6. Personal conduct
6.1. Discrimination and bullying
All Norvax employees have a shared responsibility for building a team spirit and a good working environment. The Companyexpects employees to behave with respect and consideration and to display common courtesy in relation to colleagues, competitors, customers and others. By being inclusive and committed, we make each other better. Discrimination and harassment must not occur. Anyone who feels that they are being discriminated against or harassed shall be taken seriously.
6.2 Relations with managers and colleagues
Norvax aims to create a positive, stimulating and enthusiastic working environment. Trust, respect, cooperation with and openness in relation to managers and colleagues are fundamental to achieving this goal. All Norvax’s employees have a responsibility for helping to create a good working environment.
6.3 Duty of secrecy
Employees have a duty of secrecy in relation to business matters and matters of a private nature relating to customers, employees and others that they become aware of in connection with the performance of their work for the Company. This duty applies unless they are legally obliged to disclose the information or are obliged or urged to report such matters pursuant to these ethical rules. The duty of secrecy does not only apply in relation to third parties, but also between the companies in the Company.
The duty of secrecy applies in relation to colleagues, advisers, family members and others ,unless the party entitled to confidentiality has expressly consented to the disclosure. The CFO or a person authorised by the CFO may, in specific cases concerning financial matters, consent to the disclosure.
The duty of secrecy also applies after an employee has left their job with Norvax.
An employee shall not actively seek information about other employees or about customers via the computer systems or in any other manner, unless this is necessary for the employee’s work in Norvax
An employee shall not actively seek information about other employees or about customers via the computer systems or in any other manner, unless this is necessary for his/her work in Norvax.
6.4 Relations with business connections
No one may act in a way that prevents them from acting impartially in relation to the Company’s customers, suppliers, shareholders or other business connections. Employees must exercise caution when entering into private agreements and exchanging services with companies and persons with whom they have dealings through their work for the Company. They must also exercise caution in relation to business agreements with persons with whom they have a private relationship.
Employees who have private relations with a business connection must notify their immediate superior.
6.5 Hospitality and events
Employees who, by virtue of their position, represent or can be identified with The Company must conduct themselves in a way that ensures the trust of both The Companyand other employees.
Events organised by The Companyshall be characterised by moderation and have a relevant and adequate professional content. If alcohol is to be served at a Norvax event, non-alcoholic options must always be available. Any costs of travel and overnight stays for external parties shall be covered by those parties themselves (either directly or through a participation fee).
Employees who are considering participating in trips or events under the auspices of Norvax’s business connections must clarify this with their immediate superior. Travel and stays in connection with the performance of work for Norvax shall, as a rule, be covered by the Company. Any deviation from this rule must be clarified with the employee’s immediate superior. This also applies to travel and accommodation in connection with seminars and other job-related events that are covered directly or as part of the participation fee.
Sponsor activities must be in accordance with Norvax’s sponsorship strategy.
Norvax has prohibited political donations, and full transparency is required about all payments that can be perceived as support for an organisation.
6.6 Gifts and benefits
Employees must exercise great caution with respect to accepting gifts or other benefits from customers, suppliers or Norvax’s business connections. Employees or their closely related parties (see section 6.8) may not receive gifts worth more than NOK/SEK/DKK 500 from any one party per calendar year. If there is a risk that an employee’s impartiality or independence can be put in doubt, the gift must not be accepted. If gifts are returned, this shall be done in a manner that causes as little offence to the donor as possible.
An employee must not accept gifts or services of any kind in connection with or prior to entering into negotiations or as a return favour for entering into business agreements on behalf of Norvax.
Corresponding restrictions apply when gifts are given to business connections. Norvax’s motives and the integrity of the recipient must be beyond doubt.
Norvax promotes transparency, and all gifts and hospitality activities must be registered in the Company’s gift register.
6.7 Family relations
As a rule, siblings, parents/children or spouses/cohabitants shall not work under the same manager (line manager) or in the same department. Potential situations of this kind must be clarified in advance with the HR department. Employees who are related to each other shall not obstruct, assess, approve, audit, check or in other ways influence the work of a relative.
No one may participate in or influence the handling of or decision in a matter where circumstances exist that could weaken trust in their independence.
No one may consider, decide or seek to influence a matter if they themselves or any of their closely related parties have any direct or indirect financial or other personal interests in the matter. By closely related parties is meant spouses, cohabitants and children, as well as any companies, associations, clubs etc. in which the employee or any of their closely related parties have a significant influence. Other personal relations may also by their nature be considered equivalent to closely related parties (for example neighbours, close friends etc.).
As a rule, if a superior is deemed to be disqualified on grounds of partiality, this also means that the matter cannot be decided by anyone reporting directly to them.
Employees shall inform their immediate superior as soon as they become aware that a conflict of interest may arise. The superior shall consider the risk of the employee’s impartiality or ethical integrity being put in doubt by other employees or external parties. In such a case, the employee in question must not participate in further consideration of the matter.
Employees must not use their position to influence appointments so that preference is given to a candidate on the basis of other criteria than those that are of direct relevance to the position in question.
6.9 Secondary occupation and participation in other companies and organisations
No employee may, without their employer’s consent, work for, serve on the board of, operate or have financial interests in undertakings that engage in the same type of business as one of the Company’s companies or that have business relations with such companies.
An employee whose primary position is with The Companyand who wishes to start a private business or take paid employment during their free time must ask the employer in advance. If the secondary job/office can be combined with fully satisfactory work performance and the position in the Company, the employee may be permitted to hold a secondary job/office. Managers must be informed about political offices, which are regulated by law, and arrangements must be made to minimise any inconvenience to the Company.
Employees must notify their immediate superior if they or any of their closely related parties have ownership interests in businesses with which Norvax has a customer or supplier relationship. If there is a risk that such ownership interest will give rise to doubt about the employee’s loyalty or independence, Norvax may demand that the ownership or customer relationship be terminated and set a deadline for its termination.
Unless express permission has been obtained from the employee’s immediate superior, employees in executive positions may not be a board member of or member with other responsibilities in a company engaged in business activity. Other employees may hold offices outside Norvax. If an employee is in doubt about whether such an engagement will affect their work in The Company or is in conflict with the Company’s values, they must raise the matter with their immediate superior. In cases where the company’s employees refer to Norvax in the media, The Company expects a courteous and loyal attitude.
6.10 Insider information and Security trading
Insider information is precise information that an investor is likely to use as the basis for investment decisions, and that could influence the price of the Norvax share upwards or downwards. No employee may use or contribute to others using insider information about The Company or other companies as a basis for trading in securities. This applies to both private trading and trading on behalf of the Company.
Private investments in securities must take place within a responsible financial framework. Norvax’s interests shall always take precedence over employees’ personal interests, and such interests must be kept separate.
Employees must not, on their own behalf or on behalf of closely related parties, use insider information
about possible securities trading by Norvax to trade in or give advice about buying or selling securities. Such information is confidential and will be considered a trade secret, and could also constitute insider information that triggers a statutory prohibition on trading and criminal liability.
Any doubts concerning insider information and securities trading must be raised with the CFO or Head of Investor Relations in advance of any trading.
Board members are referred to the rules on impartiality and the duty of secrecy; see Sections 9-5 and 9-6 of the Financial Undertakings Act.
6.11. Use of the Company’s equipment and property
No one may use the company’s data, IT equipment, material or other property to an unreasonable extent for private purposes or for activities that are not relevant to their work for Norvax. Equipment must not be used for computer games, gambling, pornography, to promote racism or for other purposes that can be perceived as offensive.
6.12 Orderly personal finances and financial situation
Norvax expects employees to have their personal finances in order. Employees who take up positions that confer powers to commit Norvax financially must expect the company to check their creditworthiness.
The Company expects employees to ensure that their financial obligations to Norvax are kept in order, and this also applies to customer relationships with the Company.
If an employee is exposed to strong financial pressure, this can be construed as weakening the Company’s respect and independence. Employees who realise that they will be unable to meet their financial obligations must inform their immediate superior of this, unless the financial situation is of a temporary nature.
An employee must not register or change the terms and conditions of their own or closely related parties’ insurance contracts or other agreements. However, this does not prevent employees from using the same service channels as are open to other customers.
If an employee’s insurance claim or attempt to take out insurance is rejected on grounds of insurance fraud, this may have consequences for their employment relationship. The same applies if employees behave dishonestly as customers in any other of the Company’s business areas. As customers of the Company, employees must conduct themselves in the same way as other external customers in their communication with the company. Internal communication channels or undue pressure must not be used.
Coverage of an employee’s personal expenses must be approved by their superior in accordance with authorisations.
Fringe benefits enjoyed by Norvax’s employees must not be exploited for other purposes than those forming the basis for the arrangement.
Participation in illegal gambling activities that entail financial risk is not compatible with Norvax’s activities.
6.13 Human dignity
Employees on service assignments or business travel must not behave in a manner that could violate human dignity. This means, among other things, that employees must not purchase sexual services.
Employees must not behave in a way that results in unjustified enrichment or advantages for themselves.
Employees who leave The Companymay not take with them or copy the company’s knowledge base,
customer lists, internal systems or other organised knowledge. Nor may they take with them rights or intellectual property that have been purchased or developed by employees or others for the Company. Immediate superiors are responsible for following this up.
Abuse and addiction are about employees having problems relating to alcohol, the use of narcotic substances, abuse of medication, doping, pornography, compulsive shopping, computer games or games of chance.
Employees are not permitted to use or be intoxicated by alcohol or euphoriant/stimulating substances during working hours. Managers are responsible for raising the matter with employees if they are concerned about abuse or addiction problems.