing on the
importance of a maturing the project in the early phases and that the concept is matured before final
investment decision is made. Below is a schematic presentation of a high level contractual strategy
and project budget cost spread over time:
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Figure 14, Typical work package/contract breakdown of LNG terminal
C Customer Terminals
Project interated team
Amount
Site preparations
Amount
LNG Storage tank (bullet type)
Amount
LNG Tank process systems
Amount
Gasification plant
Amount
Import and export piping
Amount
Vessel loading/unloading facilities
(If applicable) Amount
Truck and rail unloading/Loading
facilities
Safety and Automation Systems
Telecom
Fire fighting Systems
Amount
Civil
Structural and Architectural
Systems
Waste Water Treatment Plant
Sewage Treatment Plant?
HVAC
Amount
10GRAND TOTAL
Customer Terminals
WP F0
WP F9
WP F9
WP G7 WP H7
WP G9 WP H9
WP G9 WP H9
WP F4
WP F5
WP E6
WP C7 WP D7 WP F7
WP C5 WP D5
9
Amount
8
WP G6 WP H6
7 WP A7
6 WP A6 WP C6 WP D6
WP G5 WP H5
3
4 WP A4 WP C4 WP D4
WP A3 WP C3 WP D3 WP G3 WP H3
WP G4 WP H4
5 WP A5
COST BREAKDOWN STRUCTURE
Work PackageA
Project General
C
EPC
management,
engineering and
services
D
Equipment cost
and
manufacturing
F
Civil construction
G
System and
equipment
installation
H
Mechanical completion,
commissioning, tests
and hand over
I
Total
B
External
assistance and
studies
FEED contractors
EPC contract site preparations
EPCIC LNG terminal contractor
0 WP A0 WP B0 WP C0 WP D0
WP B7
WP B8
WP B9
WP A8
WP A9
WP C8
WP C9
WP D8
WP D9
2 WP A2 WP C2 WP D2
1 WP A1 WP C1
Contractor identificationProject inergrated team
WP G0 WP H0
WP B1
WP B2
WP B3
WP B4
WP B5
WP B6
WP G2 WP H2
WP F1
WP F2
WP F3
WP D1
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Norconsult AS general information
General
Norconsult is an interdisciplinary engineering and design consultancy, providing services to clients in
the public and private sectors worldwide. The company is the leading Norwegian consultancy, a
considerable European player, and has leveraged its substantial international presence and
experience in projects on all continents.
Norconsult takes an active part in building society, and its interdisciplinary experience provides a solid
foundation to participate in developing tomorrow's infrastructure. The company employs engineers,
economists, social scientists, architects, landscape architects, environmental, information and
communication technology professionals as well as experts in a broad range of specialty fields.
The company's services are organized within the following nine business areas: Buildings, Energy,
Environment, Industry, Oil and Gas, Planning, Risk Management, Transport and Water. Norconsult
always seeks to improve the clients' business and secure their investments. The company covers all
phases of a project cycle from the earliest pre-investment and feasibility studies, through planning and
design, tendering and construction supervision, to project implementation, operations and
maintenance.
The company's social responsibilities in the markets it operates, as well as the respect for local laws
and regulations are key business success factors. Norconsult's corporate values are based upon good
business practice, honesty and respect for other people, and the company's statutes and operations
comply with the general requirements, codes of ethics and quality assurance policies of the
International Federation of Consulting Engineers (FIDIC).
The group's turnover was NOK 3 843 million in 2014, with an operating profit of NOK 147 million.
Norconsult has approximately 2 900 employees and is owned by the employees.
Norconsult AS has an engineering team directly involved into offshore activities, mainly in the North
Sea, as well as involvement in LNG liquefaction plants and storage and regasification terminals.
Location
The work will be executed by personnel located in Stockholm, Gothenburg in Sweden and Sandvika,
outside Oslo, Norway.
Management system
Norconsult has a management system according to NS-EN ISO 9001, current revision. The system is
documented in our Company Handbook. The system takes care of all kinds of requirements, whether
governmental, contractual or self-imposed.
The most important elements of the management system related to each assignment are the
following:
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a) Requirement Review
Requirements to work performance and results, as well as risks and interfaces, are reviewed
during the bid process, in more detail during the project start-up process and again during every
change handling process.
b) Planning
During the bid process necessary actions and activities and governing documents are identified
and plans made, based on the requirement review. During assignment start-up the plans are
reviewed, based on the detailed requirement review, and governing documents for the project are
updated, adapted or prepared as necessary. During each change handling process, the plans are
reviewed again, and revised if necessary.
c) Implementation
All current governing documents for the assignment, whether new, adapted, updated or existing
and implemented, are made available to and reviewed by assignment personnel during
assignment start-up.
d) Follow-up
The day-to-day follow-up of requirements to work performance and results is done by the leading
personnel assigned the responsibility for the work, through planned inspections, reviews and
reports.
e) Handling of Changes
Every change proposal is treated in a process resembling the assignment start-up: Review of
changes in requirements and their consequences, decision to implement the change proposal,
revision of governing documents according to the change and practical implementation of the
change.
f) Handling of nonconformities
Any nonconformity discovered starts a process with two types of actions: To remove the
nonconformity and to prevent the nonconformity occurring again.
The most important elements of the quality system at company level are the following:
g) Permanent governing documents
Laws, regulations, standards and other permanent governing documents for our operations are
identified and recorded in a common company database, and monitored by assigned personnel.
Changes are published on the relevant discipline net portal and implemented in the management
system as needed.
h) Training
All new employees undergoes a standardised initial training covering the management system and
further initial training adapted to their competence regarding relevant markets, disciplines and
services. The company has a comprehensive set of internal and external courses for employee
development.
i) Professional management and development
All disciplines offered are organised in internal discipline networks. Each discipline network has a
coordinator, a portal on our intranet and meetings for updating and development within the
discipline. Every operational consultant is a member of one or more networks, depending on the
services they perform.
j) Monitoring of the system
The management system is monitored through internal and external quality audits. The company
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performs company internal quality audits according to a yearly audit plan. Internal and external
quality audits within a project are performed according to the project plans.
k) Management review
The top management team performs a yearly review of the system, where data and experience
from the preceding year forms a basis for an evaluation of system status and prioritizing of actions
(system development, training, monitoring) for the coming year.
l) System maintenance
The management system is maintained and updated by a management system department
reporting directly to the president and CEO. Changes are published on our intranet.
Comprehensive changes are implemented through information campaigns and other training as
needed.
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Quality policy
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Health, Safety and environmental internal control
Norconsult has a Health, Safety and Environmental Internal Control System (HSE IC System) fulfilling
the requirements of the Norwegian "Regulation concerning Systematic Health, Environmental and
Safety Activities at Enterprises" ("Internal Control Regulation"). The HSE IC System is an integrated
part of our Quality System. The Quality System is documented in our Company Handbook.
The most important elements of the HSE IC System are the following:
a) Organisation
The responsibility for fulfilling all relevant requirements in governmental laws, regulations and
decisions is an integrated part of the management responsibility of every manager, both within the
basic organisation and the different project organisations.
There are two specialised functions with special responsibility for supervision of the working
environment:
- The Working Environment Committee
- The Personnel Safety Representatives
The Quality System Manager supervises the HSE IC System as part of the Quality System.
b) Review of requirements and risks
General requirements to the company in governmental laws, regulations and decisions and
general health, safety and environmental risks has been identified and necessary preventive
actions implemented. Special, additional requirements and risks due to each project are identified
during start-up of the project and additional preventive actions implemented when necessary.
c) Health and safety when working in our own offices
Factors that may affect health and safety, such as the design and state of the building, fire
protection, electrical systems, sound, light, heating, ventilation and air conditioning, cleaning,
working space ergonomics, working habits and psychosocial factors are monitored.
d) Health and safety when working outside our own offices
Factors that may affect health and safety when our employees visit or work at construction sites or
the premises of other companies are considered to be the same as for the people working there
full time. The company has general rules and advice for commonly visited types of sites and
common protective equipment available. Each employee identifies the risks and rules that are
relevant for each site they will visit and takes measures accordingly.
e) Environmental issues
The normal activities of the company does not have special adverse effects on the environment.
f) Company health service
The company has arrangements for health service. Sick leave and injuries are monitored.
g) Information
Every new employee follows an information and training programme.
All employees have access to information on the operation of the company.
h) Supervision of the HSE IC System
The HSE IC System is supervised by the manager of each organisational unit, by the Safety
Delegates and the Working Environment Committee, and, as part of the Quality System, by the
Quality System Manager.
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Health, Safety and protection of the environment
Norconsult AS statement regarding Health, Safety and protection of the environment:
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Health, Safety and environmental internal control policy
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Code of ethics
The Code of Ethics /attachment 1/ is a governing document, and part of Norconsult’s management
system. It defines the ethical standards upon which we shall act.
This Code of Ethics does not provide detailed guidance on any specific situation, or give instructions
on how to comply with local legal requirements in the many different countries in which Norconsult
operates. It provides a framework of conduct to be followed when representing Norconsult, and as
such influences how to think about what we should and should not do. Managers on all levels at
Norconsult are responsible for familiarising their employees with the Code of Ethics, and implementing
and ensuring compliance with it.
Employees shall comply with all applicable laws and regulations. If there are differences between such
laws and regulations and the standards set out in this Code of Ethics, the most stringent standard
shall be applied.