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People 

Health & safety 

Sleipner is committed to providing a healthy and safe working environment for all our employees, suppliers and other stakeholders. Whenever we work or interact with third parties, our health and safety standards are applied to them as well. Health and safety require that everyone is equally involved. We make sure everyone at Sleipner is aware of all relevant health and safety regulations and complies to them. The goal of our zero-harm policy is to prevent all injuries, safety incidents and health hazards. 

Human rights 

Sleipner respects human rights. In all our operations, we are committed to all internationally proclaimed human rights as stated in the United Nations Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the Ten Principles of the United Nations Global Compact, and the International Labour Organization’s Declaration of Fundamental Principles and Rights at Work. 

Fair employment 

Fair and respectful treatment of employees is our way of working. We recruit, develop and promote based on merit – regardless of gender identity, race, age, religion, sexual orientation, disability, nationality, political opinion, union affiliation, social background or ethnic origin. We also value diversity. 

Any forms of compulsory, forced or child labour are neither used nor tolerated. Sleipner respects all applicable legislation and regulations regarding working hours and compensation. Sleipner also respects the freedom of association and the right to collective bargaining. 

Harassment 

Sleipner provides a working environment that is based on mutual respect and fairness. No physical, sexual or verbal harassment, violence, threats, discrimination, bullying, humiliation or intimidation is tolerated. We expect inclusiveness and support from all our employees. Our employees are sensitive to cultural considerations when travelling, as well as when interacting with people from different cultural backgrounds. These principles apply to our global operations and when conducting business, representing and travelling. They are adhered to also in premises of third parties, as well as on social media. 

Business conduct 

Laws & regulations 

We respect local legislation, regulations and customs everywhere we operate. If there is any inconsistency between our Code of Conduct and any local laws, regulations or customs, we apply the higher standard. 

Violations of laws, in particular anti-corruption and competition laws, can cause significant damage to Sleipner reputation, penalties and financial losses. For Sleipner employees or anyone involved, they may lead to disciplinary action, such as termination of employment. 

Corruption & money laundering 

Our approach towards corruption and bribery is zero-tolerance, and we 

comply with both national and international anti-corruption laws. We do not engage in business with anyone who does not share these principles. We do not offer, pay, demand, or accept any bribes, kickbacks or facilitation payments, directly or indirectly. These principles are applied for both the public and the private sector. We do not commit or approve any business transactions that violate any anti-money laundering or terrorist financing laws. We are committed to ensuring that our products and services are used only for legitimate purposes with legitimate funding. 

Gifts & entertainment 

While offering and accepting gifts, hospitality and entertainment is normal business practice in many of our operating locations, we do not compromise our anti-corruption policy. Accordingly, only occasional and modest gifts, hospitality and entertainment are permitted – both receiving and offering. These gifts must be offered or accepted in the course of normal business interaction and must be approved in accordance with our policies. Gifts, hospitality or entertainment must never involve cash gifts, cash gift cards or the like. Any gift will never be offered or accepted if the purpose is to influence a business decision. 

Conflict of interest 

We expect all Sleipner employees to always act in our best interest. A conflict of interest occurs if you have some competing interests or loyalties that may have an effect on your ability to perform your work for Sleipner. Also, a financial or other benefit that can influence you or someone close to you can be a conflict of interest. If you see any actual, potential or perceived conflict of interest, you must immediately disclose it to your manager and HR business partner and remove yourself from related decision-making processes for Sleipner.  

Third parties 

This Code of Conduct applies also to our customers, suppliers, agents, distributors, consultants and other business partners. They are expected to be committed to and comply with the same principles of proper business behaviour. 

Government relations 

Integrity and transparency are maintained with all governmental authorities. Sleipner remains politically neutral and makes no donations or contributions to any political party or candidate. 

Competition 

Sleipner is committed to fair and transparent competition, complying with all relevant competition laws. Any price fixing, market or customer allocations, bid rigging, illegal bundling, exchange of competitively sensitive information or other unlawful competition-restricting arrangements with customers, suppliers, dealers, agents, distributors, consultants or other business partners is prohibited. 

Trade compliance 

Sleipner is committed to responsible trade. We expect also our suppliers to comply with these principles. We comply with all relevant trade sanctions and applicable export and Harmonized System tariff laws and regulations.  

Company assets 

Privacy 

We comply with data privacy and protection laws and regulations when collecting, processing and retaining personal data. This applies to our employees and business partners alike. Data is collected only for legitimate business purposes. 

Intellectual property rights 

Sleipner’s intellectual property rights are a key asset and represent significant value for our business. This is why they must be protected by appropriate restricted disclosure, confidentiality, licensing arrangements and other measures. We also respect the intellectual property rights of others and are committed to not using them without permission. These include registered rights, such as patents and trademarks, as well as unregistered rights, such as trade secrets, copyrights and know-how.  

Confidentiality 

To ensure that confidential information will only be used for permitted purposes, Sleipner must protect it and limit access to it on a need-to-know basis. This applies to our own confidential information, as well as to the confidential information of our customers, suppliers and other business partners. This may include information about technologies, designs or other 

technical data, financial or commercial information, customer details or personal information. 

IT & cybersecurity 

Sleipner’s IT infrastructure must be protected against unauthorised access, viruses, cyber-attacks, phishing, damage or theft in a way consistent with our instructions. IT devices and systems must not be used to access, store or upload any illegal, inappropriate, obscene or offensive material from the internet, social media or other sources. Access to our IT devices and systems may be monitored and blocked when necessary. Within the boundaries of applicable laws, all data stored on our IT devices and systems may be accessed and reviewed by us for business, IT maintenance or legal reasons. This includes the investigation of any illegal or unethical behaviour. Our employees are encouraged to engage in different social media channels to support our customers, build the Sleipner brand and communicate with stakeholders. Acting with integrity, considering the target audience and not disclosing any confidential information are our main guidelines in using social media channels. 

Brand & reputation 

Sleipner aims to maximise the customer recognition of our brand. Building and strengthening the Sleipner brand supports our business strategy. Our visual brand guidelines must always be followed for marketing materials, products, clothing and documents. Our reputation must always be protected and promoted. We must always act and treat others with integrity and respect when representing or interacting for Sleipner. This includes business travel and long-term assignments. 

Sustainability 

Environment 

We are committed to minimising our environmental footprint and the impact of our operations, as well as to influencing the operations of our customers and suppliers. We aim for the efficient and sustainable use of energy, water and 

other resources and for minimised emissions and waste. We strive for constant environmental improvements for our customers through our solutions, equipment and services. 

Quality & product compliance 

All the solutions, equipment and services we produce are consistent with applicable legislative and regulatory product safety requirements in terms of developing, designing and delivering them. Our aim is that they meet or exceed our customer expectations and industry requirements.