I up the neutrals to full credit, and apply some restrictions to my self.

Anything clearly sailing into a hostile port (notably Hartlepool) and within the declared war zone, or sailing in a hostile convoy is fair game.

All shipping on non-historical courses, or in non-historical locations, are ignored.
Throughout the war, all norwegian vessels, operating in norwegian waters, are hands off.

I haven't found anything saying he was. He sank another one (the sixth) on 22 Aug, 1942, the day they declared war on Germany.