1.1 This code of ethics has been adopted by the board of directors of BWG Homes ASA.
1.2 The objective of the code is to establish a healthy corporate culture in which employees follow good business practice standards and assume shared responsibility in upholding our reputation and corporate social responsibility. In addition to ensuring that BWG operates in an ethical manner, the code also acts a tool for the exercise of value-based management and employee participation.
1.3 The code applies to employees of BWG Homes and the Group's subsidiaries ("BWG"). It also applies to shareholder-elected board members when they act on behalf of the company. All employees of BWG shall comply with this code. The board is responsible for ensuring compliance with the code.
2. FUNDAMENTAL ETHICAL PRINCIPLES
2.1 BWG expects employees to demonstrate fairness, honesty and professional and personal integrity in their dealings with their employer and colleagues, customers, suppliers, shareholders, competitors and BWG's other stakeholders.
2.2 BWG does not tolerate discrimination on the grounds of ethnicity, nationality, religion, age, gender, disability or sexual orientation. Respect for the individual is fundamental; everyone shall be treated with dignity and respect.
2.3 BWG does not tolerate corruption. Employees of BWG shall neither directly nor indirectly offer, promise, give or accept bribes. The same applies to illegal or inappropriate gifts or other unreasonable advantages or benefits in order to obtain gains for BWG or personal gain.
2.4 BWG requires employees to comply with legislation and regulations in the countries in which the company operates. The internal guidelines also apply in these countries, provided they do not contravene current legislation.
3. ETHICAL GUIDELINES
BWG employees shall demonstrate honesty and professional and personal integrity. BWG expects all employees to actively contribute to value creation and the positive development of BWG's reputation through the exercise of value-based management and employee participation in an open and stimulating corporate culture, which is characterised by high ethical standards and continuous improvement. The values will help managers and employees to deal with dilemmas in working life with optimum efficiency. The fundamental ethical principles and values will also help ensure that BWG acts as a socially responsible player.
BWG's Norwegian and Swedish operations have established values in their own internal value processes.
Norwegian values: "We are proactive, reliable and future-oriented."
Swedish values: "We are open, honest and responsive. We help each other. We take responsibility. We are constantly developing. We are profitable. We are committed."
3.2 Working environment
3.2.1 BWG shall be a professional, positive and stimulating workplace with an inclusive working environment.
3.2.2 BWG shall comply with all requirements laid down in relevant legislation and endeavour to establish working methods that ensure a good and safe working environment. BWG shall not make use of child labour.
3.2.3 All employees shall help create a working environment which is free of discrimination on the grounds of ethnicity, nationality, religion, age, gender, disability or sexual orientation. BWG does not tolerate behaviour that may be perceived as derisive, humiliating or threatening.
3.3 Relationship with contractual partners, competitors and government authorities
3.3.1 Contractual partners shall be treated with due respect.
3.3.2 BWG shall maintain constructive, open dialogue with government authorities.
3.3.3 BWG aims for fair, open competition in all markets. Under no circumstances shall BWG or any of its employees participate in activities that contravene current competition legislation.
3.3.4 BWG does not tolerate any form of bribery or corruption. BWG will take necessary action to avoid being involved in financial transactions that may involve money laundering.
3.4 Loyalty, conflicts of interest and duty of confidentiality
3.4.1 BWG requires all employees to show loyalty to the company and to refrain from any actions or interests that may impede their ability to perform their work objectively and effectively.
3.4.2 Conflicts of interest should be avoided. If a conflict of interest arises, the employee in question is responsible for assessing the situation and, if necessary, notifying a superior. This applies to all conflicts of interest that may involve customers, suppliers, current or future employees, competitors or other stakeholders.
3.4.3 All employees shall keep secret all confidential information about BWG, in order to avoid unauthorised parties gaining access to it, and shall show due caution in conversations about internal matters, in order to avoid being overheard by unauthorised parties.
3.4.4 Only the CEO and chairman of the board, or a person delegated by them, may make public statements on behalf of BWG with regard to financial conditions, future prospects and the board. The CEO and CFO are BWG's spokespersons in communications with the financial market.
3.5 Trading in BWG shares, accounting and reporting
3.5.1 BWG employees who have access to information that may affect the value of the company’s shares shall not disclose such information and shall act in accordance with current legislation and BWG’s rules on insider trading.
3.5.2 BWG shall establish accounting procedures and ensure that all transactions are registered in accordance with current reporting standards and generally accepted accounting principles. All employees are required to follow BWG's accounting procedures and guidelines.
3.5.3 All reporting by BWG shall be in accordance with current legislation and regulations, and shall be complete, accurate, comprehensible and timely.
3.6 Compliance, control and sanctions
3.6.1 As an integral part of internal control and external audits, BWG shall regularly ensure compliance with all aspects of this code of ethics.
3.6.2 Any questions or uncertainty concerning interpretation or application of the code of ethics should be addressed to the managing director of the relevant subsidiary or, if appropriate, to the chairman of the board of the subsidiary.
3.6.3 Any violation of the code of ethics shall be reported immediately to the managing director of the relevant subsidiary or, if appropriate, to the chairman of the board of the subsidiary.
3.6.4 Employees shall also have the facility to report censurable circumstances to an independent notification committee in accordance with established notification procedures. The privacy of the notifier and the subject of the notification shall be respected.
3.6.5 The managing director or board of the relevant subsidiary shall without delay investigate all reported instances of violation of the code of ethics and take necessary and preventive action.
3.6.6 All serious violations of the code of ethics shall also be reported to the board of BWG Homes ASA.