NCC Supplier Code of Conduct

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.

NCC suppliers must:

• Comply with laws, rules and regulations of the jurisdiction in which they operate or where they provide services to NCC.
• Ensure that all reports, records and invoices are complete and accurate.
• Prohibit corruptions and bribery, such as giving or offering anything of value to a government official or company representative, including NCC employees, to influence a decision.
• Avoid situations that may present a conflict of interest in work with NCC, such as exploiting relations with business partners and NCC for personal gain.
• Be engaged in legitimate business activities where money laundering or criminal payments do not occur.
• Respect fair competition and antitrust law and not enter into any agreement concerning price fixing or market sharing.
• Not use or disclose sensitive or confidential information about NCC.
• Never share personal data except with those employees or associates who have a legitimate business need for the information, in accordance with applicable privacy laws.

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

NCC suppliers must:

• Promote equal opportunities, which applies to everyone irrespective of gender, transgender identity and expression, sexual orientation, ethnical background, religious beliefs, disability or age.
• Prohibit behavior or statements, or tell jokes, that may be understood or interpreted as degrading or humiliating to others.
• Contribute to a work environment that is free of hostile, violent, threatening or bullying behavior.
• Not engage in forced labor related activities, such as using force or threats to get a person to work, retaining their employees´ identity documents and must ensure that employees are subject to fair working hours, wages and benefits that are consistent with laws and industry standards.
• Have zero tolerance for child labor.
• Respect the right of employees to organize themselves in voluntary employee organizations and to negotiate collectively. • Encourage supply chain transparency and take reasonable efforts to avoid in its production the use of raw materials which directly or indirectly finance groups who violate human rights.

At NCC, we have a vision of zero workplace accidents and work continuously to make improvements to ensure safe and healthy workplaces.

NCC suppliers must:

• Proactively manage health and safety risks to provide an incident-free production environment where occupational injuries and illnesses are prevented.
• As a minimum, follow the applicable employment laws and health and safety laws or international labor standards as defined by an internationally recognized body e.g. ILO, whichever standard is higher.
• Ensure that employees have relevant safety training for their work.
• Take responsibility and never disregard safety devices on worksites or the need for personal safety equipment.
• Report to NCC any health and safety incidents and unsafe conditions related to NCC’s projects and work sites.

At NCC, we prioritize suppliers that are proactive and systematic in their work relating to environ- mental sustainability. Our aim is to be able to produce sustainable products with low climate impact that are traceable throughout the supplier chain.

NCC suppliers must:

• Ensure that activities allow for efficient use of resources and reduction in all types of harmful substances, focusing on climate, energy, materials and waste.
• Show a proactive approach for continuous improvement of their environmental work including the development of their products or services they provide.
• Provide managers and NCC with ideas that could lead to innovations with a positive environmental impact.

NCC’s general approach is to encourage improvement. Critical deviations or repeated unwillingness to make improvement, however, may jeopardize the supplier’s relationship with NCC.

NCC is entitled to perform audits of the supplier and be provided with the assistance needed from the supplier to establish the supplier’s compliance with NCC’s Code of Conduct and all applicable rules and regulations. NCC may engage a third party to perform such an audit on the condition that this third party does not conduct business in competition with the supplier within the field of the agreement.

NCC will act against business partners found to be in breach of our guidelines, and the relationship may be terminated, or other actions demanded, in the event of minor, repeated, or serious breaches.

Tell Me is a mechanism that enables NCC employees, suppliers, business partners and the general public to report possible breaches of the NCC Code of Conduct. All reports are investigated and treated in confidence. Read more at: www.ncc.group/report/

NCC suppliers must:

• File a report in NCC Tell Me if an employee of NCC, NCC supplier, or anyone acting on behalf of NCC, violates national laws or breaches the NCC Code of Conduct.
• Ensure that investigation or retaliations do not jeopardize the employment of NCC employees or suppliers, because they have insisted on following the NCC Code of Conduct or filed a report in NCC Tell Me.