Business Ethics

Upholding the principles of the Code of Conduct is a shared responsibility.

As an employee, you should be familiar with it and consider how it applies to your own work. You are encouraged, and must feel free to report possible breaches.

At NCC, we strive to achieve long-term business relationships as a basis for generating customer value, shareholder value and secure workplaces that promote development. We achieve this through our actions – demonstrating to our customers and other stakeholders that we are a reliable and honest company that always meets its commitments.

That is why it is equally important to communicate our Code of Conduct as a natural part of cooperation with business partners and other third parties.

Laws, regulations and international conventions

It goes without saying that NCC complies with laws and international conventions. This means that we always respect and comply with the legislation and regulations relevant to our operations. We expect all employees to be aware of the laws and regulations that apply to their specific function or role.

Business relations

At NCC, we are honest and open in our relationships with business partners and third parties, and we expect our business partners and their suppliers to behave in the same way. We honor our commitments and respect the agreements we have entered into. We expect our business partners to communicate our values, or if their own values are similar, throughout the supply chain. We expect them to act and demonstrate that they comply with our or their own, similar values /code of conduct.

Practical guidelines

I act in compliance with and respect the shared decisions and regulations at NCC and the commitments that NCC has. I am guided by the values of honesty, respect and trust.

Anti-bribery and anti-corruption

At NCC, we are committed to securing business solely on the merits and integrity of our products, services and people. We do not tolerate bribery or corruption. We will not give or offer anything of value to a government official or company representative to influence a discretionary decision.

Practical guidelines

I always show care and restraint, and include a professional/serious part, if I offer a gift to customers, public officials, subcontractors, suppliers, consultants or other external stakeholders, or if I invite these individuals to participate in dinners, parties, sport events and any other form of business entertainment.
I do not accept hospitality or a gift from anyone with whom NCC has, or will have a business relationship if it represents more than common business courtesy, creates a sense of obligation or is contrary to NCC’s policies of care and modesty.
I convince business partners of NCC’s position through the strength of my commercial argument.
I never provide anything of value to a public official unless I have confirmed that it is legal and consistent with NCC Compass, the stakeholders own regulations/guidelines or other industry guidelines.
I never distort the true nature of any transaction. I do not use a third party, such as an agent or distributor, to pay a facility payment or bribe.
When in doubt, I turn to the Ask Me function for guidance.

Competition Law

NCC competes forcefully in the marketplace to meet our customers' needs and enhance shareholder value. We do not enter into agreements or engage in activities that restrict competition. For example, we do not permit any form of anti-competitive behavior such as pricing collaboration, cartel building or abuse of its market dominance. We support appropriate and unrestricted competition with regard to bids, tenders, procurement and purchasing in all phases of its operations.

Practical guidelines

I do not enter into any contracts with competitors without first having checked the situation with my business area’s legal counsel.
I never enter into any agreement concerning price fixing or market sharing. If I am asked to participate in such an agreement, I firmly reject the offer in a way that cannot be misunderstood. Leave the meeting, document the event and report it to your manager and your business area’s legal counsel.
I am particularly careful in my relationship with competitors.
I always make sure that all meetings are documented.
I am particularly careful if NCC holds a dominant position in any relevant market
When in doubt, I turn to the Ask Me function for guidance.

Conflicts of interest

A conflict of interest exists whenever someone’s private interests interfere, or appear to interfere, with those of NCC. As employees at NCC, we are obliged to inform our immediate superior of any business activity that we conduct outside the NCC Group. We may not work in any way or participate indirectly in business activities for an organization that is in competition with, or does business with, NCC. We may not engage in activities that could lead to conflicts of interest or be used for personal gain in relation to business partners. This includes providing or accepting personal gifts or services, or participating in expenses-paid activities beyond normal business requirements. It also includes seeking or making any form of promise connected to the acceptance of gifts. As employees, we must disclose personal conflicts of interest to our immediate superior.

NCC as a company does not make contributions or donations to political organizations. While the company does not subscribe to any party-political position, employees are encouraged to take an active interest in social issues and topical debate.

Practical guidelines

As an NCC employee, I avoid any situation where I am in a position to potentially exploit my professional capacity in some way for personal benefit, or am at risk of biasing a decision in a way that contradicts NCC’s interests.
I promptly disclose any potential conflict of interest to management since, in certain cases, such activity may require the prior approval of NCC.
I do not engage in a private and personal relationship with a fellow NCC employee who directly or indirectly reports to me without first informing my manager.
If I am uncertain as to whether an activity I am engaged in constitutes a conflict of interest, I turn to the Ask Me function for guidance.

Anti-Money laundering

NCC will follow the laws that apply to prevent money laundering to occur. Money laundering is various types of arrangements to conceal criminal activity or present them as legitimate with regard to making criminal payment of money become legitimate.

Practical guidelines

I take realistic steps to identify and assess the integrity of our business partners and ensure they are engaged in legitimate business activities.
I am cautious if asked to transfer money to a receiver or country that is unrelated to the transaction.
I raise questions if I see suspicious activity. Resolve your concern with a member of NCC Treasury, NCC Legal or NCC Security.

Information and social media

Only explicitly authorized persons are allowed to speak on behalf of NCC. As NCC employees, we are all aware of the clear distinction between our own personal views and views that represent an official NCC company position or NCC´s views. We are careful not to disclose confidential information belonging to NCC or others, except to those who have a legitimate need to know and who are authorized to access the information. Information shared through instant messaging, texts, blogs and social networking sites can be far-reaching, permanent and have a negative or damaging impact on you as a private person, NCC and our stakeholders.

Practical guidelines

I use caution when discussing company business or working on a laptop or other IT devices in public.
I do not access, use or disclose confidential information without appropriate management authorization.
I never allow third parties to access NCC facilities without appropriate authorization.
I refer all inquiries from analysts or investors to NCC Investor Relations.
If I want to use media tools to describe my work day or my work at NCC as an NCC employee, I am clear about who I am and what I work with and respect the NCC values and Code of Conduct.
I never give the impression that I am speaking on behalf of NCC in any personal communication, including media tools (such as online forums, blogs, chat rooms, podcasts, Facebook, LinkedIn, Twitter, etc.), without proper authorization.
If I see something inappropriate or anything that NCC should act on, I inform NCC´s Head of Digital.
Before talking about company matters with media, I take advice from NCC Group Communication.

Privacy

NCC only collects and processes the personal information of consumers, employees and third parties in compliance with applicable privacy laws and relevant NCC policies. Confidential employee information is maintained securely and, unless required by law, may only be disclosed to individuals with proper authorization to receive such information.

Practical guidelines

I ensure that personal data is collected only for law- ful, legitimate purposes – “good to have” is not a valid reason.
I never share personal data except with those employees or associates who have a legitimate business need for the information, and always in accordance with applicable privacy laws.
When in doubt, I take advice from NCC HR or NCC Compliance.

Human Rights

At NCC we support and respect international conventions concerning human rights and promote diversity and equality.