Code of Conduct
Purpose
Scope and responsability
Code of business practice
1. Compliance with laws, regulations and internal working practice
2. Combating corruption and fair competition
3. Relations with suppliers, partners and customers
4. Strengthening human rights
NORSE supports and respects internationally proclaimed human rights including the UN Declaration and Convention on human rights, and acknowledge all employees’ right to form and join trade unions of their own choice.
NORSE employees shall expect a workplace free from harassment and discrimination. NORSE will not use child or forced labour, and will not tolerate working conditions or treatment that are in conflict with either international laws and practices or our internal standards.
NORSE shall ensure that the company, through its operations, does not cause any infringement of human rights. The company shall address and minimize risks of human rights infringements in the supply chain, in the projects where we contribute as a supplier and all other parts of our operations.
5. Ensuring equality and diversity
NORSE will show respect for all individuals and make active efforts to ensure a good working environment characterised by equality and diversity.
NORSE does not accept any form of discrimination of its own employees or others involved in our activities. It may, however, sometimes be legal and justifiable to use positive discrimination to achieve equality and diversity. Discrimination includes all unequal treatment, exclusion or preference on the basis of race, gender, age, disability, sexual orientation, religion, political views, national or ethnic origin or other similar circumstances that result in the setting aside or compromising of the principle of equality.
6. Monitoring and handling of breaches
Infringement of laws and regulations applying to the business and the execution of such, or violation of instructions and regulations is regarded as a breach. All breaches will be recorded, and appropriate actions will be performed by NORSE.
Where a conflict of interest is notified, the manager shall ensure that the conflicted individual is isolated from any operation, influence and/ or decision- making process associated with the subject of the conflict.
All directorships, employment or other assignments held or carried out by NORSE employees in other enterprises, which have, or may expect to have, commercial relations to NORSE, must be approved in writing by NORSE.
NORSE’s Code of business practice stipulates how all our people are expected to behave, act and react to all planned and unforeseen situations, which might occur.
7. Combating bribery and handling of gifts and hospitality
Bribery and facility payments
It is your responsibility to make sure that all payments made are proper and legal, that relevant NORSE personnel approve them, and that they are recorded accurately in appropriate records.
You must not (either directly or indirectly through a third party) offer anything of value to improperly influence the actions or decisions of any person, including any government employee or official or private party, in pursuit of NORSE’s interests.
Dealing with public officials requires extra caution when it comes to corruption risk. As a representative of NORSE, you shall not, in order to obtain or retain business or other improper advantage in the conduct of business, offer, promise, or give any undue advantage to a public official to make the official act or refrain from acting in relation to the performance of her/his duties. This applies regardless of whether the advantage is offered directly or through an intermediary. Particular caution must be exercised regarding hospitality and entertainment provided to a public official.
Facilitation payments shall not be made by any person acting on behalf of NORSE, even if not considered to be a criminal offence under certain jurisdictions. If a payment is demanded from you in order to avert an immediate threat to the life or health of any person, such payments are not prohibited, but they must be immediately reported.
Gifts and hospitality
NORSE does not allow gifts and hospitality where giving or accepting them could influence business decisions or enforcement of regulations, or cause others to perceive such influence. As a company, we do not expect gifts or hospitality from any of our business partners. Gifts and hospitality may be accepted or offered when this is expected as common business courtesies, however, only when aligned with regulations.
In principle, gifts shall not be neither offered nor accepted. Expensive gifts are never acceptable, while modest gifts in some situation may be accepted if they can be expected as common business courtesy, but shall be reported to the nearest manager or director.
Hospitality, expenses, or other favours shall not be offered or received where it could be perceived to influence decision-making in situations of contract negotiation, bidding, or award.
8. Integrity and handling of information
Conflict of interest
A conflict of interest occurs when your personal relationships, participation in external activities or interest in another venture can influence or could be perceived to influence your decisions when acting on behalf of NORSE.
It is your responsibility to avoid conflicts of interest. You shall act in the best interests of NORSE and take appropriate steps to avoid situations and positions that may create or appear to create conflicts of interest.
If you believe there is an actual or potential conflict of interest, you shall notify your manager in writing and disclose all relevant facts. You shall not participate in any transactions or other business arrangements on behalf of NORSE where you directly or indirectly have, or could reasonably be suspected to have, a personal interest, financial or otherwise, or that could otherwise reasonably be considered to harm NORSE’s interests or reputation.
Business transactions must be entered into solely for the best interests of NORSE. You shall not, directly or indirectly, benefit from your position as an employee or from any sale, purchase, or other activity of the company. Persons subject to this Code of Conduct shall avoid situations involving a conflict or the appearance of a conflict between their duty to the company and their self- interest.
You must not have interests outside the company in any business that competes with or provides services to NORSE or its subsidiaries, and/or that would affect your objectivity in carrying out your responsibilities.
You shall avoid doing business on behalf of NORSE with a close personal friend or relative; however, recognizing that these transactions do occur, any such conflict of interest that cannot reasonably be avoided, shall be made transparent and reported to your manager in writing.
Insider information
You must protect confidential business information and never use it for your own benefit, in particular when trading in shares or other securities or recommending anyone else to do so. Insider information can only be shared with individuals who are authorised and need this information in their work for NORSE.
You must not spread rumours, mislead with false information or manipulate prices.
Money laundering
You must conduct appropriate counterparty due diligence to understand the business and background of our prospective business partners and to determine the origin and destination of money and property.
You must not deal with payments in cash, which could be perceived to be generated from criminal conduct.
You must exercise specific caution if there are irregularities in the course of receiving payments.
9. Publicity and media relations
All inquiries regarding NORSE or any of our business partners or projects shall be referred to the Public Relations department and be handled by the CEO, or other individuals who have been specifically designated to speak on behalf of NORSE.
All public statements must be professional and accurate and seek to share all available information regarding the matter at hand, thus contributing to a transparent and objective coverage of the matter at hand.
10. Reporting / Notification of breach
Corporate Social Responsibility (CSR) Policy
Purpose
NORSE contributes to sustainable development through our core activities and the use of our products and services. Our products and services contribute to more efficient operations, reduces environmental impact and we use natural resources efficiently.
NORSE is committed to operationalise our values and ethical conduct, strengthening the respect and dignity of individuals we affect.
This document describes the main principles that the owners, managers, and employees in NORSE will follow in order to incorporate socially responsible conduct. Ethical behaviour and social responsibility is ingrained in all our activities and decisions, and shall be fronted by all our people.
ISO 26000 is used as the framework for our CSR efforts.
Key CSR principles
1. Sustainability
2. Human rights
NORSE respects human dignity and supports the principles of the Universal Declaration of Human Rights. We will ensure that our business activities exercise due care with relation to human rights, and handle risk situations associated therein.
We have a fundamental respect for all individuals, and will not accept any discrimination based on sex, race, religion, sexual orientation, age, ethnicity, political opinion or any other factor.
We find child labour inacceptable and will avoid suppliers who practice this.
3. Working conditions
NORSE will ensure appropriate and safe working conditions. Working conditions must adhere to national laws and regulations, and in the case of international involvement, be consistent with current international labour standards. The company will develop, implement and maintain guidelines for the working environment, based on working environment requirements, identified areas for improvement, challenging objectives and performance monitoring.
We acknowledge the importance of having strategic dialogue with key groups and organisations and seek to establish collective negotiation structures between the parties in the workplace where natural.
We shall not benefit from working relationships with partners, contractors, or subcontractors who base their practice on injustice, exploitation, or abuse.
4. Environmental protection
5. Reputable business activities
NORSE will in all decisions, activities and communication maintain a high standard of integrity and transparency through maintaining best business practices and our focus on continuous improvement. We shall be acting comfortably within our values and ethical standards and within the law at all times. This means that we will be demanding, honest and reputable in our business activities, and in competition with others. We require high ethical standards of our people and everyone who acts on our behalf.
We will ensure anti-corruption and transparency on all sustainability issues and actively engage with key stakeholders.
6. Social commitment
NORSE wishes to make a positive contribution to society and the local community. This kind of commitment could, for example, be in the form of partnerships, voluntary work, local recruitment, involvement in education and culture, charity and sponsoring.
Health, Safety & Environment (HSE) Policy
NORSE is committed to protecting our people, the environment and our assets from hazards, accidents and harm.
No other aspects of our work is as important as safety, and no other aspects is given as much attention.
Safety of our operations, and in the use of our products, will never be compromised.
Key HSE principles
- HSE leadership – emphasise the importance of HSE by showing it inpractice through clear and visible leadership
- Working environment – create a safe and healthy working environment, enabling all our people to do their job in the best possible manner
- Training and necessary resources – provide our employees with the necessary framework conditions, resources, equipment and training to ensure safety in all our operations
- Planning and risk assessment – plan our work and carry out risk assessments to identify risks
- Mitigating actions – implement mitigating actions to reduce the risk to as low as reasonable possible
- Monitoring and continuous improvement – monitor and assess our safety performance to ensure continuous improvement
- Compliance – ensure that all our people understand their personal responsibility for conducting operations in a safe, environmental friendly and efficient mannerOur HSE policy is implemented at all levels in our organisation and is an integral part of all our operations.
Quality Policy
NORSE is committed to achieving a high degree of quality in all our activities, services and results.
NORSE is defined by the quality of our work, services and value delivered to our clients. We ensure high quality standards through our robust management system in which all processes, structures, procedures and deliveries are defined and described.
Key Quality principles
All persons working in or for NORSE are committed to:
- Quality leadership – emphasise the importance of quality in everything we do by living our values every day through clear and visible leadership
- Management system – ensure consistency and predictability through continuously improving our operations, and their description in the management system where responsibilities, accountability and mandates are clearly defined and understood
- Training and necessary resources – provide our employees with the necessary framework conditions, resources, equipment and training to ensure consistent high quality in everything we do
- Planning and execution – ensure proper planning and delivering rigorous execution, understanding and adjust to changes in the framework conditions we work under
- Monitoring and continuous improvement – monitor and assess our operational and quality performance to ensure continuously improving an effective business management system
- Compliance – be updated on and understand all requirements set by customers, contractors, ourselves, national legislation and international standards
- Stakeholder management – interact with suppliers, sub-contractors, customers, regulatory bodies and other relevant stakeholder.
Our quality policy is implemented at all levels in our organisation and is an integral part of all our operations.
We believe that a continuous focus on quality in everything we do, every day, is the best way to ensure quality deliveries to our employees, customers and shareholders.