The purpose of this policy is to provide information to our stakeholders about NORDA’s approach to Corporate Social Responsibility (CSR). The document defines the basic CSR principles of NORDA ASA, and outlines how the Company complies with them.

As an active player in the national and international biotech market it is of high importance to NORDA to implement the focus on social responsibility in the operations and activities of the Company. Guiding principles for the NORDA’s CSR work are integrity and transparency. NORDA aspires to achieve sustainable development, i.e. to strike a balance between financial results and corporate social responsibility (CSR). The value created is to benefit owners, customers and other stakeholders.

NORDA’s CSR objective is, in addition to dealing with internal issues within the area of employee rights and working conditions and external issues like environment and climate, to understand and deal with the local and global challenges that society faces in the geographical areas in which NORDA operates. The Company shall strive to ensure that the suppliers and other partners honor fundamental principles for corporate social responsibility that coincide with NORDA’s principles.

Human rights

NORDA’s current activities are not of a nature that presents any significant challenges related to human rights. However, more international activities entail more exposure, either directly through our own operations or indirectly through our value chain. NORDA supports the principles of UN’s Universal Declaration of Human Rights and to ensure that operations are performed in accordance with these rights, all employees, board members and consultants of the Company are obliged to follow NORDA’s Ethical Guidelines (to be found at www.nordasa.com).

Discrimination:
The ethical guidelines state that NORDA acknowledges and appreciates the fact that each of us represents something unique and valuable and deserves recognition for our individual abilities. We do not condone any form of discrimination of colleagues, working partners, clients or other interested parties on account of religion, gender, sexual orientation, age, nationality, political views, population group, marital status, disability or other circumstance.

The ethical guidelines state further, that NORDA’s employees should not condone any form of harassment, discrimination or any other conduct that could be considered threatening or disparaging by one’s colleagues or by our business connections. This also means that one must respect and show consideration for other cultures and customs. Everyone is encouraged to participate in a multifarious working environment and thus do their part to ensure that general and special skills will give us good risk control and lasting value creation.

Buying sexual services:
NORDA’s ethical guidelines state that the employees of the Company shall not buy sexual services when representing NORDA on business trips or other assignments. In addition we are clearly opposed to any kind of trafficking.

Child labour and compulsory labour:
The nature of NORDA’s operations means that issues related to child labour and forced and compulsory labour are of little relevance. We are surveying the situation in the value chain. There have been no reports of cases related to these topics.

Use of security personnel at the international level:
Thus far, the nature of our international operations has not required the use of special security personnel to ensure our employees’ safety.

Indigenous rights:
NORDA has not been involved in violations of indigenous rights.

All NORDA’s employees have been trained in the ethical guidelines, and have received information about the Corporate Social Responsibility Policy and the UN’s Universal Declaration of Human Rights. Breaches of human rights shall not occur at NORDA.

Anti-corruption

Corruption poses a threat against commerce and society in all countries, encompassing a wide variety of activities whose purpose is to obtain illegal advantages. Corruption shall not occur at NORDA.

To ensure independent action of the NORDA staff and the Company as such in any situation of purchase and sale, NORDA’s Ethical Guidelines state some rules of independent behavior. As a rule, no employee shall receive any financial benefit from any of the Company’s connections. Nor must colleagues ever receive gifts in any form in connection with negotiations or as a token of appreciation for a specific contract or behavior from the Company’s side. If a colleague receives a gift of a certain value, or discovers that he or she will be offered such a gift, that person’s immediate superior is to be notified and is to determine whether the colleague’s independence would be threatened if the gift was accepted or kept. This point does not, however, apply to the usual tokens that are given, within a reasonable scope, in connection with Christmas, anniversaries, trips, company visits and the like. Gifts valued up to NOK 1.000 per calendar year may be accepted in this connection (cf. the Tax Act). Gifts in the form of cash are always prohibited.

As a rule, colleagues also must not accept discounts for personal purchases of goods or services from the Company’s connections. The same thing applies to “close associates”, when the gift or benefit in question is presumed to be related to the colleague’s position as an employee of the Company.

Colleagues who are offered the opportunity to participate in trips or events paid for by the Company’s connections shall, if they wish to participate, obtain approval in advance from their superior.

As far as possible, spouses, persons living together on a regular basis, or family members (father/mother, son/daughter) should not work together in the same unit. They are not to have positions where one of them is the other’s immediate superior.

As a rule, other suppliers than friends and family are to be chosen when purchasing goods and services. When purchasing from closely related parties, extreme caution shall be exercised, and one’s immediate superior must always be involved.

Employee rights and working conditions

NORDA’s employees will be challenged to use their skills and abilities to contribute to the Group’s progress as well as to their own development. They will be taken seriously, treated with respect and given orderly working conditions.

NORDA shall be a corporation with an abundance of diversity. Naturally, health and safety will be given priority and all NORDA’s employees will enjoy equal opportunities. The EHS Handbook enables NORDA to work systematically on issues regarding Environment, Health and Safety, in accordance with internal goals and public demands. The routines, charting methods, forms and action plans of the Company are saved in a system that fulfils the documentation demands of the Internal Control Regulations. The texts in the Handbook are hyperlinked to relevant laws, regulations and directives, so that any update is immediately intercepted by the Handbook.

The EHS Handbook and the internal control system shall contribute to a better working environment and safety for all employees. It should help preventing health damage or environmental disorder from products or services and it should protect the external environment towards pollution and improve waste handling.

A systematic improvement work is based upon experiences and follow-up. To succeed it is of importance that both the management group and the employees take an active part in this work. All of NORDA’s employees have a joint responsibility to ensure that work is done under safe conditions and in a manner that safeguards and promotes the health and well-being of individuals and safeguards the environment. Each colleague is responsible for following local procedures and regulations, as well as for notifying his or her immediate superior about accidents or the release of any toxic substances.

It is forbidden to be under the influence of alcohol or narcotic substances at the workplace. The use of alcohol on NORDA’s premises is prohibited, except for controlled consumption at social gatherings approved by management or one’s superior. It is strictly forbidden to be in possession of, use, sell, purchase or give away narcotics at any of NORDA’s locations.

The loyalty requirement obligates everyone at NORDA to speak up when they discover anything unethical or illegal, and to seek advice when confronted by an ethical dilemma. In such cases, the matter is to be taken up with one’s immediate superior, the CEO, or Chairman of the Board. An employee may also notify management internally through his or her union rep (shop steward), safety deputy or a colleague. The Directorate of Labour Inspection’s guidelines for notification are normative when giving notification about blameworthy circumstances in the company (cf. http://www.arbeidstilsynet.no/).

Quality Assurance extends throughout all functions and departments in NORDA for greater company efficiency and to ensure continuous improvement of our Quality Management System, products and customer services. NORDA’s Quality Management system is designed to supervise the products’ entire lifecycle, from the idea of a new product, the systematic and controlled development of the product to the production, release processes, sales, support and maintenance of the product in the post market phase. This results in high safety, a high product and service quality, as well as satisfied customers, employees and investors.

Climate and the environment

NORDA shall act responsibly with a view to the footprint left by our activities on the external environment. This means we will strive to reduce harmful direct and indirect influences on the external environment. NORDA has composed its own Environmental Policy (to be found at www.NORDA.com) and aims to be conscious about the way its business and operations affect the environment and tries to make the environmental influence as gentle as possible. Pollution is to be prevented and environmental legislation to be complied with.

The Board and the Management Group are responsible for the Company’s influence on the environment and for the compliance with rules and regulations. In the course of their life cycle NORDA’s products shall affect the environment to the lowest extent possible. NORDA is careful when it comes to use of solvents, reagents, energy, water and materials. Normal operations do not involve risk of pollution from the laboratory. Processes that include use of potentially dangerous substances take place in closed systems, and such substances are sorted out and treated as special waste. NORDA has made arrangements with approved waste return companies to ensure secure handling of special waste, and to prevent that potentially dangerous substances go astray.

NORDA’s instruments are produced in compliance with the RoHS Directive (2002/95/EC), and the Company’s handling of disposal of instruments is in accordance with the WEEE Directive (2002/96/EC)

NORDA tries to encourage its employees to a restrictive use of copy/printer paper. One example is that the Company’s quality system of manuals and SOPs is electronically based, and does not exist on paper. Another example of saving copy paper is the invoice system – the company is in a process of implementing an electronic system for this. NORDA wants for its staff to focus on the respect of the environment, and the company therefore encourages to a continuous improvement in this field and to think creatively when it comes to environmental friendly actions.

Follow-up

We will ensure that our work to promote the corporate social responsibility is planned in a professional manner and integrated into the Group’s business strategy, becoming part of the Group’s business planning and follow-up routines.

NORDA’s CSR policy has, in its entirety, been discussed and approved by the Board of Directors.