Code of Conduct

This code of conduct applies to all NBT directors, employees, temporary personnel, suppliers, and other business partners. All individuals within this group are responsible for ensuring that the standards and requirements described below are followed, and that any actual or suspected violation of this code is reported to the General Counsel or to the whistle blower notification function.

NBT Guiding Principles

1. Everything we do is transparent with open and fair business activities, and an open and direct dialogue within our organization ensures we do everything as a team and for the team. 

2. We select our business partners based on our longterm goal of providing a dependable energy source at the lowest possible cost for the communities where we operate.

3. We are dedicated to provide a safe environment for our employees and the communities we serve through the way we design and construct our energy parks. 

4. We nurture our culture of integrity, teamwork, and mutual trust and respect both internally between employees and management, as well as externally with our business partners. 

5. We respect the culture, customs, and spirit of the law of all the countries where we operate, and we hire locally to contribute to economic and social development through our activities. 

Whistle blowing

We encourage both employees and external partners to use our whistle blowing reporting function to raise concerns about possible violations of this code or any of our policies when this is difficult to do through a manager or the HR department. All reported concerns are taken seriously and investigated to determine whether there has been a violation of laws, policy, or this code. The whistle blowing notification function is managed by BDO on behalf of NBT, and you can submit a report be emailing whistleblowing@BDO.no where someone will keep your identity anonymous, and will only communicate with the NBT General Counsel regarding your reported concerns. Investigations typically take time, but you will be kept informed of the status of the case. NBT has a non-retaliation policy for individuals reporting their concerns. Concerns raised in good faith will be treated as an honest attempt to provide accurate information, even if if the information later is proven to be incorrect. However, if the investigation proves that anyone knowingly made a report based on false information, NBT will follow up with disciplinary actions. Here are some examples of issues that must be reported to your manager or the whistleblowing reporting function immediately: 

  • Bribery or attempts to influence a decision 
  • Illegal behavior or breach of NBT policy requirements by an employee or business partner
  • Fraud or theft 
  • Errors in accounting records or financial reporting 
  • Unauthorized access to NBTs information systems 
  • Forced labor 
  • Bid rigging or other anti-competitive activities 
  • Money laundering 
  • Breach of trade sanctions 
  • Health, safety, security, and environment

We are committed to providing a safe and healthy work environment, and it is therefore critical that all facilities are free from all known hazards and that our HSSE procedures are followed to ensure safe operating processes. Furthermore, we strive to not only comply with all applicable environmental laws and regulations, but also conduct our business in a manner that protects the environment, our team members, and the local communities where we operate. 

Drugs and alcohol

We strictly forbid anyone to be under the influence of drugs or alcohol while at work. The only exception to this is that moderate amounts of alcohol is allowed during business dinners or company sponsored events. 

Harassment

At NBT we treat each other with respect. We do not tolerate unwelcome sexual advances, requests for sexual favors and other forms of verbal, physical, written or visual conduct of a sexual nature, or any other form of disrespectful behavior.

Human rights and labor rights

We are committed to following all local employment laws where we operate, as applicable, for minimum wage requirements, overtime compensation and limits, and other pay practices. We also support internationally proclaimed human and labor right conventions, and do not tolerate violations of these principles in any part of our operations or supply chain. 

Equal opportunity

NBT provides equal employment and promotional opportunities for all team members as well as any individuals applying for employment without regard to race, religion, sex, sexual orientation, national origin, age or disability. 

Conflicts of interest

We must maintain objectivity in our business relationships and activities to promote our culture of integrity and earn the trust of our stakeholders. There are many situations where conflicts of interest can arise to influence our judgment and decisions, and you are therefore required to immediately report conflicts of interests when discovered. 

Anti-Corruption

NBT strictly prohibits anyone acting on behalf of our company directly or indirectly from offering or accepting bribes, facilitation payments, or other improper payments. 

Money laundering

We are committed to ensuring adherence to applicable anti-money laundering laws in all countries we operate through our KYC processes. 

Gifts and entertainment

NBT does not offer or receive any gifts other than promotional items of maximum 50 USD value to avoid possible situations for conflicts of interest. Meals or other forms of entertainment must for the same reason be of modest value, so it is not influencing anyone’s decisions. 

Fair competition

We compete fairly and in compliance with antitrust laws to ensure free competition and value for our customers. 

Export Control

All international trade transactions must follow relevant export and import rules, as well as US and EU sanctions rules.

 Intellectual property and confidential information

Intellectual property includes copyrights, trademarks, trade secrets, patents, and other sensitive and confidential information. We respect the intellectual property rights of others, and it is everyone’s duty to make sure this type of information from suppliers, customers and others is safeguarded, and that all software and licensed products are appropriately licensed and only used in accordance with the license agreement. 

Sensitive and confidential information

Sensitive and confidential information must be properly safeguarded and distributed with due care only on an as needed basis. 

Data privacy

We handle personal data with care to ensure personal data is only collected for a specific and legitimate purpose and deleted as soon as no longer needed. 

Accurate books and records

Our records must be accurate and maintained for the time periods required by local laws in all locations where we operate. 

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