Code of Conduct
1 Purpose and scope
Our Code of Conduct describes the standards for our personal behaviour and business ethics and forms a framework to ensure that our business is conducted according to relevant legislation, internal rules and our core values:
Thermosaver’s Code of Conduct applies to all Thermosaver companies and everyone that represents Thermosaver. This includes employees, board members, hired staff, consultants, agents and other that may represent Thermosaver. Furthermore, Thermosaver wants our values and business ethics to be exercised by all cooperating partners.
2.1 Our Business
Trust is built through a frank and honest approach. To succeed long term, we need to gain employees’ and customers’ trust through our integrity. Words align with action. We do not promise anything we can’t deliver and strive to win our customers’, shareholders’ and employees’ trust through delivering on our promises.
Frequent and regular communication between management and staff is a key to success. We will facilitate such communication through meetings and briefings. This will cover strategy, targets and short-term priorities. In addition to newsletters, web sides, training and presentations, the interaction between management and staff shall focus on how the employees contribute to achieving corporate objectives.
2.1.3 Human Rights
Thermosaver support and respect internationally approved human right. This is to ensure that Thermosaver never contributes to violating such rights. Thermosaver does not accept customers or suppliers who violate the UN declaration on human rights in their business, i.e. child labour, forced labour.
2.1.4 Employee rights
Thermosaver supports and acknowledges internationally approved labour rights including the right to establish unions and conduct collective negotiations.
2.1.5 Equality, diversity and respect
Thermosaver wants an inclusive work culture and proactively seek to develop a work environment characterised by diversity, equality and respect. Thermosaver does not accept any form of harassment or discrimination based on sex, colour, religion, age, disability, sexual orientation, political beliefs, national or ethnical origin.
Code of Conduct
© 2022 | THERMOSAVER 3
2.1.6 Health and safety
Thermosaver works actively to prevent incidents and establish a healthy work environment which contributes to building a cautious safety culture. We plan and act to avoid incidents and work systematically to manage risk. No activity justify risk to life and health. Thermosaver employees have the right to refuse working in situations that can endanger life or health.
Thermosaver takes responsibility for the environment through a long-term sustainable use of renewable resources. Our target is continuous improvement in our projects, products and services. We actively seek possibilities to reduce negative environmental impact in a life cycle perspective and aim for re-use and full recycling of our products.
2.2 Personal Behaviour
Employees and others representing Thermosaver shall operate in the best interest of the company and contribute to realisation of strategies and targets. Everyone is to leverage their competence and position to ensure good processes. This involves expressing and listening to views and opinions before decisions are made. Loyalty is required when decisions are made.
2.2.2 Confidentiality and mutual respect
We shall always respect the individual’s right to confidentiality regarding personal issues. This applies to employees, customers, suppliers and partners. Thermosaver staff must obtain, store and use personal information according to Thermosaver’s policy, relevant legislation and best practice.
2.2.3 Company property
We are all obliged to handle and use Thermosaver property with due care. Thermosaver property is not to be used for personal gain.
2.2.4 Involvement in other activities
Employees are not to have other paid work or engage in private business to such an extent that it may infringe on commitments vis-à-vis Thermosaver as employer. Board roles outside Thermosaver must always be prior approved by senior management. This does not apply to voluntary organisations as long as the service is unpaid and may not involve conflict of interest.
2.2.5 Alcohol and drugs
Being under the influence of alcohol or drugs whilst working for or representing Thermosaver is unacceptable. This also applies to use of non-prescription drugs which is not prescribed by a doctor that can have intoxicating effect. During corporate hospitality, travel, participation at conferences, courses and seminars etc. limited volumes of alcohol may be consumed according to local customs. It is expected that everyone indulges with due care and an attitude that supports the objective of the event.
Code of Conduct
© 2022 | THERMOSAVER 4
2.2.6 Data discipline
Thermosaver IT equipment, systems and networks are tools to execute the activities and we process and use information in a responsible and professional way. Thermosaver’s equipment is not to be used to obtain information that the employee is not meant to access.
2.2.7 Social media
Thermosaver supports employees use of social media. However, all needs to be aware that the employee is responsible for what they publish in social media. Published information may damage Thermosaver, colleagues or business partners and can represent a breach in the duty of loyalty relating to employment or engagement.
2.2.8 Sexual services
Acquiring sexual services is illegal in some countries. Even in countries with no such legislation, Thermosaver disallows this in connection with work or engagements for the company. In this way Thermosaver contributes to the effort of fighting trafficking which represent a violation of human rights.
2.3 Business conduct
2.3.1 Corruption and bribery
Thermosaver takes a firm stand against any form of corruption or unethical behaviour that may hamper fair competition. We shall neither receive nor offer bribes or any other undue advantage for business or private gain.
2.3.2 Fair competition
Thermosaver believes that fair competition is good for all participants in business life and thus wants to enhance fair competition. Fair competition affects Thermosaver’s activities from competitors to suppliers and customers. Relevant legislation is to be observed prior to any decisions.
2.3.3 Gifts and representation
Thermosaver does not accept that any employee receives gifts or take part in events that may influence objectivity and integrity. Furthermore, we shall therefore not offer this to our business associates. Participation in events that are arranged by business associates shall always be prior accepted with immediate line manager.
Everybody has a responsibility for preventing that sensitive or confidential information is exposed. This may include but are not limited to information regarding security, individuals, commercial, technical or contractual issues protected by law. Non-disclosure is relevant also after an employee has left the company.
2.3.5 Business partners
Code of Conduct
© 2022 | THERMOSAVER 5
It is expected that our business partners behave in line with standards that are found in Thermosaver’s Code of Conduct. Agreements with business partners or suppliers are to be in writing and shall give a correct description of the relationship between the parties. Agreed compensation must correspond to the services rendered, and there must be satisfactory documentation and correct bookkeeping.
2.3.6 External communication
Thermosaver’s reputation is based on Thermosaver having credibility in all we do. We therefore communicate in an open, active and honest manner, maintaining customer confidentiality.
Misconduct covers illegal actions including but not limited to embezzlement, fraud, illegal cartels and other forms of economic crime. Thermosaver has zero tolerance for misconduct.
2.3.8 Correct bookkeeping and reporting
We shall conduct our business in an open, active and honest manner and at the same time respect confidentiality. Financial information shall be correct, recorded and in line with laws and regulations.
Thermosaver expects fair competition in the marketplace and expects the same standards from its suppliers.
3 Reporting of deviations or violation of rules.
Thermosaver’s company culture is based on transparency. It is accepted and required to bring forward concerns and reprehensible matters. All employees are encouraged to report suspect behaviour and observed breaches of laws or ethical rules to immediate line manager. An alternative reporting line may in such matters be Thermosaver’s notification channel with the Law Firm Compliancepartner AS, with mail address: email@example.com, where employees also may report anonymously. See Thermosaver’s own notification poster on deviations and violation of rules. Such matters will be treated confidential, and confidentiality about such notification will be maintained to the extent possible. Thermosaver will not tolerate any form of negative reactions or attempts of retaliation against employees who, in good faith have reported on breaches of Thermosaver’s Code of Conduct or other legal requirements. Those who retaliate will be subject to disciplinary consequences. The same goes for misuse of the notification channel. Thermosaver has zero tolerance for breaking laws or the company’s ethical standards. In such cases, disciplinary measures may be imposed, including but not limited to filing a compensation claim and /or police notification.