Business Conduct Guidelines

The objective of the Business Conduct Guidelines is to describe NADG´s commitment and requirements regarding business practice and personal conduct. The Code of Conduct defines the behaviour NADG expects of employees and what you can expect of NADG.

Scope and responsibility

The Business Conduct Guidelines applies to all employees (including temporary personnel) of NADG. It also applies to intermediaries, consultants and others who act on NADG´s behalf.

These guidelines provide a framework for what NADG considers responsible ethical conduct but is not exhaustive. You shall always strive to exercise good judgement, care and consideration in your service for NADG. If there are differences between applicable laws and regulations, and the standards set out in the Business Conduct Guidelines, the highest standard consistent with applicable local laws shall be applied.

If you have questions regarding the Business Conduct Guidelines, please contact someone in management. Violation of the Business Conduct Guidelines may in accordance with relevant regulations lead to internal disciplinary actions, dismissal or criminal prosecution.

1. Bribes and facilitation payments

NADG expressly prohibit any offering or accepting of bribes of any variety to any person, whether private or public, and it is strictly prohibited to offer or make facilitation payments.

Bribery occurs when you offer, pay, seek or accept an improper payment, gift or advantage to influence a business outcome or someone who acts on NADG´s behalf in conduct of their duties. Turning a blind eye to your suspicions of bribery and corruption can result in liability for NADG and for you personally.

You must not (neither directly or indirectly through a third party) (i) offer anything of value to influence the actions or decisions of any official, other person in public or legal duty, any person acting on behalf of customers or sub-contractors/suppliers, or any other third party, or (ii) to otherwise obtain any improper advantage, in selling goods and services, conducting financial transactions or representing NADG´s interests. 

Facilitation payments are payments aimed at expediting or securing the provision of products or services to which the company is legally entitled. The payment is not intended to influence the outcome of the official’s action, only its timing. Facilitation payments shall not be made by any person acting on behalf of NADG, even if not considered to be a criminal offence under certain jurisdiction. If a payment is demanded from you to avert an immediate threat to the life or health of any person, such payments are not prohibited, but must be immediately reported to your supervisor. It is your responsibility to make sure that payments made are proper and legal.

Public officials

You shall not, to obtain or retain business or other improper advantage when conducting business, offer, promise or give any undue advantage to a public official (or a third party) to make the official act or refrain from acting in relation to the performance of her/his duties. This applies regardless of whether the advantage is offered directly or through an intermediate.

Caution must be exercised regarding entertainment with public officials in relation to business meetings or inspections. No employee or business partner will suffer adverse consequences for refusing to engage in improper payment activity, even if this results in loss of business.

2. Gifts and hospitality

You must not allow gifts and hospitality to influence your business decisions, or cause others to perceive an influence, and you must not place yourself or NADG under any obligation.         

Modest gifts may be accepted after careful evaluation of the following:

  • What is the intention behind the gift?
  • What is NADG´s relationship with the donor?
  • Is NADG in a contracting or a negotiation phase?
  • How will the gift be perceived by third parties and/or customers?

Gifts shall not be accepted in situations of contract negotiation, bidding, or award. Any gifts received are considered company property and shall be properly recorded.

Hospitality

You may attend social events and entertainment related to NADG´s business with third parties that are considered modest and relevant to maintain the business interests of NADG. Hospitality, expenses, or other favours shall not be offered or received where it could be perceived to influence decision making in situations of contract negotiation, bidding or award.

The cost of entertainment must be kept within reasonable limits and must not be accepted on a recurring basis. Ensure that travel, accommodation and other expenses for the individual representing NADG always is paid for by the company.

No person subject to these Business Conduct Guidelines, or member of his/ her family, shall solicit or accept from an actual or prospective customer or supplier of NADG any compensation, advance loans (except from established financial institutions on the same basis as other customers), gifts, entertainment, or other favours that are of more than token value or that the employee would not normally be able to reciprocate under normal expense account procedures.

The above principles also apply in reverse direction, so that no person subject to these Business Conduct Guidelines may offer, participate in or pay for transactions, entertainment, gifts or favours that violate the above principles. All expenses that are incurred on behalf of a customer need to be accurately detailed in expense reports.

3. Conflict of Interest

A conflict of interest is when your personal relationships, participation in external activities or interest in another venture can influence or could be perceived to influence your decisions when acting in your capacity as a NADG employee.

Business transactions must be entered solely for the best interests of NADG. You shall not, directly or indirectly, benefit from your position as an employee or from any sale, purchase, or other activity of the Company. You must not have interests outside the company (1) in any business that competes with or provides services to NADG, and/or (2) that would affect your objectivity in carrying out your company responsibilities.

It is your responsibility to avoid conflicts of interest. You shall act in the best interests of NADG and take appropriate steps to avoid situations and positions that may create or appear to create conflicts of interest. If you believe there is an actual or potential conflict of interest, notify your supervisor in writing together with all relevant facts.

4. Fair Competition

Antitrust laws protect free enterprise and prohibit behaviour that limits trade or restricts fair competition. These laws apply to every level of business. They combat illegal practices like price-fixing, market-sharing or bid-rigging conspiracies, or behaviours that aim to achieve or maintain monopoly. NADG is committed to fair and open competition and does not tolerate violation of antitrust laws and competition laws and regulations. Failure to follow these laws may result in criminal penalties including jail sentences and/or fines and loss of employment.

If an employee identifies what might be an antitrust/anti-competition problem, he/she should promptly notify the Company management.

5. Information Security

NADG´s trade secrets and proprietary data are part of the Company’s valuable intellectual property. These include technical, financial, operating, marketing and administrative information. A company employee shall not use or disclose such information for personal benefit or for the benefit of anyone other than the Company. This restriction on disclosure to others applies to prime contractors, subcontractors, and suppliers, as well as to the public.

The Company and its employees may from time to time receive or have access to trade secrets or proprietary data of other corporations and others. Employees shall handle these in accordance with any agreements concerning their use or disclosure, and with the same care and under the same restrictions as if they were the Company’s trade secrets or proprietary data. Furthermore, Company employees shall not disclose to other Company employees or use for the benefit of the Company trade secrets and proprietary data of their former employers.

Whether inside or outside the Company and its facilities, employees shall take reasonable precautions to protect confidential information from disclosure. Confidential information must be stored in such a way to ensure that only authorised persons can access it. Employees are obliged to securing laptops and phones by locking them properly, not downloading unauthorised software and not sharing passwords with anyone.

E-mail is a business record and employees are expected to use care and discretion when drafting e-mails. Do not send company e-mails to discuss or promote personal religious or political matters.

Personal data must be handled in accordance with data protection laws. Data on employees and external parties can only be gathered under strict conditions and for legitimate purposes. It is everyone’s responsibility to prevent misuse of such data.

6. Substance Abuse

NADG strives to provide a safe work environment for its employees by ensuring that the workplace is free from substance abuse. Employees should be fit and ready to carry out their work duties always while at work. Employees are prohibited from being at work or on NADG business while impaired by drugs or alcohol or with illegal drugs present in their systems. The use, possession, sale or distribution of illegal drugs and the misuse of legal drugs or other substances is prohibited.

7. Discrimination & Harassment

NADG´s employees shall expect a workplace free from harassment or discrimination. NADG will not tolerate working conditions or treatment that conflicts with international laws and practices. You shall respect the personal dignity, privacy and rights of everyone you interact with during work and those affected by our business operations and shall not in any way cause or contribute to the violation or circumvention of human rights. If you become aware of any situation in breach with NADG´s standards, you shall notify your supervisor in writing.

8. Declaration of compliance

You as an employee (including temporary personnel) of NADG will be asked to confirm that you have read and familiarised yourself with these Business Conduct Guidelines, and that you agree to comply with its purposes and provisions.

9. Reporting/Notification of breach

If you observe or personally be subject to unprofessional conduct, said conduct shall immediately be reported. There will be no retaliation against you, nor any impact on your professional career, for reporting possible violations in good faith. Any employee knowingly making a false report for the purposes of harming another individual will be subject to disciplinary action.

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