Ethical guidelines for suppliers

Purpose, principles and guidelines

1. Purpose

Norwegian Property is committed to conducting responsible, ethical, and sustainable business operations at all levels, imposing strict requirements on suppliers in the procurement of goods/services and their impact on the environment and society. We have guidelines and principles for the following areas:

• Human Rights
• Employee Rights and Social Conditions
• External Environment and Climate
• Combating Corruption

These guidelines are based on the three dimensions of sustainability: Social aspects, the environment, and the economy.

2. Principles

These guidelines are developed to clarify the expectations Norwegian Property has for its suppliers of goods and services, and it is assumed that anyone agreeing to sell goods and services to Norwegian Property also commits to complying with these guidelines.

If the supplier uses subcontractors to fulfill an agreement, the supplier is obliged to convey and contribute to compliance with the requirements of its subcontractors.

Where national laws and regulations address the same issues as these guidelines, the highest standard shall always apply.

The guidelines are intended to ensure that Norwegian Property and the suppliers we do business with uphold and respect fundamental human rights and decent working conditions in the production of goods and delivery of services.

Norwegian Property will consider social and environmental standards, in addition to other factors, when choosing suppliers. The supplier's compliance and demonstrated willingness to work towards improvements in line with the ethical guidelines outlined in this document will be considered in the supplier selection process. The following points will be given special consideration, and it is expected that the supplier:

• Complies with the law and established labor standards
• Does not exploit children or other vulnerable parties as labor
• Does not discriminate
• Respect and ensures human rights
• Prevents environmental harm resulting from its operations
• Reduces greenhouse gas emissions

3. Guidelines

Suppliers of products and services to Norwegian Property shall:

• Work to promote internationally recognized human rights and decent working conditions, including those outlined in:
  • The Universal Declaration of Human Rights (1948)
  • The International Covenant on Economic, Social, and Cultural Rights (1966)
  • The International Covenant on Civil and Political Rights (1966)
  • The Convention on the Rights of the Child (1989)
  • The International Labour Organization's eight core conventions on fundamental rights and principles in the workplace:
    • No. 29 on Forced Labor
    • No. 87 on Freedom of Association and Protection of the Right to Organize
    • No. 98 on the Right to Organize and Collective Bargaining
    • No. 100 on Equal Remuneration for Men and Women for Work of Equal Value
    • No. 105 on Abolition of Forced Labor
    • No. 111 on Discrimination in Employment and Occupation
    • No. 138 on Minimum Age for Employment
    • No. 182 on the Worst Forms of Child Labour
• Work to promote equality and prevent discrimination of any kind, such as based on gender, pregnancy, childbirth or adoption leave, caregiving responsibilities, ethnicity, religion, beliefs, disability, sexual orientation, gender identity, gender expression, and seek to prevent harassment, sexual harassment, and gender-based violence. Respect for the individual is fundamental, and everyone should be treated with dignity and respect.
• Follow established labor standards and the right to organize. All requirements stipulated in relevant legislation shall be followed.
• Allow employees to organize.
• Strive for work methods that ensure good working conditions with high standards for health, environment, and safety.
• Not employing children under the age of 15, and when using young people over 15, it should be done in a way that does not undermine their educational and developmental opportunities. However, suppliers are encouraged to provide opportunities for young people, for example, by using apprentices on assignments for Norwegian Property.
• Ensure that forced labor does not occur and that all employees receive a decent wage.
• Seek to prevent or reduce unwanted environmental impacts. National and international environmental laws and regulations must always be complied with.
• Prioritize environmentally friendly materials, reuse, and solutions that reduce energy consumption and greenhouse gas emissions.
• Distance themselves from corruption, bribery, or any other practices that hinder fair competition. Norwegian Property's employees have been instructed not to accept expensive gifts or services from suppliers or participate in trips or events paid for by suppliers. Norwegian Property's employees should also not use the company's suppliers for personal purposes unless approved by management.
• Do not use Norwegian Property's assets for personal gain. Nor should they take the company's assets when the agreement terminates. This applies to intellectual property, such as copyright and intellectual works.
• Handle all personal information obtained in connection with the agreement following the current data protection regulations. The information should only be used for the purpose it was collected, and it should be deleted when no longer needed.
• Norwegian Property operates in Norway by Norwegian law, and it is assumed that our suppliers operate their businesses per legal and statutory requirements in Norway.

4. Supplier procedures

Effective routines and organization are crucial for the implementation and adherence to ethical guidelines. Therefore, Norwegian Property expects that the supplier has systems/procedures supporting the implementation of these guidelines. It is therefore assumed that:

• The supplier shall designate a person responsible for implementing the guidelines in their own business.
• The supplier shall make the guidelines known in all relevant parts of its organization.
• The supplier shall obtain consent from Norwegian Property before production or parts of production are outsourced to a subcontractor/contractor if this has not been agreed upon in advance.
• The supplier shall be able to account for where goods ordered by Norwegian Property are produced and ensure that there have been no violations of human rights or decent working conditions in the production of the goods.
• Furthermore, Norwegian Property may require the supplier to account for its efforts to prevent, limit, and stop adverse effects on human rights and decent working conditions. Norwegian Property reserves the right to use this information to fulfill its obligations under the transparency law, including responding to information requests and explaining its due diligence assessments.
• The sharing of information will be done following the rules of the transparency law and current data protection regulations.
• The supplier is expected to provide data for the greenhouse gas accounts, including emissions related to the production of services, purchased goods, and the transport of goods. At a minimum, the supplier is expected to provide a breakdown of the quantity of materials used, along with corresponding Environmental Product Declarations (EPDs) where available.
• The supplier shall join Startbank when requested by Norwegian Property.
• Suppliers in construction projects are expected to be able to present the following documentation for all employees associated with the project and be prepared for any unannounced spot checks:
  • Copy of the Health, Safety, and Environment (HSE) card
  • Copy of employment contracts
  • Copy of time sheets for work carried out in the given period
  • Copy of payslips for work carried out in the given period

5. Supplier follow-up

The supplier shall strive to adhere to these ethical guidelines in its own business and contribute to compliance among its subcontractors. Upon request from Norwegian Property, the supplier shall be willing to document that this is happening through one or more of the following methods:

• Self-declaration from the supplier and possibly from subcontractors
• Follow-up meetings with Norwegian Property
• Inspection of working conditions at the production site, conducted by an independent party authorized by Norwegian Property or Norwegian Property itself. Norwegian Property reserves the right to carry out announced or unannounced inspections at relevant production or service delivery locations.

In case of an inspection, the supplier is obligated to provide the names and contact details of subcontractors. Contact information will be treated confidentially.

6. Violation of guidelines

In the event of a breach of the ethical guidelines, Norwegian Property will demand improvement of the identified issues within a reasonable timeframe. Norwegian Property reserves the right to terminate the agreement in case of significant breaches of the guidelines or if improvement is not achieved.

The supplier is obliged to inform Norwegian Property about any breaches of the ethical guidelines and present a plan on how to work towards compliance with the guidelines. This plan must be accepted by Norwegian Property for the agreement between the parties to continue.

7. Whistleblowing

Norwegian Property encourages the disclosure of any misconduct within the business so that corrective actions can be taken. Both its employees and employees of suppliers are encouraged to report such issues. Reports can be sent to info@npro.no.