Norvax Code of Conduct 

Norvax is completely dependent on the trust of our surroundings to carry out our social mission, namely safeguarding lives, and global public health. Ethics are essential in this context.

The basis for our ethical work

From the President and Chairman of Norvax AS

Our Code of Conduct, our ethical framework, is an important guiding principle for how we work on our attitudes, and describes what is expected of you as an employee or as someone acting on behalf of Norvax. It is therefore important that all members of staff familiarise themselves with our Code of Conduct, and act according to the code in their day-to-day work.

As a company, we are increasingly facing more requirements from customers, authorities, investors, analytics companies, and voluntary organisations.  They are concerned with how we conduct ourselves as a Vaccine Manufacturer in Norway and supplier of Contract Development and Manufacturing Organization (CDMO) services, and as a Vaccine Developer – and the attitudes we convey. We must increasingly document and highlight this for external stakeholders, so that they can evaluate us on the basis of publicly available information.

Vision

Passionate about Global Public Health.

Mission

Serving the ecosystem as a partner for the transformative development and manufacture of vaccine and biological medicinal products.

Values

The five core values of Norvax are:

  • Collaboration
  • Integrity
  • Excellence
  • Innovation
  • Joy

Code of Conduct (ethical framework)

Norvax safeguards life, health and assets. Our business is completely dependent on securing the trust of customers, authorities, shareholders and the rest of society. Everything we do must, therefore, stand up to public scrutiny.

This means that everyone who represents Norvax must conduct themselves in a careful, proper and fair manner, and in line with our ethical rules. It is the individual’s responsibility to familiarise him with these and other guidelines. If an individual breaks the rules, it will have consequences for the company, and for the individual.

Norvax’s basic rules of conduct

Open and honest communication

Open and honest communication is important, both internally and externally. This must naturally be weighed in relation to the necessary confidentiality and duty of secrecy. Open and honest communication is a prerequisite for making the right decisions and for elucidating all aspects of a matter. Furthermore, it is important that you report any matters that warrant criticism.

Only those authorised to make statements on behalf of the company may do so externally. You are also expected to be cautious about how you express yourself in social media in contexts where you could be perceived as a representative of Norvax.

Ethical rules

Norvax shall be characterised by high ethical standards. A good business culture and a positive reputation are preconditions for our business. You are responsible for keeping up-to-date with the guidelines and statutory provisions that apply to your area of responsibility. The ethical rules also provide guidance on how you should act in order to comply with Norvax’s values and norms. If you are in doubt, contact your immediate superior.

The ethical rules can be viewed herein 

Discrimination and harassment

In Norvax, we have a joint responsibility to contribute to a team spirit and a good working environment. Each employee is expected to behave with respect and consideration and to display common courtesy in relation to colleagues, competitors, customers and others. By being inclusive and involved, we make each other better. Norvax has zero tolerance for discrimination and harassment. This includes unwanted sexual attention. Anyone who feels that they have been discriminated against or harassed shall be taken seriously.

Discrimination refers to unequal treatment due to gender, age, ethnicity, cultural background, religion, social affiliation, disability, sexual orientation, marital status or political convictions. Harassment refers to someone being subjected to negative actions over time from one or more persons.

How to help combat discrimination and harassment:

  • You must treat everyone with respect and openness.
  • Always keep in mind that reward and recognition should be given based on what a person does, not based on who he or she is.

Data protection and declaration of confidentiality

Data protection concerns the right to a private life and to control your own personal data.

Norvax’s customers and employees must be able to trust that this information is handled in accordance with the applicable laws and regulations, and that relevant information is accessible and of a high quality.

All personal data must therefore be processed in a legal and fair manner, and in a way that enables the person concerned to access the information.  

Personal data shall only be obtained for specific, explicitly stated and justified purposes, and not be further processed in a manner that is incompatible with these purposes.

You are responsible for familiarising yourself with the relevant guidelines for your area of responsibility, and acting in accordance with these.

Corporate social responsibility and sustainability

Norvax has taken its corporate social responsibility seriously and created a sense of security for over 200 years. We are expected to do even more going forward. Corporate social responsibility is ingrained in the overall strategy and is recognised in The Company as a key factor for long-term, sustainable value creation. Goals that will influence our choices in future have been developed as a means of implementing the overall strategy. Norvax’s sustainability goals also underpin the UN’s sustainable development goals, and form the basis for status reports on our work in relation to climate and the environment, social conditions, and management and control.

Health, safety and the environment (HSE)

Norvax aims to develop and maintain a positive internal working environment. It is, therefore, important that our employees take active responsibility for ensuring a good working environment. In order to succeed in our HSE work, every individual must be familiar with their duties and adhere to the guidelines that apply to their work.

How to act according to our HSE rules:

  • You are familiar with the laws, regulations and established procedures that apply to your work.
  • You contribute to a secure and positive working environment and prevent harm to the natural environment.
  • You speak out when you need competence-raising measures and training.
  • You use the necessary protective equipment or other aids as necessary or when required.
  • You inform your employer or safety delegate if any harassment or discrimination is brought to your attention.
  • You contribute to the development and implementation of follow-up plans if you are absent due to an accident, illness, etc.
  • You inform your immediate superior of any breaches of laws/regulations/errors or defects (deviations)

Notification

Notification (whistleblowing) means reporting censurable matters to someone who can do something about them. Examples of censurable matters are violations of statutory provisions and internal rules and guidelines.

Since such matters can be rectified, notification is essential, both for The Companyand for society at large. Employees who are willing to report censurable matters are therefore an important resource for the Company.

There are several channels for giving notification. Employees can always give written or oral notification to their superior, the HR partner, Director of Risk Management HR, employee representatives, safety delegates or the chair of the Working Environment Committee. You can also use Norvax’s notification channel, where you will also be able to remain anonymous.

How to become a good whistle-blower:

  • You familiarise yourself with our notification procedures.
  • You inform us of unacceptable conditions, and notify us about censurable matters in the workplace.
  • Keep in mind that you have a special duty to report criminal offences, or if life or health is at risk.
Good business conduct

Customer service

Norvax shall know the customer best and care the most.

Everyone acting on behalf of Norvax is responsible for giving our customers a good experience – the Norvax Experience. Everything we do should be characterised by a great degree of integrity and that we care. We must treat all customers with respect and in line with good business practice and industry standards.

How we create the Norvax Experience:

  • We keep our promises
  • We always deliver quality
  • We make complicated things simple
  • We ensure that the customer is satisfied.

Openness and honesty

Openness is a prerequisite for motivation, trust and security. That is why openness should define our corporate culture. Everyone should feel safe to discuss both small and big issues with their superior or with others in the Company. Everything we do must stand up to public scrutiny. It is important that we can justify everything we have done, how we have evaluated and which decisions we have made.

How to contribute to openness 

  • You should be able to document everything you do in accordance with the rules that apply to your work.
  • Everything you do must stand up to public scrutiny and maintain trust in Norvax.

Compliance

All employees and others who act on behalf of Norvax must adhere to laws, regulations and agreements in all aspects of our business. This applies to both external requirements and internal regulations, such as agreements, policies, standards, instructions, processes and routines/procedures. Deviations must be handled in accordance with the Company’s procedures for handling deviations and incidents.

Where regulations overlap, the most restrictive regulations apply, unless otherwise stated.

How to be compliant: 

  • You are familiar with and follow the rules and procedures that apply to your work.
  • You consult a more experienced member of staff or a manager if you are in doubt.
  • You are familiar with and follow set procedures for reporting any breaches of internal or external rules.

Money laundering and corruption

Money laundering is a social problem that both Norwegian and International law demands we actively combat.

Norvax must actively combat money laundering, financing of terrorism and corruption. We must do what we can to protect Norvax from being exploited by criminals, and the potential risk of damage to our reputation, trust and money.

How to combat money laundering: 

  • You are familiar with and follow set rules and procedures that apply to anti-money laundering, financing of terrorism, and anti-corruption.
  • You can identify suspicions of money laundering, financing of terrorism and corruption.
  • You report any suspicions of money laundering, financing of terrorism, and corruption in accordance with the Company’s procedures.

Gift registration

Before you give/accept a gift/activity, you must be aware of the gift’s/activity’s value, whether it/they are appropriate, and how frequently the transaction occurs. Assess whether the gift/activity entails a sense of obligation or influences evaluations. Keep in mind that everything we do must stand up to public scrutiny.

Employees or related parties cannot give or accept gifts or other benefits (private discounts/bonuses, etc.) worth more than NOK 500. Relation-building activities must be in accordance with our guidelines. Norvax strives for transparency, and all gifts and relation-building activities not conducted under the auspices of the employer, must be registered in the Company’s gift register, with its estimated value.

How to proceed when you receive a gift/activity:

  • You must assess whether ethical rules and other regulations permit the receipt of gifts/activities.
  • You cannot receive gifts from external parties worth more than NOK 500.
  • If you accept gifts/activities from external parties worth less than NOK 500, this must be registered in the gift register.
Every employee has a responsibility to protect Norvax

Protecting our values, information and brand

Everyone acting on behalf of Norvax has 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 their performance of work for the Company. The duty of secrecy also applies after the employee leaves Norvax.

We must also prevent internal communication being distributed outside the company.

How to take responsibility for protecting values, information and the brand:

  • You are familiar with and follow the information security rules and procedures that apply to your work.
  • You report any information security breaches immediately.
  • You neither distribute nor take assets and information outside Norvax without an official need.

Conflicts of interest (impartiality)

You must not take part in – or seek to influence the processing of – a case if there are circumstances that could diminish trust in your independence/impartiality. If you have a direct or indirect financial or other personal interest in a case, you must not become involved in the processing. As a rule, lack of impartiality on the part of a superior also means that the case cannot be decided by anyone reporting directly to him/her.

How to avoid conflicts of interests:

  • You are open about personal and close relationships to other Norvax employees.
  • You discuss relevant issues with your immediate superior or others in the professional environment.
  • You must report any situations in which a conflict of interest may arise.

Insider information

As a listed company, Norvax must comply with the provisions of the Securities Trading Act when handling inside information. As an employee or a representative of Norvax, you could be granted access to information that could be defined as inside information and that could influence the price of the Norvax share or another financial instrument.

None of us must use or contribute to use by others of inside information about The Company or other companies as a basis for trading in securities.

How to deal with inside information

  • You are expected to act in accordance with the relevant inside information guidelines, to ensure such information is not misused. You are also expected to act with due care when trading in financial instruments.

Intoxicants

When alcohol is served at various events after working hours in Norvax, alcohol should be consumed in moderation, without abusing the substance, and without endangering health and social relations.

All events organised by the company for the employees must be organised in such a way that they do not encourage excessive alcohol consumption. Furthermore, non-alcoholic beverages must be as accessible as alcoholic beverages.

Leaders have a particular responsibility to practice what they preach, display attitudes and set norms through their own behaviour, also in relation to alcohol. This applies both in relation to internal and external events. The individual leader must be loyal to Norvax’s provisions, and he/she is responsible for creating a good organisational culture and a good working environment in their area of responsibility.

Each employee is responsible for ensuring that their alcohol consumption is appropriate, in relation to the company’s guidelines and the individual event. Inebriation that endangers one’s own and/or the life and health of others, causes offensive or socially unacceptable behaviour, is not acceptable under any circumstances.

Standard Language of English

The Company’s major endeavour is in the export of pharmaceutical industry products and services and therefore the Company’s standard operating procedures and language is always in the English language. Local regulations and requirements pertaining to local language requirements will be supported as necessary.

Ethical Rules of Norvax AS
1. Norvax fundamental values

Norvax’s social mission is to safeguard lives, health and assets and to do so in a manner that takes the Company’s stakeholders into consideration.

A good business culture and a positive reputation are fundamental preconditions for Norvax’s operations. We depend on the trust of our customers and shareholders, the authorities and society at large. In order to gain this trust, we must make sure that everything we do is characterised by professionalism, expertise and high ethical standards. This applies to both the Company’s business operations and our employees’ conduct. All employees must act with due care, honesty and objectivity, and must refrain from doing anything that could undermine people’s trust in the Company. Managers have a particular responsibility and must be good role models.

All Norvax’s activities must stand up to public scrutiny. Employees are therefore expected to behave in accordance with the Company’s ethical rules. Employees who are in doubt as to what this means must contact their immediate superior.

2. Target Company

The ethical rules apply to all employees and officers at Norvax, and to hired consultants when they act on behalf of The Company(cf. section 6.8 of the impartiality rules).

3. Other regulations

The ethical rules set out requirements for ethical conduct, but do not cover all aspects of what constitutes ‘correct behaviour’. The Companyhas other guidelines and regulations that supplement the ethical rules. It is important, therefore, that employees use their own judgement as regards how to act in an ethically correct manner in each situation.

In addition to following the ethical rules, employees must loyally comply with laws, regulations, circulars, relevant codes of ethics for the industry and internal rules that regulate the Company’s activities. Managers must ensure that employees are given an opportunity to familiarise themselves with the rules that apply to their particular field of work. However, it is the employee’s own responsibility to follow these rules.

4. Openness

The Company’s corporate culture shall be based on openness, which is a precondition for motivation, trust and a sense of security. We want all employees to feel confident about raising both minor and major issues with their superiors or others within the Company.

The ethical rules will not always tell us what is right and wrong in a given situation. It is important that employees raise relevant matters or actions with their manager or the HR department if they are unsure. Another option is to use the ethics mailbox. All enquiries will be treated confidentially.

5. Good business practice

5.1. Human rights

The Company shall respect fundamental human rights, among other things as described in the UN Universal Declaration of Human Rights and by the International Labour Organization (ILO). The Company’s financial investments shall be in accordance with recognised principles for ethical investments from a human rights perspective.

5.2. Environment and procurement

Norvax shall endeavour to reduce the business’s environmental impact on society, and ensure that employees can do the same.

The Company is a purchaser of industrial goods and services. We must therefore make active endeavours to ensure that manufacturers and suppliers conduct their business operations in accordance with internationally recognised principles and guidelines relating to human rights and labour rights, the environment and anti-corruption. Products delivered to Norvax must meet our environmental requirements.

5.3. Healthy competition and sales

The Company shall always act in accordance with relevant competition and marketing legislation. We must show due care in connection with work carried out under the auspices of industry associations, and where competitors are involved. Such work shall always be carried out in accordance with the remits and/or guidelines we have drawn up in advance.

The Companymust not engage in any form of sale or marketing that can be perceived as offensive or that comes into conflict with generally accepted social norms. We must always give advice based on the customer’s needs, financial situation and willingness to take risk, and the advice must serve the customer’s interests. We shall know the customer best and care the most.

5.4. Tax and public regulations

Norvax must follow the relevant tax legislation in the country where The Company operates. Norvax must inform the tax authorities about any transactions and dispositions where Norvax considers the law to be unclear. The Companyshall not support or facilitate tax avoidance by other parties.

All employees must familiarise themselves with the rules, laws and regulations that apply to their own area of responsibility and ensure that they are complied with. Employees must not recommend or initiate violation or evasion of applicable laws and regulations.

 5.5 Corruption

Corruption means abusing one’s position to obtain improper personal or business advantages for oneself or others. Through its anti-corruption programme, The Companyshall actively endeavour to prevent corruption.

No one may accept benefits for themselves or others from the Company’s business connections if such benefits are a result of their employment relationship. Correspondingly, no one may offer such benefits to business connections. Examples of benefits are gifts, discounts, travel and rewards in connection with private purchases, loans etc. This does not apply to more trivial gifts (cf. section 6.6). Advantages that The Company has negotiated for all employees in a country or parts of a country where The Companyoperates are an exception from this rule.

Employees must not let their decisions or actions be influenced by undue pressure or offers of financial advantages from parties with an interest in the matter. Nor may they recommend or initiate violation or evasion of applicable laws or regulations relating to corruption and financial crime.

Employees must be familiar with the content of the Norvax leaflet ‘Do you know enough about corruption?’.

5.6. Money laundering and financing of terrorism

Money laundering means converting the proceeds of criminal offences into apparently lawful revenues or capital gains. The Companymust avoid any dealings with funds that stem from criminal activities.

Financing of terrorism means to provide money or other assets for the purpose of financing acts of terrorism or the planning of such acts.

Suspected money laundering or financing of terrorism must be reported to the anti-money laundering officer.

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.

6.8. Impartiality

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.

 

6.14 Self-interest

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.

6.15 Depency

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.

7. Whistleblowing

Whistleblowing means to report censurable conditions in the workplace. There are several ways of reporting such matters, but you can always notify your immediate superior or via the channel for whistleblowing. You can also notify the HR partner, HR Director, employee representatives, safety delegates or the chair of the working environment committee. If you wish to be anonymous, however, you must use the channel for whistleblowing.

Censurable conditions are matters that are in breach of 

  •  laws and regulations (legal rules)
  •  written ethical guidelines in the company
  •  ethical standards widely accepted by society

Violations of the law and criminal offences are always deemed to constitute censurable conditions.

Norvax encourages employees to report censurable conditions to enable swift rectification. Such disclosure is important for The Companyand for society at large. Employees who are willing to report are therefore an important resource for Norvax.

In some cases, you are obliged to file a report, for example 

  • when a co-worker is subjected to discrimination or harassment (Working Environment Act Section 2-3 (2))
  • about matters that may entail a risk to life or health (Working Environment Act Section 2-3 (2))
  • when the duty is set out in other law such as health legislation or the Money Laundering Act
  • when the duty is set out in regulations, instructions or rules applicable to the duties or Norvax in general

Read more about whistleblowing on our intranet pages and in Chapter 2A of the Working Environment Act.

8. Responsibility and follow up

All employees must familiarise themselves with and comply with the ethical rules, and assess their actions in relation to the rules. In cases of doubt, employees must contact their immediate superior or use the ethics mailbox.

Managers at all levels have a particular responsibility for ensuring that their own and their subordinates’ conduct is in compliance with the regulations. Line managers are responsible for making the ethical rules known, and for ensuring that employees act in accordance with them.

HR has overall responsibility for administering the ethical rules, including following up the gift register and the ethics mailbox. HR must assist the management by taking steps to ensure that all employees are informed about what the ethical rules mean in their day-to-day work.

 The consequences of transgressions of the Company’s ethical rules are shown in the matrix below.

Degree of seriousness

Negligent

Culpably negligent/repeated offences

Deliberate/ repeated cases of culpable negligence

Infringement of: 

Internal rules and guidelines

Infringement of: 

Internal rules and guidelines

Oral warning

Written warning

Laws and public regulations

Written warning

Consideration of criminal report, voluntary or imposed dismissal

Criminal report, voluntary or imposed dismissal

(N.B. Throughout this document the third person plural (they, them, their) is also used to denote the gender specific third person singular (he, him, his and she, her, hers)).

Norvax Basic Rules of Conduct and the Ethical Rules are largely inspired by Gjensidige and are in no way a recommendation by Gjensidige