ethical guidelines

Ethical guidelines

2 Ethical GuidElinEs Ethical GuidElinEs 3

dear colleagues 3

high ethical standard and an open corporate culture 4

Group responsibility 7

individual responsibility 9

safety and crime 9

Gifts and benefits 9

alcohol and drugs 10

Politics and religion 11

Punishable offences 13

conflicts of interest and legal misconduct 15

communication 16

Professional secrecy 16

Reporting of ethically reprehensible activity 19

Violation of the Ethical guidelines 20

test your ethics 20

notification 22

Contents

We thrive on delivery. in order to deliver, we must haveboth our customers’ trust, and motivated employees.two of our corporate values are honesty and respect.these are core values in relation to customer trust, and a good working environment. the Ethical guidelines are built on the group’s core values, creating a norm for what is considered responsible conduct.

the guidelines apply to all employees in the group, and describe our culture for dealing with each other and theenvironment. We shall have an open corporate culturewhere discussion of ethical dilemmas in the workplace isencouraged.

Many know from experience that it is not easy to know where the boundary lies, or know exactly how to proceed given a particular situation. these Ethical guidelines do not provide answers to all dilemmas, but are rather meant to be a source of help and guidance in order for you to manoeuvre safely within the stipulations of applicable laws and regulations. Given a particular situation where you are in doubt about how to proceed, i encourage you to talk with your colleagues, or take up the issue with your manager. the ethical dilemma test found in the back of the folder can also be of assistance.

i ask that you become well-acquainted with the Ethicalguidelines. Following the Ethical guidelines is crucial to our company culture, so that we achieve our common goals. dag Mejdell President & cEO

Dear colleagues


What are ethics, and why do we need Ethical guidelines?Ethics are about what is right and wrong, and providesa framework for our behaviour. Ethics are value-based obligations that we impose on ourselves, our employer and the community to which we belong. We relate to our ethical obligations on the basis of general community values, as well as the group’s company-specific values.

these Ethical guidelines are built on the group’s values.By founding our behaviour on the group’s shared values,and by acting in accordance with these guidelines, wecan contribute to a high ethical standard affecting thewhole of the group.

a high ethical standard is fundamental to a goodworking environment and a sound and open corporateculture. By manifesting high ethical standards and astrong corporate culture, we aim to establish trust anda good reputation to demonstrate to our customersthat we are to be trusted.

the Ethical guidelines are not exhaustive, but ratherthey create a norm for what the group judges to begood and responsible behaviour. the guidelines are alsointended to be a source of help and guidance in order to

manoeuvre safely within the stipulations of applicablelaws and regulations. the individual employment contract further describes provisions and requirementsthat are to be met by each individual employee within his or her areas of responsibility.

To whom do the Ethical guidelines apply, and what isyour responsibility?the Ethical guidelines apply to all companies that arepart of the group, and to all of the group’s employees.the guidelines also apply to members of the Board,employees on leave of absence, external consultants,temporary employees and others employed on contractwith the group.

Managers are responsible for communicating theEthical guidelines to ensure they are understood andfollowed. Managers are also responsible for informingemployees that non-compliance will result in a certaincourse of action. Furthermore as a leader you have the special responsibility of adhering to the Ethical guidelines by setting a good example of ethical behaviour through your actions.

as an employee in the group, you have the duty to bewell-informed, and to comply with the Ethical guidelines.

The group shall be characterised by a high eth-ical standard and an open corporate culture


The group shall be a responsible employer,community player and business partner

the group shall be a professional employer thatadheres to fundamental human rights. in the group we recognise our differences and use them for the common good. the group does not accept any type of harassment or discrimination based on race, religion, national origin, sexual orientation or gender. neither do we accept any kind of behaviour that is liable to be perceived as threatening or humiliating by colleagues or other business relations.

as an employer, the group stands for good job opportunities and the fair treatment of all employees. Objective criteria should form the basis for all decisions concerning employment, promotion and wage-setting.Employee rights protected by law, wage agreementsand international conventions shall be followed.

the group will be at the forefront of the effort leadingtoward creating a healthy work environment in whichno one will run the risk of being injured or becomingill due to his or her work. the individual employee isexpected to contact his or her immediate superior, orthe safety deputy, to report any defect or problem thatmay endanger life or health during work.

as a responsible community player, the group is obliged to meet the licence requirements, as well as other government requirements. the group shall work actively to reduce emissions and pollution, save energy and choose environmentally-efficient solutions.


as a trusted third party supplier of physical and electronic solutions, the group assumes great responsibility, with respect to its customers. this responsibility applies to money as well as post, goods and cargo, information and other valuables. the customers must be able to trust that what they deliver to the group will arrive safely within the stipulated time-frame.

suppliers shall be treated impartially and with fairness. the group shall not abuse its market position.

We expect our suppliers and partners to share our ethical values.

as an employee in the group, you are obliged to complywith all laws, regulations and internal guidelines, to show responsibility, and to do your work safely and conscientiously, given your current level of authority. You should behave honestly and with integrity, treat everyone with respect and demonstrate good behaviour to all business relations, colleagues and other contacts.

Safety and crimeYou are obliged to contribute to the prevention ofcriminal actions within, and against the group, and tofollow the safety routines. You should be vigilant andhonest when handling the group’s assets, postal items,goods and cargo, information and other valuables thatare handled for customers. You are also required toprovide information of any criminal actions taken within or against the group.

Gifts and other benefitsYou shall not, on behalf of yourself, or others, acceptany gift, commission, service or other benefit thatwould be likely to, or on the intention of the giver, improperly influence your work for the group. You should also refrain from giving, or offering, such benefits. in this context, benefits also include invitations to meetings and events, travel offers and other similar benefits paid by others than the group. attendance to such meetings and events must be approved by your immediate superior. it is prerequisite that the group, at a minimum, covers travel expenses, including lodging and meals. When you participate in these types of meetings

Everyone is accountable for honest and responsible personal behaviour


and events, you will always be a representative of thegroup, which must be reflected in your behaviour.

Modest forms of hospitality and social gatherings arecustomary in all business relationships. it is acceptableto both give and receive gifts of small value in connec-tion with christmas, holidays or other special occasions. however, favouritism must not be developed to the extent that it affects the decision-making process, or gives cause for others to believe that it does so.

if you receive a reward or benefit of substantial value,or become aware of an impending offer for such abenefit, your immediate superior should be informedin order to decide whether you can receive the gift, orif it has already been received, possibly keep the gift.the determining factor is whether your integrity wouldbe impaired by receiving the gift, or would it createsuch an impression to the detriment of yourself or thegroup. special caution should be exercised when bene-fits are offered in connection with negotiations, specificcontracts or issues that are under consideration.You shall not receive discounts when privately buyinggoods and services from the group’s business relations,unless a discount has been offered to a large group ofemployees in the group.

it is never acceptable to buy sexual services when acting on behalf of the group.

Alcohol and drugsall group workplaces shall be alcohol and drug-free. it isnot acceptable to be under the influence of alcohol orother illicit drugs at work. it is expected that you reportany colleague whose work is currently, or has been,

negatively affected by alcohol or illicit drugs during thework day. alcohol may be served in modest quantitieswhen customary, or on special occasions provided thatconsumption does not take place during work activities.

Politics and religionYour political or religious affiliations, participation insocieties and associations etc. are not a concern of thegroup. nevertheless, you must appear impartial whenacting on behalf of the group. Furthermore, we expectthat you display a loyal attitude in both personal andprofessional situations so that you do not harm thereputation of the group.


We uphold zero tolerance for corruptionand other criminal offences

the group does not tolerate any type of corruption, orother criminal offences committed in connection withwork for the group.

Zero tolerance for any corruption and criminal offencemeans that these actions shall incur strong and consis-tent reactions resulting in dismissal. circumstancesthat are considered liable to penalty will, as a generalrule, be reported to the police. corruption includes bribery and undue business influence.

corruption undermines legal business activities,distorts competition, impairs trustworthiness and thegroup’s reputation, and exposes the company as well asindividuals to undue risk. apart from being ethically unacceptable, corruption and complicity in corruption are actions liable to penalty, whether the matter con-cerns the acceptance or offering of bribes.

criminal offences committed by employees in the groupthat negatively affect customers are consideredparticularly serious and will be considered aggravatingfactors when determining the appropriate sanctions.like corruption, such offences are particularly destructive to the trustworthiness, and reputation ofthe group. additionally, they may negatively affect theworking environment.


Conflicts of interest and misconduct shall be avoided

as an employee in the group you shall not try to obtainbenefits, for yourself or any other person closelyrelated to you, which are improper, or in other wayslikely to impair the interests of the group. You are notallowed to have salaried work, owner’s interests orother influential positions in the business arena thatmay undermine your loyalty towards the group.

serving on the board of directors of other for profit companies shall be approved by your immediate su-perior, or his or her manager.

You may not participate in, or seek influence over, anydecision if there are circumstances that could raisedoubts about your impartiality. such circumstances mayarise where there are personal interests in the case,for example through a family relationship, a closepersonal relationship or financial interests. this alsopertains to owner’s interests or board membership in acompany, society or association connected to the case.

if a potential conflict of interest should come to yourattention, you must immediately report the matter toyour immediate superior. if disqualification is disclosed,or if circumstances arise that result in diminished trustin the group, and/or the decision-making processesof the group, you shall immediately refrain from anyfurther dealings with the matter in question.


We shall be open and truthful in ourcommunications

We shall be open and truthful in all of our internal and external communications. all media contact shall be handled in compliance with the corporate communications Policy.

The duty of confidentiality must be upheldYou are obliged to maintain secrecy about confidentialinformation entrusted to you in connection with thework, or task that you carry out for the group. an important part of this obligation is to maintain confidentiality of information of a competitive nature, as well as any information that might be of interest to criminal circles.

the duty of confidentiality also applies to colleagues who have no need for the information in their work. the duty of confidentiality is exercised in order to prevent unauthorised persons from gaining access to information that may harm the group’s customers, activities or reputation. the duty of confidentiality is also intended to protect personal information, and the integrity of individuals, whether they are customers, or group employees.the duty of confidentiality continues to apply after termination of employment or after the entrusted task has been carried out.


Ethically reprehensible activity must be reported

Raising concerns about any illegal and ethicallyreprehensible activity is considered a contributionto the positive development of the group. Ethicallyreprehensible activity is understood as the violation ofall laws and regulations, these Ethical guidelines, andother internal rules that govern group activities.

there are a series of internal channels through whichone can express ethical concerns. it is advised thatyou first contact your immediate supervisor, and whennecessary follow-up with his or her supervisor, unionrepresentatives, and the safety deputy. it is a funda-mental goal to ensure that problems are solved as soonas possible as to when and where they took place. thegroup’s senior management has the responsibility ofproviding a process to solve problems that arise. if theexisting circumstances prevent you from accessingany of these channels, you should report the problemyou are experiencing to a special hotline. in some casesit will be appropriate to report activity to external aut-horities, typically supervisory authorities or the police.

the group should be characterized by an open corpo-rate culture where it is acceptable to raise concerns,and to complain about ethically reprehensible activity.When you raise concerns in a responsible way, you canexpect to be taken seriously, listened to and assuredthat someone will take steps to investigate your con-cern. You should always be informed about how the caseis being handled. You should feel certain that no adverseactions or sanctions will be taken against you after your


responsible reporting of any reprehensible activity. as ageneral rule reporting of ethically reprehensible activityis advised.

Violation of the Ethical guidelines may have consequences Violation of the Ethical guidelines may have consequ-ences to your employment in terms of a warning, or dismissal. the group shall maintain a high ethical standard in the treatment of employees who haveviolated, or who are suspected of having violated theEthical guidelines. applicable laws and current agreements shall be followed. all considerations regarding legal protection and general human rights should be taken. an employee should be treated with respect irrespective of the offence committed.

the Ethical guidelines of the group do not establish any rights for customers, suppliers, competitors, shareholders or any other individuals or units. Test your Ethicsif you face an ethical dilemma, ask yourself the followingquestions:

is this legal? does this feel right? Would you tell your family, a colleague or

a friend about your actions? Would the issue stand up to public scrutiny?

if you are in doubt, seek advice from your immediatesupervisor.


it is critical that ethically reprehensible activities andmisconduct are reported, and resolved as soon as possible. Most often this will involve your direct supervisor, or his or her manager. When it is difficult for you to make a report directly to your manager about the reprehensible activity or misconduct you have experienced, the group has established a corporate unit for the safe reporting of misconduct.

Contacting the corporate unit for misconduct intranet Email address: [email protected] telephone number +47 23 14 99 40 Mail address:

Posten norge as Konsernets Varslingsinsitutt Postbox 1500 sentrum 0001 OslO norway

Examples of ethically reprehensible activity andmisconduct that can be reported Financial improprieties, embezzlement, mail and goods

fraud, affecting customers or entreprises in the group. corruption. Environmental crime. unacceptable activity not considered a violation of

rules and regulations, but falls outside the group’s and/or society’s norms. Violation of health-, environmental- and

security regulations.

Violation of corporate governing documentation, including the Ethical guidelines.

Activity not handled by the corporate unit formisconduct. internal activity, such as personality conflicts and

the like. Reprehensible activity based on political or ethical

beliefs. Professional disagreements.

Before making a reportthe procedure for reporting shall be carefullyconducted. Before making a report you should askyourself: do i have a basis for making the report? how can i proceed? With whom should i speak?

it is expected that you disclose your name to the corporate unit for misconduct. the co-workers in this unit will strive for the confidential handling of your report. You should feel secure that the making of a report will not result in negative consequences.

Notification of ethically reprehensible activity and misconduct in the group

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ethical guidelines

Documents

ethical obligations

high ethical standards

ethical dilemma test

corporate values

groups values

groups core values

groups companyspecific

group responsibility