Code of Conduct
Professional behaviour Guidelines for Norican employees
Introduction from Norican CEO, Anders Wilhjelm
Norican’s Code of Conduct (“Code”) sets the standard of behaviour we expect from all Norican employees. The decisions we make impact all of us, and we are all responsible for creating a culture where it is the norm to do the right thing, and where we take personal responsibility for our actions.
We are one global team respecting and enjoying local differences. We each take pride in acting as an owner of Norican, and being a good owner also requires being responsible corporate citizens. As responsible corporate citizens, we will play our part in leaving the planet in a better condition than when we inherited it. Playing our part also means making ourselves, but also our customers, better so we all can sustainably reduce waste and consumption, whilst always improving efficiency.
We do this by having outstanding technologies, products and services, a global and local infrastructure, combined with a humility to always strive to do better and to do more. We believe in equal opportunity and in diversity as drivers of good, and that being a good corporate citizen is an essential part of being an attractive company for all our stakeholders.
Our Code is guided by our Values Wheel:
LEADING for sustainability
We ensure the company’s long-term success and viability. We provide the offer of the future by innovating in all that we do. We embrace change. We develop the leaders of tomorrow. We proactively make choices to make Norican more successful.
RESPECTING and building on diversity and teamwork
It is our differences that make us strong. We should embrace these differences and allow diverse voices to be heard. Our leaders should come from diverse backgrounds and perspectives.
DELIVERING on commitments to all stakeholders
It’s important that we, as a business, keep our promises. We should increase the profit and sustainability of our customers, create a safe and enjoyable working environment, treat suppliers fairly and consistently, and increase returns in a sustainable and ethical manner.
DEVELOPING employee potential and excellence
Our employees (that means you!) are the most important and valuable resource we have. We are committed to investing in and growing your capabilities. We should give people the confidence and trust to make changes and reward achievers and learners.
Our Code will help us live up to our Values and will help guide our relationships with our customers, suppliers, partners, competitors, and the communities in which we operate.
Please read and understand the Code, and most importantly apply it. Our Code will only be effective if we all do this. We must also take responsibility for any breaches of the Code, or if we see, know
of, or suspect anything which might be illegal, unethical, or harmful. In these instances, please do speak up. Your concern will be taken seriously, and we will not tolerate retaliation against anyone who raises a concern.
Thank you for your commitment to our Values and our Code.
Anti-Bribery, Anti-Corruption, Gifts and Hospitality
How Norican does business, matters. Compliance with anti-bribery and anticorruption laws is essential to protect Norican’s reputation and to preserve our ability to do business globally, and we will comply with all such applicable laws. Our aim is to compete fairly, and we do not tolerate bribery, kickbacks, fraud, money-laundering, or any other improper payment.
Aside from being fundamentally wrong, bribery and corruption are also criminal offences, conviction for which is punishable by up to ten years’ imprisonment for individuals, and unlimited fines for businesses. If a business is found to have taken part in bribery or corruption, it can be excluded from tendering for public contracts and will seriously damage its reputation. We therefore take this very seriously and have a zero-tolerance approach to bribery and corruption.
All Norican personnel and all third parties acting on our behalf must conduct business honestly, with integrity, and in compliance with anti-bribery and anti-corruption laws. We must not give, offer to give, or accept any gifts, hospitality, entertainment, travel, accommodation, or anything of value, whether directly or indirectly, which may improperly influence our or others’ business decisions. Nobody within Norican has the authority to waive this requirement.
Facilitation payments and kickbacks must not be accepted or made. Making a payment or gift to a person to encourage them to act more swiftly may be customary in some parts of the world, however we will not tolerate any such gift or payment.
We recognise that giving and receiving modest gifts and entertainment in the ordinary course of business can help strengthen or develop working relationships. However, under no circumstance should the giving or receiving of such gifts or hospitality be done with a view to unduly influencing a business decision making process. Any such gift or hospitality must be reported to your line manager, and written approval from your line manager must be provided. A line manager’s record of approval may be requested as part of any internal audit. Pre-approval must be sought from Norican’s General Counsel for any gifts intended to be given to a government or government officials.
• comply at all times with our policies and procedures on anti-bribery, anti-corruption, gifts, and hospitality;
• not offer, or make facilitation or ‘grease’ payments, regardless of local custom or practice;
• not offer or make any payment to an intermediary or third party when we know, or can be substantially certain, that it will be used to make an improper payment;
• only accept or offer gifts of a modest value, and when it is lawful to do so, and where it cannot be construed as being capable of influencing any business decision;
• not make political donations or contributions on behalf of Norican;
• report any gifts or hospitality without delay; and
• speak up if you become aware of any breach or potential breach of anti-bribery and anti-corruption laws.
Further information on how Norican protects against bribery and corruption is available in the Norican Anti-bribery and Anti-corruption Policy.
Support and Assistance
This Code is not intended to provide an answer to every question or situation that may arise.
If you are unsure and need additional guidance, you can find more detailed information in the policies referred to in this Code, which are available on the intranet.
If you have any questions about this Code please contact the General Counsel, at email@example.com.