Code of Conduct

Introduction

Mitt Dekkhotell’s reputation is of fundamental importance. It has taken us a long time to build and must be nurtured on a daily basis so that our success story can continue into the future.

By ensuring that the services we deliver are of the highest quality we will be a leader in our industry. We will always act honestly and treat our customers and business partners in a way that fosters a high degree of trust. Our goal is to be the preferred provider in the business areas in which we operate from time to time while at the same time being a workplace in which our employees thrive.

In order for us to achieve these ends it is essential that employees and managers exercise good judgement in our interactions with colleagues, customers, suppliers and business partners. This means that we will at all times act in a professional manner, be polite, practice a high ethical standard and refrain from any action or statement that might damage the trust in which we are held or harm individuals. We will comply with the applicable procedures for work, laws and regulations and will only contemplate entering into agreements with partners and suppliers who adhere to the same standards of ethics and integrity as we ourselves do.

Based on the above points of departure we have drawn up a Code of Ethics and Business Conduct (the Code). The Code describes our values, the way in which we conduct ourselves and what we expect of our employees and managers. The Code will help our employees to take decisions in their day-to-day work on behalf of Mitt Dekkhotell that are correct and ethically appropriate.

In the following, employees and managers are referred to as employees, your and you. Mitt Dekkhotell is referred to as Mitt Dekkhotell, we, us, our or the Company.

Mitt Dekkhotell’s Code of Ethics and Business Conduct does not grant legal rights to customers, suppliers or other third parties.

Foundation

The Code of Ethics and Business Conduct was adopted by the Board of Directors of the parent company, Mitt Dekkhotell AS, and also applies to all subsidiaries. The Code should be viewed as a supplement to the Contract of Employment and all employees are required to familiarise themselves with and understand its contents and the expectations it lays down. The Code also applies to contract workers.

The Company’s managers have a particular responsibility for following up the Code and serving as good role models.

Everybody is different and so there will be individual interpretations of the message contained in the Code. You may have questions about the Code and situations might arise in which deciding on the ethical course of action will prove difficult. If and when this occurs, you must seek advice and guidance from the management.

This Code of Ethics and Business Conduct must be signed by all employees.

Sales, marketing and communication

Mitt Dekkhotell has worked long and hard to earn the good reputation and excellent customer relations that we now enjoy. Maintaining this reputation is an ongoing process requiring a daily effort on the part of every employee.

In our contact with our customers, be it directly in a sales situation or indirectly via our marketing, our communications must always be characterized by honesty, seriousness and courtesy and our primary focus must always be on the customer.

All messages must be based on generally accepted standards and values and must not in any way be interpreted as offensive or contraventions of applicable laws and legislation.

Competition

Fair and healthy competition makes us better and is an essential aspect of free enterprise. Mitt Dekkhotell will at all times follow applicable competition law and will never exchange competition sensitive information or enter into agreements with collaboration partners or competitors which contravene competition legislation or have as their purpose the prevention of free competition.

Our business conduct must be characterised by fair treatment of customers, suppliers and business partners. Our choice of suppliers and business partners must be based on objective criteria such as level of service, quality, price and other relevant benefits that Mitt Dekkhotell would receive in any potential business relationship.

We will treat all our customers, competitors and business partners with respect and never spread false, incorrect or misleading information about them.

Working conditions

We firmly oppose any form of social dumping or other gross exploitation in which employees are subjected to serious violations of the regulations governing health, safety and environmental conditions or receive pay levels that are unacceptably low relative to the normal rate paid for work of an equivalent nature. On the contrary, it is our wish and to our advantage that employees, both permanent personnel and contract workers, should have a safe workplace with decent working conditions and competitive terms of employment. Personnel who enjoy good working conditions and are treated with respect will always do a better job.

Our operations are highly labour-intensive and because demand for our services is seasonal, we also hire a relatively large number of personnel from both Norway and abroad. Our contracts of employment are written in a language that our employees understand and satisfy the legislative requirements applicable to both temporary and permanent employment.

Any accommodation provided for our employees is of a high standard and located in safe areas.

Non-discrimination

Mitt Dekkhotell is pro-diversity and against all and any discrimination on the grounds of gender, ethnicity, skin colour, religion, political beliefs, disability or sexual orientation. Nor do we discriminate in terms of pay. In determining the conditions of pay and employment of our employees we look exclusively at responsibilities, qualifications, talent and relevant personal abilities.

Heath, safety and environment

The services we supply are labour-intensive and also involve the use of machines and equipment that require the full attention of the operator. Our focus is on maintaining a safe workplace and we provide thorough training in the use of equipment and work routines for both permanent employees and contract personnel. We work with the company health service in conducting the necessary mapping and prevention of accidents and injuries at work.

Machines and equipment are calibrated and maintained on a regular basis by professional service providers in order to ensure that our operations are safe and secure.

We adopt a pro-active approach to the environment in our operations. This includes assessing work processes, the operation of business premises, waste disposal, production equipment and technological improvements with the aim of reducing our own environmental impact. Environmental assessments are included in relevant decisions, and we are committed to seeking out business partners and suppliers who live up to the same exacting standards.

Data and IT

We invest substantial resources in the development and management of IT systems. They play an essential role in our operations. Secure storage of data using data redundancy is a priority for us. Data collection and storage is conducted in accordance with the applicable laws and regulations.

Information supplied to us by customers, suppliers or business partners is never shared with third parties unless permission has been granted for us to do so.

The working environment and interpersonal relations

At Mitt Dekkhotell everyone must be treated fairly and with respect. The Company does not tolerate any form of assault, harassment, threats, bullying or other degrading or offensive behaviour directed at employees, customers or other business associates.

It is your responsibility as an employee to treat everyone you encounter with courtesy and respect. We have zero tolerance of discrimination or harassment on the grounds of background, religion, political outlook, skin colour, ethnicity, sexual orientation, disability or of any other gross violation of bodily integrity.

Intoxicants

Mitt Dekkhotell is a drug and alcohol-free workplace. Attendance at work while under the influence of drugs or alcohol will not under any circumstances be tolerated. Employees may be tested for the presence of drugs or alcohol where this is considered necessary and is permitted under the applicable legislation. We generally encourage moderation at social occasions and events.

Utterances and communication

Employees must exercise care and good judgment in their personal utterances in public spaces, both during working hours and in their leisure time. Public spaces include social media, net forums, other channels of communication or in the company of other people. Utterances of this nature may be taken as representative of Mitt Dekkhotell and harm the trust in which we are held and our reputation.

All forms of contact with the media must be conducted through and cleared with the marketing manager or the management of the parent company. Generally speaking, you have a duty to safeguard our interest in the best way possible if you have been granted approval to contact the media.

You will generally refrain from making any statements that are likely to harm our interests.

The use of IT systems

Employees have a duty to safeguard our systems in a manner that is consistent with our Code of Ethics, good business practice and that prevents abuse and unauthorised access. The systems are generally intended for use in work-related activities and a high degree of care must be exercised when visiting unknown websites and opening e-mails or files originating from senders outside the organisation.

Seeking out information on the Internet that might harm Mitt Dekkhotell’s reputation is not permitted. This applies in particular information that contravenes the legislation in force from time to time.

Furthermore, you must not download or run alien or harmful software applications to or on our infrastructure. In the event of uncertainty seek advice from the IT Department.

Corruption, integrity and conflicts of interest

Mitt Dekkhotell opposes any form of corruption or bribery aimed at influencing the decision of individuals in pursuit of gains for oneself or Mitt Dekkhotel. As an employee you are required to refrain from giving or receiving gifts or payments where the intention is to achieve benefits that might influence your own objectivity or that of another person.

Normal and modest hospitality is acceptable, provided that it does not establish any form of obligation on the part of the persons involved, the hospitality is of limited value, and this is consistent with the ethical guidelines of all parties concerned.

In cases in which employees intend to take on additional offices or other financial activities outside working hours the consent of Mitt Dekkhotell must be obtained (ref. the Contract of Employment). Consent of this nature will normally be granted provided that the activity is not illegal, has no impact on the performance of the employee or creates a conflict of interest. It is not possible to describe all potential conflicts of interest, but as a general rule employees must exercise judgment and care in cases in which outside activities or interests in other businesses could influence the employee’s decision-making when acting on behalf of Mitt Dekkhotell.

Do not take part in activities, enter into agreements or conduct transactions on behalf of Mitt Dekkhotell where you have a personal interest or might derive advantage in other ways from your position with Mitt Dekkhotell. Never put yourself in a position in which your personal interests take precedence over our interests.

Furthermore, you must not take part in any activity that is in direct or indirect competition with Mitt Dekkhotell or that might in other ways compromise your integrity.

You must decline gifts or other benefits that might be perceived as an unacceptable favour in light of your employment by Mitt Dekkhotell.

Loyalty, competence and duty of confidentiality

As an employee of Mitt Dekkhotell you have a duty to devote your full productive capacity to your position and to refrain from using working hours, our equipment or premises for private purposes. You must respect our internal guidelines and the applicable laws and regulations.

You must not take part in decisions that might serve to undermine your independence or attempt to influence others towards the same ends. This applies in particular to situations in which an attempt is made alone or in collaboration with others to influence the outcome of a decision and where the sought-after outcome would bring you an unlawful benefit.

As an employee you will come into contact with or gain possession of sensitive or confidential information in varying degrees. You have a duty to maintain complete confidentiality with regard to such information both during your employment with us and after your employment comes to an end. This might include information about customers or business partners or information relating to our commercial operations, including but not limited to commercial secrets, calculations, working methods, technical drawings, business strategies, plans for the future, source codes, business logic or other information of an internal and confidential nature. This duty of confidentiality also applies within the company with respect to colleagues who do not have any need for such information in their work. If you are uncertain about whether sharing information internally is appropriate you must consult management.

Mitt Dekkhotell reserves the right to order employees to sign a detailed non-disclosure agreement where necessary. Breaches of the non-disclosure agreement may result in sanctions and where applicable criminal liability both during and after the employee’s employment by Mitt Dekkhotell.

Quality

Our success is dependent on the quality of the services we provide. In order to ensure that this high quality is attained across all our units, we expect all employees to follow the applicable routines and procedures and to perform their work in such a way that quality is maintained in the best way possible. Nobody must perform work involving machinery and equipment that they have not been properly trained in the use of.

Mitt Dekkhotell is always striving to be better. As well as enhancing customer satisfaction, this increases our competitiveness. Employees with suggestions and ideas that might improve our work processes and quality are urged in the strongest terms to bring them to the Company’s attention.

Whistleblowing

As part of the continuing development of Mitt Dekkhotell we our employees to provide us with feedback. Employees must always be met with openness and respect with a view to encouraging a constructive dialogue. Moreover, in the case of matters of a more serious nature it is of particular importance for measures to be put in place at the earliest possible time and for the whistleblower to be safeguarded in an orderly and efficient way.

Should you encounter inappropriate circumstances of any kind or circumstances that are in breach of our Code of Ethics, you are strongly urged to report them to us.

They can be reported to management or via our whistleblower channel:
E-mail: varsling@mittdekkhotell.no

Mitt Dekkhotell will process all whistleblower reports according to current procedures and will, in cases where it is deemed necessary, seek external consultation or legal assistance. The person who reports will receive confirmation of the received report.

In the case of serious incidents, for example gross breaches of the law or circumstances in which life and health are under threat, you have a duty to lodge a report. In cases of this nature, the report must be lodged directly and without delay.

All whistleblower reports must be legitimate, and their purpose must not be to unlawfully harm or spread false rumours about third parties. Any cases of this nature will be viewed as gross violations of trust.

Breaches of the Code

Breaches of our Code of Ethics may result in sanctions of various types depending on the degree of severity of the breach and on whether the breach was deliberate or of a repetitive nature. Sanctions may take the form of an oral or written warning, where applicable termination with or without notice.

The guidance provided in the Working Environment Act will be followed when sanctions are imposed.

 

Updated August 1, 2023