NSE’s ethical guidelines are designed to ensure that everyone acting on behalf of the company goes about their business in an ethical manner and in line with the company’s values and principles on business practices and personal conduct. In NSE we emphasis on ensuring that attitudes and actions are consistent with the company's ambition to emerge as a company that has ethics and corporate responsibility on the agenda. NSE defines corporate responsibility as achieving commercial profitability in away that is in accordance with fundamental ethical values and respects individuals, the environment and society.
For other policies, rights,regulations and obligations relating to employment ship and contractual agreements with NSE, we refer to the company’s Social Responsibility policy, personnel handbook, quality manual and HSE-manual.
1. Introduction
1.1 The main object of the ethical guidelines
The ethical guidelines are intendedto ensure that everyone who acts on behalf of NSE performs his or her activities in an ethically sound manner and in line with NSE’s values and principles for commercial practice and personal behaviour.
1.2 To whom the guidelines apply
The guidelines apply to all the companies in NSE, hereinafter called “NSE”.
The guidelines apply to the enterprise and each individual employee, to members of the board of directors, hired personnel, consultants, agents and other intermediaries, lobbyists andothers who act on behalf of NSE, hereinafter called “the employee”.
1.3 Paramount requirements for the employee
NSE is subject to both Norwegian legislation and current legislation in those countries where NSE conducts operations at all times. Violations of laws and the ethical guidelinesconstitute a threat to the company’s reputation and competitiveness. Allemployees are personally responsible for operating within the requirementsconsequent on current legislation and on the ethical guidelines for NSE.
It is expected that all employeesfamiliarise themselves with applicable laws and governing documents relevantfor their work, participate in training and seek advice if in doubt.
It is expected that all leaders shallact as good role models by what they say and do. Leaders shall contribute tocreate an inclusive and open environment where people are comfortable askingquestions or notify without fear of retaliation. Leaders shall notify andcorrect violations of laws and regulations.
2. NSE’scommercial practice
2.1 Business method
NSE shall be known as a reliablecompany that delivers quality on time.
Suppliers, customers and partnersshall have confidence in NSE and its employees. NSE and the employees thereforecommit themselves to comply with current Acts and Regulations, live up to ahigh ethical standard and take active social responsibility in their conduct ofbusiness. The employee shall
comply with the rules and guidelinesthe customer has laid down for the individual assignment, including the requirementsthat apply to being on the customer’s property outside working hours.
NSE shall encourage its businessassociates to live up to ethical standards that correspond to NSE’s ethicalrequirements.
NSE shall have a business culturethat is characterised by the company’s value basis:
· Norm
· Safety
· Experience
Poor morale and unethical attitudes among anenterprise’s management and employees are a threat to desired and expressedquality. Our basic rule is that all levels in the organisation shall endeavorto act fairly, honestly and with personal integrity in dealings withcolleagues, customers, suppliers, competitors and the general public.
2.2 Wages and working conditions
Employees shall be secured wages,working conditions and working hours in accordance with applicable laws andagreements to prevent social dumping. Employees shall have a written employmentagreement in an understandable language.
2.3 Fair competition
NSE shall compete within thecompetition regulations applicable to the market in which the company isoperating, and otherwise with integrity and in an ethically sound manner.
No one shall participate inanti-competitive behavior for example price fixing, bid rigging, market sharingor abuse of market power in violation of competition laws.
The employee shall focus on NSE’scompetitive edges, and shall avoid emphasising the weaknesses of thecompetition or others in the industry.
2.4 Fighting corruption
Introductory provisions
Corruption can lead to a distortionof competition, under- mining legal business activity, maintaining poverty andoppression and it exposes the company to risk and loss of reputation. All formsof corruption are unacceptable in NSE.
Corruption takes many forms. If anemployee tries to influence someone in the performance of their duties bygiving or offering them an unlawful or improper benefit, for example, this isbribery. It could also be trading in influence if an employee, via a thirdparty, gives or offers someone an unlawful or improper benefit to influence abusiness relationship.
The ban on corruption applies to boththe person giving or offering the unlawful benefit and the person asking for,receiving or accepting it. The prohibition applies in the private and thepublic sectors, and both in Norway and abroad.
An unlawful or improper benefit may,for example, consist of cash, objects, discounts, coverage of travel oraccommodation expenses, participation in events or services etc.
In principle NSE is liable forcorrupt acts committed by the company’s employees. In addition, NSE can be heldliable for corrupt acts committed by third parties who have made contracts withNSE, and in
other cases where NSE can benefitfrom corrupt acts committed by third parties. NSE shall therefore work activelyto reduce the risk of corruption in the company’s operations, and will in allcontractual relations commit third parties to accede to the same rules andprocedures that apply to NSE as regards corruption.
Facilitation payments
Facilitation payments are paymentsdesigned to accelerate or secure delivery of services or products to which onemay have a lawful claim. This may take the form of payments demanded from theemployee to get goods more quickly through customs, to get more quickly throughpassport control and so forth. Such payments are, as a rule, illegal underNorwegian legislation. NSE does not accept such payments, except in cases wherethere may be a danger to the employee’s or others’ life or health, or if theemployee finds the situation threatening. All such payments shall be reportedto NSE’s CFO, with an explanation of why the sum was paid. It shall be postedin NSE’s accounts as “facilitation payment” and the amount shall be refunded tothe employee.
Gifts and entertaining
Employees shall not under anycircumstances request personal benefits from business connections. Gifts,entertainment, events and other benefits shall be carefully assessed inrelation to the specific situation and other circumstances. Each employee must assess whether the benefit is such that it willaffect own or others’ objectivity, independence or integrity. Hospitality such as social events, gifts or otherexpenses may be offered or received, as long as it is in accordance to thecompany’s guidelines.
Employees may not give or receive gifts, with theexception of small token gifts whose value does not exceed about NOK 500,preferably promotional items. If it is clear that refusal to accept a gift ofhigher value will be considered impolite, however, the employee may accept thegift, but must report the matter immediately to his/her immediate superior andmanaging director, and the gift must be handed over to him/her. Also seeprocedure NSE-ADM-P01 Economic authorization.
If the employee is aware that thebusiness connection has a lower value limit than NSE, gifts of a value higherthan that which applies in the recipient’s organisation should not beexchanged.
Cash is unacceptable irrespective ofthe amount or circumstances.
Personal discounts may not be receivedas a result of NSE’s business connections. Exceptions apply for discountsapproved by NSE.
If it is clearly business-related,the employee may participate in social gatherings and receive refreshments,provided that the cost is within the range of what is reasonable. In thisconnection NSE shall itself pay travel, accommodation and other expenses forthe employee.
In the same way, employees who act onbehalf of NSE, may not offer or pay for hospitality in conflict with theabove-mentioned principles.
The employee must exhibit a highdegree of caution about offering gifts or entertainment to, or receiving themfrom, representatives of enterprises with which NSE is in a negotiation andtendering phase, and prior to other important decisions. Hospitality, gifts, expenses or other favours shallnot be offered or received in connection with contract bidding, evaluation oraward.
The employee must exhibit a highdegree of caution about any offers of gifts or entertainment vis-à-vis publicservants, and in such cases written approval shall always be obtained inadvance from senior management. The employee must display similar caution aboutaccepting gifts or entertainment from public servants.
Expenses in connection with gifts andentertainment shall be treated in accordance with the relevant accounting andtax legislation.
Use of intermediaries
All agreements between NSE and anagent, consultant, lobbyist and others acting as an intermediary between NSEand a third party shall be in writing and describe the real relationshipbetween the parties. There must be correspondence between agreed remunerationand the described service that is delivered.
The contract must contain arequirement that the intermediary complies with NSE’s ethical guidelines. Theguidelines shall be reviewed with the intermediary before the contract issigned, with a particular focus on the ban on corruption. The contract shallspecify that NSE shall have full right of inspection of what the intermediarydoes on the company’s behalf, including the right to audit the intermediary,and that NSE is entitled to cancel the agreement if corruption is uncovered.
NSE may only make use of lobbyists toinfluence decisions in the public or private sector if the lobbyist informs theperson whom NSE wishes to influence that he or she is representing NSE. Thecontract with the lobbyist must contain a clause obliging the lobbyist tocommunicate this information.
Obligatory background check ofintegrity
Before a contract is made with a newthird party, an Integrity Due Diligence check shall always be carried out ofthat business partner with regard to economic and reputational risk to NSE. Acontract shall only be made when the business partner satisfies NSE’srequirements for Integrity Due Diligence.
The Integrity Due Diligencerequirement applies in relation to all third parties, including partners,suppliers, consultants, agents etc.
2.5 Anti-money laundering
Money laundering is the processes of disguising the proceeds ofcrime in order to hide its illegal origins. Criminal proceeds include forexample money, assets, real estate or intangible property that are derived fromcriminal activity.
Money laundering is illegal and supports other criminal activitiessuch as drug trafficking, terrorism, corruption, human rights violations andtax evasion.
NSE shall comply with all applicable anti-money laundering laws.
2.6 International trade restrictions
Sanctions means that countries have imposed economic restrictionsthat affects business with specific countries, companies or persons.
Export controls means that certain items, technology and servicescannot be exported without permission or licenses from public authorities.
NSE shall comply with all applicable sanctions, trade restrictionsand export regulations in countries where it conduct business.
NSE shall screen business partners, suppliers and other partiesagainst relevant sanction list before entering into contracts. If it isrequired, governmental licenses shall be obtained.
2.7 Correct information, accounts andreporting
All transactions shall be documented and posted in the accounts.Accounting information shall be correct, documented and registered inaccordance with the relevant regulations.
NSE shall provide complete, precise and comprehensible informationin its financial reports, also in its documentation and communication vis-à-vispublic authorities. The employee shall exercise the greatest care in thepreparation of this material.
2.8 Security
NSE shall secure its own facilities and assets, including thereceipt and dispatch of materials and equipment. Employees shall contribute tomaintain proper security measures to safeguard tangible and intangible assets.
2.9 Freedom of Association
NSE respects the freedom of association and the right tocollective bargaining and to form trade unions.
2.10Political activity
NSE is a politically neutral company. This does not prevent NSEfrom supporting political views that promote the company’s interests.
The employee may freely participate in political activities aslong as this happens without reference to the individual’s relationship withNSE.
2.11Sponsorship and donation
NSE does not make contributions to political parties, candidatesor persons. NSE may provide donations to non-profit organizations in line withthe company’s values upon written approval.
2.12Community
NSE respects human rights of the local community members affectedby our business. We will respect the local community and work according tointernationally recognized principles to seek to prevent and mitigate adverseimpact on local community.
2.13Child labour
NSE does not employ persons below 15 years or higher if mandatorylaw requires other higher minimum age. For persons under 18 years NSE shallsecure that they do not perform hazardous work or work that may interfere withtheir mandatory schooling.
2.14Modern slavery and forced labour
NSE is against all forms of human trafficking and forced labour.No one shall perform work for NSE unless it is voluntary, based on true andtransparent conditions without any form for mental, physical, financialcoercion or threat of any penalty or sanctions.
3. Personalbehavior
3.1 Equal treatment
NSE shall show respect for allindividuals and desires an inclusive workplace culture and is working activelyto promote a good working environment. All employees shall be guaranteed payand working conditions that prevent social dumping.
The company does not accept behaviorthat colleagues or business associates may perceive as threatening ordegrading, including harassment and bullying.
NSE does not tolerate any form ofdiscrimination based on the ground of for example gender, race, skin colour,religion, ethnicity, marital status, sexual orientation, political view, unionmembership, nationality, health status, disability or age. For example NSE does not accept any form ofdiscrimination
of colleagues, customer employees, or suppliersbased on ethnic background, nationality, age, gender or religion. Everyoneshall be treated with respect and not in any way be hindered in the fulfilmentof their obligations and responsibilities.
3.2 Non-disclosure
The duty of non-disclosure shallensure that unauthorised persons do not gain access to information that candamage NSE’s business activity or reputation. Sensitive information relating toemployees, business, commercial, technical, contractual or safety-relatedmatters and other confidential information shall not be disclosed tounauthorised persons. The same applies to information that is protected by law.
The duty of non-disclosure continuesto apply after the employment relationship or assignment has been concluded.
3.3 Protection of NSE’s property andresources
NSE’s know-how, production methodsand ideas are fundamental to the company’s success. The employee must protectthis knowledge and only make use of it in the company’s interests.
The employee must treat and storeNSE’s assets, for example equipment, computers, software, information andproperty in a proper manner and secure them against damage, misuse and theft.Use of NSE’s buildings, equipment, materials, capital and other assets forpurposes not directly related to the company’s operations without permissionfrom senior management is prohibited.
Employees are responsible to ensurethat documents used to obtain refund or any other payments from NSE is accurateand complete.
3.4 Conflict of interest
The employee must not become involvedin relationships that can or, or can be perceived as being, in conflict withNSE’s interests.
The employee may not take on assignmentsfor or have ownership interests in competing enterprises or with customers orsuppliers.
No employees may work with or processcases in which they themselves, their spouses or partners, or other closeassociates, have direct or indirect financial interests, or cases in whichthere are other factors that may undermine confidence in the employee’simpartiality or the integrity of the work performed.
The employee may not take on paiddirectorships, appointments or assignments for companies other than NSE withoutthe approval of NSE.
No one in the organisation is allowed to achieveunreasonable benefits as a result of unethical or illegal means, by coercion,secrecy, or abuse of confidential information or other dishonest methods. Ouremployees will not take part in or seek to influence any decision incircumstances that can give rise to an actual or perceived business or personalconflict of interest.
3.5 Inside information
By inside information is meantprecise information that can affect the price of securities and is not publiclyavailable or generally known in the market.
The employee must keep insideinformation confidential and prevent it from becoming known to unauthorisedpersons. Employees who possess inside information about NSE or other enterprisesmay not trade in the relevant securities, neither for their own account nor onbehalf of others.
3.6 Purchase of sexual services etc.
NSE is opposed to the purchase ofsexual services including purchasing or sharing child pornography. Such conductis a criminal offence and can damage NSE’s reputation. The employee shallrefrain from purchasing sexual services when he or she is working for or onassignment for NSE.
This also applies to the employee’stime off during assignments for NSE. In this connection, the employee must alsorefrain from participating in events that may put NSE or any businessassociates in an unfortunate light.
3.7 Alcohol and drugs
NSE is an alcohol and drug-freeworkplace. No one shall consume or be under the influence of alcohol or drugsduring work for NSE. The use of drugs or alcohol outside working hours that canaffect absence, the performance of work or safety is not permitted. Thisincludes hangovers and smelling of alcohol. The same applies to employees oncall.
Limited quantities of alcohol maynevertheless be served and consumed when local customs and special occasionsmake this appropriate, provided that it does not compromise performance orsafety.
Employees on assignment atinstallations with a general prohibition against alcohol and drugs must complywith the rule throughout their stay.
No employee shall use, or encourageothers to use, alcohol or drugs in a manner that may put NSE or any businessassociates in an unfortunate light.
3.8 Use of the internet and social media
NSE expects the employee to actloyally and be a good ambassador for the company in his/her use of the internetor social media. The employee shall have a conscious attitude to whatinformation is posted on the internet and social media, and whether it can beperceived as being offensive or in conflict with NSE’s interests. In-houseinformation for own employees shall not be posted on the internet. Any internalchallenges and matters relating to NSE shall be discussed within the company,not on the internet.
3.9 Contact with the media
To ensure coordinated contact withthe media, all enquiries from the media relating to NSE’s activities oremployees are coordinated with the top management. If employees are directlycontacted by a journalist, the journalist shall be referred to the NSE’s topmanagement.
3.10Privacy and data protection
NSE only process personal data forappropriate purposes. Employees shall only use personal data in accordance withapplicable privacy and data protection laws and internal regulations.
3.11Use of IT-systems
NSE’s IT systems shall only be usedfor business purposes for NSE. Private use shall be limited to a minimum and incompliance with internal ITguidelines. Information produced and stored in ITsystems is NSE’s property. NSE’s system and equipment shall not be used forillegal or unethical activities including offensive material.
4. Dealing withethical challenges
4.1 Internal whistle-blowing
Employees who discover reprehensiblematters are encouraged to blow the whistle on this. By reprehensible matters ismeant all criminal offences, violations of acts, internal guidelines or otherethical norms, e.g. bullying, sexual harassment, discrimination, alcohol ordrug abuse, a bad working
environment, matters that pose ahazard to people’s lives and health, hazardous products, embezzlement, theft,fraud, corruption, misappropriation of funds etc.
Matters that the employee believesare reprehensible based purely on his/her own moral or political convictionsare not normally covered by this provision.
Personnel-related matters shall bebroached with the employee’s immediate superior or the HR department.
Reprehensible matters shall as far aspossible be reported internally to the immediate superior. If the immediatesuperior is involved in the basis for the whistle-blowing or thewhistle-blowing is not dealt with by the immediate superior, the whistle-blowercan contact a superior. The whistle-blower can also contact the employeerepresentative system or the HR or HSE/Q manager, who can pursue the matter onhis/her behalf. If it is not expedient to blowthe whistle internally up through the line, employees can contact the externalwhistle-blowing desk.
If the whistle is blown in channelsother than those mentioned above, the matter must be brought to the correct channel by the employee/manager who receives notice of it.The whistle-blowing desk may be reached via NSE’s Intranet. See NSE’swhistle-blowing (censurable conditions) procedure for further information andprocedure.
NSE shall not undertake any form ofnegative reactions or sanction against employees who blow the whistle onreprehensible situations in a proper manner. NSE will process all reports in aproper manner.
4.2 Helpline
The ethical guidelines set theframework for what NSE regards as ethical behavior, but are not exhaustive. Theemployee shall always endeavour to exercise sound judgment. If in doubt as towhether a given activity is legal or ethically acceptable, the employee shouldconsult his or her immediate superior or NSE’s HR or HSE/Q manager.
4.3 Reactions to violations of theethical guidelines
Violation of the company’s ethicalguidelines will not be tolerated. Violation of the guidelines may constitutegrounds for internal disciplinary measures, termination or summary dismissaland reporting to public authorities and/or police.
4.4 Liability disclaimer
None of the provisions of thisdocument are intended to be construed in such a way as creating any rightsenforceable by a third party.
4.5 How to solve ethical dilemmas
Making the correct decision whenfacing an ethical dilemma may be a challenge. Below you will find somequestions you should ask yourself before making such a decision.
· Isthis legal?
· Isthis in accordance with NSE's ethical guidelines, vision and values?
· Isthis in accordance with NSE’s business strategy and goals?
· Areyou comfortable with the situation?
· Doesthe decision affect NSE’s reputation?
Helge Olsen ThomasJakobsen Berglund
Managing director Union leader
