Supplier Code of Conduct S&P 2023

Supplier Code of Conduct

for Söderberg & Partners AS and subsidiaries

Photos: 123rf.com

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Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

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1. Introduction Söderberg & Partners AS and its subsidiaries (S&P) set high standards for sustainability, quality, business integrity and ethics.

This Code of Conduct for Suppliers (the “Code”) outlines our expectations for all our Suppliers, including any approved subcontractors used by our Suppliers.

Suppliers must comply with all applicable laws, regulations and standards in the countries in which they operate. S&P expects Suppliers to maintain high ethical standards in their business practices in general and to comply with and adhere to the principles set out in this Code.

The Supplier shall in its agreements with subcontractors carry forward these expectations to their subcontractors by carrying forward this Code or similar principles not less stringent than the principles in this Code in a different contract format. The Supplier is expected to comply with this Code even if it stipulates a higher standard than required by national laws or regulations.

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Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

2. Principles This Code is based on principles derived from both local legislation and the conventions and guidelines from multinational organizations such as the UN, ILO and OECD, including but not limited to: − Central UN conventions, such as the UN Declaration of Human Rights, the Convention against Corruption, the Convention on the Rights of the Child, Convention on civil and political rights, on economic, social and cultural rights and on racial discrimination − The ten principles of the UN Global Compact, which includes standards governing anti-corruption, human rights, labour and the environment.

− ILO conventions and in particular the core conventions on freedom of association and the right to collective negotiations, prohibition of child labour, prohibition of forced labor and prohibition of discrimination − OECD guidelines for multinational enterprises, with clear expectations for due diligence − areas such as human rights, labor rights, the environment, anti-corruption and transparency − The Transparency Act (LOV-2021-06-18-99)

Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

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3. Anti-corruption S&P expects its Suppliers to have a zero-tolerance approach to corruption and all other forms of prohibited and unethical business practices.

bezzlement, fraud, extortion, tax evasion, sanctions violations and money laundering in all its business arrangements.

The Supplier is committed to exert reasonable due diligence and have reasonable policies and processes in place to prevent, detect avoid and tackle financial crime, including but not limited to corruption, em-

In all of its operations and activities, the Supplier must refrain from bribery or any other unfair influence that could lead to business advantages or give the impression of such unfair influence.

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Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

4.Conflict of Interest The Supplier must avoid interaction with any S&P employee that might, or appears to, conflict with the employee acting in the best interests of S&P. The Supplier should not offer any improper advantage to an S&P employee or their family members in order to gain business.

Supplier should seek to avoid conflicts of interest and timely disclose to S&P both actual and potential conflicts.

The Supplier shall comply with all competition and anti-trust laws. This includes agreeing not to enter into discussions or agreements with competitors regarding price fixing, market sharing, bid rigging or other similar activities.

Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

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5. Reporting misconduct S&P expects its Suppliers to promote a culture of high standards of ethics, integrity and openness. S&P has established a channel to report actual, planned or potential misconduct on the part of employees, Suppliers or subcontractors.

Suppliers can report relevant cases by sending a notification to apenhetsloven@soderbergpartners.com.

6. Human rights, incl. The Transparency Act The Supplier and its subcontractors are expected to support and respect the UN Guiding Principles on Business and Human Rights. This means that the Supplier should identify, prevent and manage human rights risks as appropriate in relation to the size, nature and context of its operations.

S&P is regulated by the Transparency Act. The Act promotes enterprises’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services and ensures the general public

access to information regarding how enterprises address adverse impacts on fundamental human rights and decent working conditions.

S&P conducts due diligence assessments of its Suppliers, subcontractors, and business partners, by assessing the risk that these counterparties may be exposed to in the realm of human rights and labor conditions. Suppliers are expected to provide S&P with the information deemed necessary to conduct these assessments.

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Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

7. Labor standards S&P expects Suppliers to ensure that their employees are offered a safe and healthy working environment and provide their employees with the protective equipment and training necessary to perform their tasks safely.

The Supplier should provide a workplace free of harassment or discrimination on the basis of age, gender, language, religion, political or other opinion, ethnic origin, nationality, union affiliation, sexual orientation, family responsibilities and disability.

All employment should be voluntary and the Supplier must not use forced labor. Forced labor is defined as any type of work or service demanded from the Sup-

plier under the threat of any sort of punishment. The Supplier must not engage in, or in any way benefit from, the use of child labor.

The right of employees to freedom of association and collective bargaining must be respected and promoted by the Supplier. Employees must receive salaries, vacation and other possible employment benefits, and have reasonable working hours in accordance with applicable labor legislation regulations and the fundamental conventions of the International Labor Organization (ILO).

Supplier Code of Conduct for Söderberg & Partners AS and subsidiaries

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8. Environment S&P expects its Suppliers to strive to minimize the adverse environmental impact of their activities, products and services through a proactive approach and responsible management of their environmental aspects.

The Supplier must comply with all applicable legal requirements, standards, agreements and guidelines regarding the environment.

S&P expects its Suppliers to promote the development and distribution of environmentally friendly technologies.

9. Compliance and monitoring The Supplier is expected, on request, to provide S&P with the information S&P requires to assess the Supplier’s adherence to the Code.

Furthermore, the Supplier shall provide S&P with right of audit to verify adherence, including access to the physical premises of the Supplier and access to personnel for interviews.

Notification of such audit shall be provided in a reasonable time frame prior to the requested audit-date.

The Supplier is required to report to S&P any incident, behavior or other circumstance that is or may be regarded to constitute material non-compliance by the Supplier with the principles of this Code.

Breach of the S&P Code by a Supplier is considered grounds for S&P to terminate the agreement with the Supplier without regard to other contractual obligations.

Söderberg & Partners Norge Postboks 3241326 LYSAKER Söderberg & Partners Org. nr.: 965 575 162 Lysaker torg 151366 LYSAKER apenhetsloven@soderbergpartners.com