A culture of compliance is fundamental to protect our company values and our reputation in the market. Compliance is about operating within the legal framework of the countries in which we operate. Our objective is complete and absolute compliance. By allowing minor deviations or exceptions we legitimate more serious violations of the laws. Consequently, we do not distinguish between important laws and less important laws.
The term ‘laws’ should be taken to mean statutes/acts, regulations and government decrees at national and local level. Furthermore, we expect that you comply with our own internal policies and procedures. These guidelines are intended to help us comply with laws, fulfil important company objectives and make our teamwork easier. Such ‘company laws’ must be studied and complied with.
Compliance requires commitment. We expect you to seek guidance and obtain legal advice if you ever find yourself in a situation where you do not know whether your acts are legal. You should not operate in ‘grey zones’ and expose yourself and the company to unnecessary risks.
Regulatory compliance is a joint responsibility. For the purpose of this Code, we would like to remind you of certain legal obligations that are especially important:
For certain areas, such as trade sanctions compliance, our company may have decided on more strict policies than is required by national laws. The reason may be that we operate in various regions and for company reasons have decided to adhere to other laws than those applicable in our home country. Where differences exist between the standard of the law or regulations and the requirements of the Code concerning our internal policies, the higher standard will be applied.
Our goal is to recruit, develop and retain the best people, and we want a creative, diverse and inclusive working environment.
We want our employees to perform to their full potential and to be recognised and rewarded fairly for their performance. To help you aspire and perform to your full potential, colleagues may give honest feedback in a constructive and respectful way. Management also welcome and encourage input from our company’s employees.
We want to ensure that the workplace is safe and free from harassment, discrimination and bullying. We will never tolerate any form of abuse or harassment of our colleagues, contractors, suppliers, customers or anyone whom we deal with.
We will treat everyone with courtesy and respect, regardless of race, gender, national or social origin, disability, sexual orientation, religious belief or political opinions, or other status.
We believe everyone should have equal opportunities. We recruit, select, train, promote and reward our employees on merits, and irrespective of their race, gender, national or social origin, age, disability, sexual orientation, religious belief or political opinions. All employee-related decisions will be based on qualifications, demonstrated skills, achievements or other professional criteria.
We also expect our contractors, suppliers, customers and other business partners to pursue similar fair treatment and equal opportunity standards in respect of their employees. The term ‘contractors’ should be taken to mean both those working within our organisation as hired staff and those working on behalf of any supplier or service provider.
You should never:
For more guidance, please consult our employment handbook.
We strive to have a healthy workforce and a safe working environment, and we are committed to safeguarding the health and wellbeing of all our employees.
The company will always comply fully with all applicable laws and regulations relating to workplace health and safety. You must familiarise yourself, and follow, all policies and procedures that apply to your line of work.
All employees must follow company guidelines and instructions from management and co-operate with those responsible for ensuring that applicable health and safety requirements are observed. In certain projects we may also be requested to comply with instructions from other companies, such as the client or the operating company. It is important to comply with such instructions and you should be aware that failure to do so may be causing injury or damage if anything goes wrong.
Health and safety concerns, work-related injuries or illnesses must be reported immediately. Any employee who is aware of a potentially dangerous situation or a ‘near miss’ incident should also report this without delay. You may always report such concerns to your line manager or by following the company’s whistleblower procedures.
Being under the influence of alcohol or drugs, or the misuse of medications, affects our judgement and performance at work and will not be tolerated in the workplace. It may also affect your safety and the safety of your colleagues.
Only undertake work that you are qualified to do and if you are sufficiently fit, prepared and rested. We always take the time to plan or work properly and to make sure everyone involved fully understands all aspect of our activities and also of any other activities that might be on-going at the same time and have the potential to impact our activities.
As an employer, we will ensure that:
As an employee you must always use the protective equipment and clothing provided by the company, as it is provided to prevent risk of accidents or adverse health effects. You have a duty to study the requirements for the use of protective equipment and clothing for the various operations you are involved in.
You are required to be careful about your own health and safety. You have an absolute duty to stop any work that you believe is unsafe, may harm your own or other people’s health or result in an accident.
We always take care to protect our business assets and information of a confidential nature.. We also respect the intellectual property and protected information of others.
As a company, we are committed to properly managing our records and complying with legal, financial and regulatory requirements. We are committed to disclosing the company’s dealings in a transparent and accurate manner, and to providing financial statements or other public records as may be required by law.
We also safeguard access to, and the appropriate use of, the company’s information and IT resources.
We are all responsible for making sure our assets are not misused or wasted. Examples of misuse are thefts of supplies, equipment, documents, cash or other property.
In particular, you should ensure that you:
All media contact is to be coordinated by the CEO or by a person with delegated authority to give statements on behalf of the company. You are not allowed to give statements to the press about company matters without prior approval.
We are committed to protecting the fundamental human rights of anyone affected by our operations. This is of particular importance where we operate in areas and regions with poor living standards and a weak protection of human rights by the national authorities. We recognise that the respect for human rights is a global standard and that upholding such rights is a responsibility to be expected of all businesses wherever we operate. This standard applies over and above national laws and ensures that people’s fundamental rights are protected even if local laws and local standards fail to do so.
The respect for human rights implies that we will:
Human rights are defined by conventions and principles, such as the United Nations International Bill of Human Rights and the ILO Core Conventions of Labour Standards. As a company, we are committed to complying with the United Nations Global Compact Principles (UNGC). By expressing our support for UNGC we are committed to upholding ten internationally recognised principles in the areas of human rights, labour standards, environmental sustainability and anti-corruption. We expect you to familiarise yourself with the ten UN Global Compact Principles (www.unglobalcompact.org).
Furthermore, we understand that the protection of human rights is not only the responsibility of states and governments. As a company, we are committed to avoiding adverse human rights impacts through our operations, and in order to comply with this commitment we all have to comply with the company’s Integrity Due Diligence (IDD) & Transparency Procedure.
Our goal is to make a positive contribution to the communities in which we operate by developing businesses, encouraging innovation and enhancing international competitiveness.
Illegal payments comprise all types of payments that are illegal under applicable laws. The term ‘illegal payments’ should be taken to mean not only corruption, but also embezzlement and fraud. Illegal payment will typically lead to the enrichment of a person or several persons at the expense of the company. In making an illegal payment you will most likely be acting against the best interest of your company. Such payments are strictly forbidden and will in most cases lead to the immediate termination of your employment.
Corruption is a threat to fair competition, and it undermines legitimate business activities. Any violation within our organisation will be a threat to our reputation and credibility in the market. Corruption is wrong and unacceptable, and no business advantage for our company will ever justify paying a bribe.
The definition of corruption may differ from one jurisdiction to another, however, the main concept is the same: giving an improper advantage to a person in the public sector or the private sector in the conduct of their duties is not permitted. Our policy is to comply with the Norwegian anti-corruption provisions, the UK Bribery Act (UKBA) and the US Foreign Corrupt Practices Act (FCPA). For this reason, you are prohibited from:
The company does not only prohibit active bribery, but also the acceptance or receipt of an improper advantage in connection with your position in our company. Never accept a kickback, “private commission” or money from any of our business partners.
You should be aware that it is not only the transfer of money that constitutes bribery. Also gifts, services, offering preferential terms for a product or a service, and travel and accommodation may in certain cases expose the company to a compliance risk.
It is also strictly forbidden to make any unauthorised transfer of money or anything of value from the company to yourself, to any of your close relatives or to any person acting on your behalf. Stealing company assets or funds will never be accepted.
For more guidance, please consult our: Anti-Corruption Policy.
Our business partners are important to the success of our company and we strive to build good and lasting relations with these partners. The term ‘business partners’ should be taken to mean our suppliers, contactors, joint venture partners, agents, customers, consultants, professional advisors etc. Our business partners and the conduct of our business partners may in some cases expose our company to reputational damage and other negative consequences. For this reason we must carefully select our business partners, especially business partners conducting services on our behalf.
The due diligence efforts needed in respect of a new business partner will depend on whether any risk factors or “red flags” are present. We expect you to:
The use of agents or intermediaries to obtain or retain business or to obtain certain permits from government authorities will in certain instances expose the company to an unacceptable level of risk. You should never engage an agent or intermediary to assist in business development or to achieve a result in relation to public authorities without prior authorisation from the CEO. For more guidance, please consult our: Integrity Due Diligence (IDD) & Transparency Procedure.
Conflicts of interest occur where our personal, social, financial or political activities affect the job we perform or our loyalty to the company. We expect you to always act in the best interest of the company, and not make decisions based on what will benefit you personally. You can also never use confidential company information that you receive as an employee of the company for your own personal gain or for that of others.
Wherever possible, conflicts of interest should be avoided. Sometimes the mere appearance of a conflict of interest can be harmful to the company. If and when a potential conflict of interest occurs, it is important that you recognise it, disclose it to your manager and ask for the appropriate guidance.
It can sometimes be difficult to identify conflicts of interest. You should ask yourself whether the situation affects how you perform your job or whether it affects the decisions you make for the company. You should also consider how the situation looks like from the outside. Would your colleagues or the company’s shareholders, contractors or customers think that the situation would influence the performance of your job for the company?
You should be aware that the following situations may create an actual or apparent conflict of interest:
You should always disclose actual or potential conflicts of interest to your manager.
We support fair and open competition in all markets.
We are committed to complying with all laws that prohibit behaviour that limits trade or restricts competition. Such laws are known as competition laws or antitrust laws.
We will not engage in any anti-competitive practices. Anti-competitive practices include agreements with a competitor to fix prices, to share or allocate markets, to rig bids or to limit or restrict supply to customers. It could also include agreements that impose restrictions on customers and suppliers.
Exchanging information may also be anti-competitive. You should therefore never share with a competitor competitively sensitive information, such as information about current and future prices, costs, strategies, customers or suppliers. Receiving such information from a competitor is also illegal. Such prohibition also applies when we participate in trade associations or joint ventures with competitors.
By way of example, you should never agree or signal your agreement to:
Penalties for breaching competition laws are severe and allegations of anti-competitive practices could harm the company’s reputation. Seek advice in all situations which you think may involve a risk of breaching competition laws – immediately report to management if there is a risk of exposure for the company.
We are all responsible for protecting the environment. As a company, we will comply with all legislation and regulations protecting the environment.
We are committed to ensuring that the environmental impacts of our operations are reduced wherever possible. We will monitor and assess the negative environmental impacts of our operations and will always address and seek to improve these. We are committed to pursuing best industry practice whenever possible. We strive to ensure the efficient use of natural resources and will consider environmental impacts when choosing a product or work procedure for a project we are engaged in. We will work to lessening our impact on the environment by trying to:
You should report any incident that occurs which may affect the environment or any apparent breach of environmental laws to management in order that management can investigate the incident and its cause, and take appropriate further action.
