NORDA is dependent on the world’s trust. Customers, suppliers, working partners, banks and insurance companies, government agencies, shareholders and the company’s own employees must at all times be able to have confidence in the company’s professionalism and integrity. This requires that the company as an institution conducts itself with due caution, integrity, competence and objectivity.

A company cannot command confidence, however, merely by acting in this manner as an institution. It is just as important that each and every employee act in a manner that is confidence-inspiring. Even though the laws of the land provide a legal framework for what is ”right and wrong,” each company must supplement this with its own ”rules of the road” that are adapted to its own business activities and to the company philosophy that the owners and the board of directors have decided upon.

The guidelines describe NORDA’s attitudes and requirements in matters of an ethical nature. This document applies to staff, board members, temporary employees, consultants and others who act on behalf of NORDA.

This document has been approved by the Board of Directors at NORDA ASA.

Definitions

The ethical guidelines are normative in determining what is right and wrong in relationships with other people. The guidelines must be viewed in relation to the company’s values and established norms.

Ethics is a set of norms and principles which serve as guides to the way people act.
Norms encompass every kind of behaviour that is expected, accepted or supported by the company.

Research ethics

All scientific activity at NORDA shall take place in line with relevant regulations and with research methodology that is internationally recognized. Any deviation from such practice must be clarified and justified.

To ensure quality, research must and shall be verifiable. Thus, findings shall be documented in a comprehensible and complete manner. Choice of method shall be justified and be grounded in scientific methodology. One must resist pressure from principals or others to modify methods, findings or conclusions. Such incidents must be brought to the attention of one’s superior. Findings are to be presented just as they are – nothing is to be added or subtracted. When making use of another researcher’s work, you are to let that fact be known and ensure that you have permission to use it. As far as possible, and consistent with the duty of confidentiality researchers have with NORDA, you are to strive towards getting your results published.

If an employee at NORDA feels that he or she has witnessed something that violates the ethical guidelines for research, they are to bring it to the attention of their immediate superior.

Business practices

Laws and regulations

You are to live up to the framework imposed upon the company by laws, regulations and the decisions of the owners.

Pursuant to current securities legislation and the rules for stock exchange listing, NORDA is obligated to give a complete, correct, precise and intelligible account in its periodic accounting reports, in documents that are submitted to supervisory authorities, and in other public communication. Employees – senior management and financial managers, in particular – are expected to exercise utmost caution in preparing such documentation and to pay special attention to the following:

• Generally accepted accounting principles must be complied with at all times.
• All NORDA’s accounts must be done and submitted in accordance with current laws and regulations applicable for the place and legal venue in question. They must not contain erroneous or deliberately misleading information. Furthermore, they must provide a correct, precise and detailed account of the company’s assets, obligations, income, expenses and all transactions and related incidents, which shall be documented in detail.
• No information shall be withheld from the external auditor.

Corruption

In all contexts it is forbidden to bribe or accept bribes or unreasonable gifts from clients, suppliers, government agencies or other interested parties. If anyone at NORDA should happen to be offered what could be perceived as a bribe, they must report it at once to their immediate superior.

It is not permitted to use consultants, agents or other mediators to channel payment to any of the mentioned interested parties.

Facilitation payments are smaller pay-outs intended to bring out products or speed up services to which one is rightfully entitled. NORDA is opposed to the use of this kind of pay-out and will act forcefully to prevent it.

Neither the company nor any of our employees must make financial contributions to political parties in NORDA’s name. This does not mean we cannot support political issues that coincide with our own interests, nor does it mean that our employees cannot become involved politically as private persons.

Fair competition

NORDA is a believer in fair and open competition. NORDA’s activities and NORDA’s employees shall not, under any circumstances, cause a breach in the rules of competition by, for example, illegal price fixing, illegal market sharing or any other kind of behaviour that prevents, limits or distorts competition in violation of current legislation on competition.

Loyalty

Conflict of interest/legal competence

The fundamental principle behind the rules of legal competence is that no-one must participate in or seek to influence a decision when the circumstances undermine trust in his or her independence. This might be a connection to a case at hand – for example, through kinship or financial interests – that could cause a colleague to focus on something other than the considerations that he or she should be safeguarding on behalf of the company.

A colleague shall inform his or her immediate superior as soon as he or she becomes aware of a conflict of legal competence. Board members are to consult with the Chairman of the Board. If legal incompetence is subsequently established, he or she must immediately desist from any further involvement with the matter in question. It must be stressed that this is the case even if the person concerned has not in actual fact allowed their views to be influenced by special interests. With regard to the rules concerning legal competence, it can be considered a breach if it is ascertained that there is a circumstance that could potentially undermine confidence in the person’s independence.

These guidelines can also be applied to ”close associates.” By this is meant the colleague’s spouse, partner, cohabiter, child(ren), close relatives or some other person with whom the colleague has close relations.

Board duties and other working conditions

Colleagues or close associates must not, without permission from their immediate superior, participate directly or indirectly (for example as shareholders), financially, in a working capacity, or as a board member in companies or institutions that are in competition with NORDA in a related line of business, or who have a customer/supplier or working partner relationship with NORDA. Investments that constitute less than 1% of shares in a listed company will not be considered a breach of these rules.

The company takes it for granted that a person’s work at NORDA is the employee’s primary occupational employment, unless otherwise agreed upon. Nevertheless, the company looks with favour on its employees being involved outside the company in their leisure time, within reason. Your superior must, however, be kept informed of any paid work or commercial activity outside the company.

Colleagues in NORDA must not have board memberships in businesses without their employer’s consent. Unpaid board membership of a private nature in connection with social/cultural purposes is, of course, exempt from this rule. It is expected, however, that any such board membership function will be conducted outside working hours.

Duty of confidentiality and discretion

Confidentiality is an important prerequisite for trust. Colleagues have a duty of confidentiality when, by virtue of their position, they gain knowledge of the company’s or its connections’ affairs. This applies not only to outsiders, but also to one’s own family, and to colleagues who have no need to know the information in question for the purposes of their work. This duty of confidentiality does not preclude a colleague informing his or her superior about circumstances in the company that are presumed to violate the law or these guidelines.

Everyone is obligated to exercise discretion in the safe-keeping and transmission of information concerning the company’s internal affairs by not discussing such information under circumstances where unauthorized persons could overhear it, and everyone must ensure that confidential information is not made available to unauthorized persons. Employees and board members shall not trade in, or give advice concerning securities in NORDA or any other listed companies on the basis of unpublished information to which they have had access by working at NORDA, and which could affect the value of such securities if the information was to be made public.

This duty of confidentiality continues to apply after you are no longer an employee of NORDA.

Information and IT systems

Everyone’s use of information and IT systems – Internet services, in particular – must be guided by commercial need, and not by personal interest.

Information produced and stored on NORDA’s IT systems is considered to be the company’s property. NORDA thus reserves right of access to all such information, except when this right is circumscribed by laws or agreements.

Each employee is responsible for keeping order in his or her electronic files and archives. Private use is permitted only when handling ordinary information, to a limited extent. Information that could be offensive or inappropriate shall under no circumstances be downloaded, stored or transmitted.

The use of software in violation of copyright laws is forbidden.

Acting on behalf of the company

No-one who is employed by the NORDA Group shall speak to the press before receiving clearance from the CEO. This is to ensure that senior management can at all times have an overview of what is happening in the Group, what is being said, and where the Group is being discussed in the media. This kind of coordination and quality assurance is meant to ensure that everyone at NORDA communicates the right values and message and is expressing the same picture of reality. Correct strategic communication and mention by the media is crucial to the company presenting a unified, uniform profile.

Safeguarding property and possessions

NORDA’s property and possessions are to be handled in a proper manner and shall only be used for the purpose they are meant to serve. Each employee shall protect the company’s property and possessions from loss, theft. damage or misuse.

Independence

Gifts and contributions

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 behaviour 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 at up to NOK 1000 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.

Representation

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. In such cases, the scope of the trip/event and the degree of relevant content will weigh heavily. The colleague’s superior will also decide whether the trip or event in question is to be considered a part of one’s work time or not. However, this point does not apply to the usual customer/supplier get-togethers, limited in scope, in connection with Christmas, anniversaries or similar.

Closely related parties

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

Personal circumstances

Private purchases

Colleagues must not purchase goods or services for private use at company expense or by using the company’s credit card, discount card or similar. This applies even when the person concerned intends to personally repay the bill later.

Respect for the individual

Equal treatment

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.

Tolerance

NORDA does 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.

It is everyone’s joint responsibility to do their best to create a good working environment of diversity and equal opportunity. It is expected that you will conduct yourself respectfully, considerately and courteously when dealing with colleagues and business connections.

Health, safety and external environment

Health, safety and environment

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.

Alcohol and narcotics

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.

Practice and follow-up

Duty to speak up and to seek advice

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/).

Personal responsibility

Everyone shall familiarize themselves with and carry out their duties in accordance with the requirements specified in this document, as well as in accordance with current laws and regulations.

Manager’s responsibility

Managers shall see to it that operations within their own sphere of responsibility take place in accordance with the requirements set forth in this document. This means that each and every manager is responsible for ensuring that all employees within their spheres of responsibility are given a copy of these ethical guidelines, and conduct information meetings on the subject. Managers shall also give advice on how to understand and practice the rules.

Consequences of violations

A breach of the company’s ethical guidelines or relevant statutory provisions can lead to disciplinary action, resignation, dismissal and being reported to the relevant government office. If an inappropriate practice or situation arises, the company will take the necessary steps to rectify the situation and prevent a recurrence.