Responsibilities of the company and employees.
Compliance with the Code of Conduct is a requirement throughout NCC: from the Executive Management Team via managers at all levels to the individual employee.
Within their specific area of responsibility, all managers have an obligation to ensure that employees and business partners are given information about the contents of the Code of Conduct and our requirement for compliance with this. NCC managers must set a good example at all times.
This Code of Conduct has been adopted by NCC AB’s Board of Directors, and the company monitors compliance with the Code on an ongoing basis as a natural part of its operations. To help employees to comply with the Code, we have created the NCC Compass – a program that provides guidance on issues concerning gifts, business entertainment, conflicts of interest and competition law.
Together with the NCC Compass, the Code of Conduct guides us in the right direction. If any employee is uncertain about how to act, a group of specially trained employees – known as navigators – are available throughout the Group for consultation. Navigators can be reached through the helpdesk called Ask Me. Employees are obliged to report any breaches of the Code of Conduct of which they become aware.
Tell Me is a reporting mechanism that enables NCC employees to bring possible breaches of the Code of Conduct or applicable laws to the attention of senior management. This facility is also available to other stakeholders such as suppliers, other business partners and the general public via NCC’s external website. All reports are taken seriously and are investigated. All reports are treated in confidence, and NCC will not tolerate any form of retaliation against employees for making “good faith” reports of violations of the Code of Conduct or relevant laws.
NCC employees found to be in breach of the Code of Conduct will be subject to disciplinary measures. We will also take action against business partners found to be in breach of our guidelines, and the relationship will be terminated in the event of repeated or serious breaches.
As a part of the NCC Compass, we monitor the adherence of NCC values and NCC Code of Conduct in several ways to get a picture of where and how improvements are needed. Indicators of the present state are: numbers of questions asked to Ask Me, incidents in the Tell Me function, media coverage, number of training sessions, statistics from the web, blog, quiz and other activities. Measurements are an important part of the NCC Compass.