Our code of conduct is the basis for the way we pursue our business, and informs both ourselves and the world at large what can be expected of us. It describes basis commitments and requirements for the way we will behave, provides guidance when we face ethical dilemmas, and helps us to take good decisions.
We see the necessity of clear ethical guidelines for our personnel. As a consultancy, this is extremely important. Trustworthy conduct – as an employer as well as towards clients and suppliers, owners and other partners – is fundamental for us. This code specifies that we will always provide the best advice for the client, that legislation and statutory regulations applicable at any given time will be observed, and that employees will be respectful of other people in their work – in both formal and more informal circumstances.
Our vision that “we lead the way and build tomorrow’s society” shows that we take our CSR seriously. We will contribute to sustainable and long-term value creation with the focus on climate and the environment, social factors and financial conditions, and this will be reflected in everything we do.
Our employees will receive the training and support they need to maintain our CSR.
The code applies to all our permanent and temporary employees, sub-contracted consultants and others acting on our behalf – including the board (hereafter collectively termed employees). We are expected to help each other to comply with the rules, speak out if anything ought to be improved and report irregularities. If in doubt, an employee must consult with their immediate superior.
Our managers must be good role models, and have a special responsibility to act in accordance with the intentions of the code. Regularly communicating the importance of complying with our code of conduct and ensuring the necessary training are part of a manager’s duties.
We expect our suppliers and partners to meet the same high standards of conduct as we do ourselves.
If an employee becomes aware of irregularities internally or at a client, they must report this. Their approach must be prudent and neither be perceived as harassment nor put unnecessary strain on the working environment. In the first instance, the correct procedure will be to report via the official channels – in other words, to the person with personnel responsibility. Where this is not appropriate, a report can be made to another manager, to a safety delegate/union official or to the working environment committee. All whistleblowing reports must be treated seriously and handled in accordance with our routines, so that the principles of avoiding conflicts of interest, maintaining confidentiality and hearing both sides of the case are maintained.
An employee who reports irregularities in a prudent manner must not be subject to any form of reprisal for such whistleblowing, and their identity must be kept confidential.
Employees must comply with applicable legislation and statutory regulations. That applies to both external requirements and internal rules, including laws, regulations, guidelines and instructions.
We respect human rights and worker rights for colleagues, client employees, suppliers and partners as enshrined in international conventions and local legislation.
Breaches of applicable legislation and regulations are not acceptable. Possible breaches or nonconformities must be handled in accordance with the company’s procedures and could have consequences in terms of labour, criminal and civil law.
We will have a working environment which promotes physical and mental health. Our systematic HSE work involves documented routines and divisions of responsibility, a working environment committee and local safety delegates, as well as continuous improvement efforts.
All our employees are duty bound to contribute to a positive and professional working environment. This means that we treat each other, our clients and our partners with respect, take responsibility for our own actions, and speak out if we observe anything which has a negative effect on the working environment or safety.
All our employees are equal, regardless of gender, age, sexual orientation, disability, ethnic background or creed. Discriminating against employees on the basis of such conditions is forbidden either in recruitment processes or during their subsequent employment. The individual’s qualities must be respected and valued. We respond actively if we observe bullying, harassment or inappropriate behaviour, and we work preventively to ensure an inclusive working environment. A diverse and inclusive workplace equips us to deliver better solutions to our clients.
All our employees are expected to behave in accordance with the guidelines and in a manner which does not discriminate against or bully/harass colleagues, clients, partners or others they meet in connection with their employment.
We work systematically on a daily basis with measures to reduce our environmental footprint. We have Eco-Lighthouse certification, and our environmental management system incorporates routines for procuring goods and services, sustainable waste handling, energy saving and reducing travel. Employees are expected to familiarise themselves with the routines which are communicated, and to make responsible choices in line with these.
All our employees have a duty to maintain the confidentiality of all conditions they learn about in the course of their employment, both within our company and at our clients or partners. That applies to both client information and internal matters in our company. This duty of confidentiality also remains in force after the employment relationship ceases.
Data security concerns ensuring the confidentiality, integrity and availability of the information we possess. We work in a structured way on data security and are certified to ISO 27001. Data security is a continuous process, and managers and employees have a shared obligation to keep their security expertise updated. All our employees have a duty to report immediately if they become aware of data security breaches.
We take data protection seriously and comply with the applicable rules for processing personal data.
Employees, clients, suppliers, partners and owners must be able to rely on us protecting their data, complying with our duty of confidentiality and processing personal data in accordance with applicable legislation.
Our communication will be open, honest and clear. That applies both internally and externally, and is important for maintaining trust in us. Only specified people comment to the media on behalf of the company, and all external communication must be conducted in cooperation with our communication department.
Every employee must exercise good judgement with regard to what they say in various media about clients, partners, competitors and colleagues. They must be aware that it is difficult to distinguish between what is said as our representative and in a private capacity. Behave in accordance with the general rules of good manners.
If an employee becomes aware of the publication of illegal material in our name or of material which could damage our reputation, they must contact the communication department for help in dealing with this.
We will treat all our clients with respect and in accordance with good business practice. We will execute assignments for clients with good quality and a high level of integrity, and clients must be assured that we give the advice which we believe is the best for them rather than for us. Employees must strive to maintain a friendly and polite tone in all interactions with clients. Everyone is expected to behave responsibly and refrain from actions which could weaken trust in us.
We treat all our partners with respect and in a fair and transparent manner. When involved in joint ventures and partnerships, we do not share commercially sensitive information or interact beyond the requirements of the project.
When choosing suppliers, products or services, we do not allow our personal preferences to influence our choice, but take decisions based on commercial requirements.
Conflicts of interest arise when our personal interests clash with our responsibility as a colleague in or as a representative of the company. Such conflicts may reflect, for example, close relationships, honorary offices, financial interests or ownership positions. They can also arise between government requirements, client expectations, our own commercial interests and the interests of our owners.
All our employees have a responsibility to take decisions unaffected by considerations of personal benefit. We avoid circumstances which could raise doubts about our personal integrity and disqualify us where a conflict of interest might arise. Anyone in doubt should consult their manager.
Financial integrity is crucial for maintaining the trust of employees, clients, partners and shareholders. We meet Norwegian and international accounting and reporting standards, ensure that we use our funds in a prudent and appropriate manner, and take decisions in line with our authorisation structure. We comply with applicable tax rules and do not contribute to tax evasion.
Every employee must ensure the accuracy of the information they provide or approve for use in making refunds or other payments from us.
Bouvet ASA is a listed company, and therefore all employees – regardless of their position – in all our subsidiaries are covered by the stock exchange’s insider rules related to sensitive information. Employees must familiarise themselves with the insider rules, which are available on the internet. These rules may also apply if an employee on assignment to a client gains access to sensitive information or does work which could affect our valuation or that of the client.
Trading on the basis of inside information is a breach of our ethical standards as well as illegal, and can have serious consequence for the inside trader personally and for us as a company.
We find all forms of corruption unacceptable, and will behave in an open and proper manner.
Corruption involves somebody receiving or offering an improper benefit because of a person’s position, office or assignment, in the form of money, gifts or services, and thereby achieving an illegitimate benefit for themselves or their own organisation.
Employees must exercise extreme caution with regard to gifts and invitations from and to clients, partners and suppliers of a size greater than would be considered normal recognition. Anyone who is in doubt whether a gift or invitation falls outside this limit should consult their manager.
Employees are authorised to use our property to carry out their work. That encompasses equipment, software, systems, information and the like which we own. Such property must be used and held in a responsible manner and in accordance with applicable guidelines. The same applies to the property of clients. We do not accept any misuse of property belonging to us or our clients.
We do not use computer equipment or other forms of electronic communication for unsuitable messages. That covers any and all forms of illegal activity and behaviour which can be perceived as discriminatory, offensive or harassing. Our employees must use software in accordance with the applicable licence terms. We do not permit the copying of software or material protected by copyright. No employee must download or upload unauthorised software or other copyrighted material.
To ensure a healthy working environment in our premises, at clients where our consultants work, and on business trips, we expect all employees to ensure that their own work commitment is not impaired by the consumption of alcohol or other intoxicants. Alcohol can be served on social occasions organised by us, our clients or other partners, but aggressive or other inappropriate behaviour attributable to the influence of alcohol or other use of intoxicants is unacceptable.