Core Values and Code of Conduct

Intention
The Byggma Group must be operated in accordance with the owners’ objectives and intentions behind their ownership. The Group depends on responsible, serious and long-term employees and owners. An important factor in achieving the company’s objectives is that the Group maintains a good reputation among society at all times. To make sure the Group achieves its objectives, the Board of Directors has adopted the following Code of Conduct. The Code generally describes the ethical principles according to which the Group must manage its business, how the Group must treat its business partners and the conduct the Group expects of its employees, as well as other parties acting on behalf of the Group. This Code is primarily a tool to describe and encourage the desired conduct and culture in the Group.

Scope
This Code comprises general provisions that apply to all employees of Byggma ASA and all employees of the Group’s subsidiaries as well as all other persons acting on behalf of the Group.
Employees must also ensure that the company operates in accordance with applicable laws and regulations in the localities where the Group is represented. Where there is doubt about whether a particular activity is legal or ethical, an immediate superior or Group management must first be consulted, as far as practically possible.

Responsibility
The Group’s Code of Conduct has been approved by the Board of Byggma ASA. The CEO is responsible for ensuring that the Code of Conduct is drawn up, maintained, implemented and complied with.
Managers at all levels have a special responsibility for ensuring that their employees and others acting on behalf of the Group are familiar with the Code and for supporting and monitoring compliance with the Code.
All employees are expected to act in accordance with the content and values of the Code. In case of doubt, employees must refrain from the action or raise the matter with their immediate superior.
All employees have an independent responsibility to report any violations of the Code of Conduct that come to their attention in the workplace. Violations of this Code will not be tolerated and may, subject to the applicable laws, regulations and work rules, result in disciplinary action, termination, dismissal and/or legal action.

Procedures for reporting ethical issues
The Byggma Group expects all employees to actively support the company’s Code of Conduct in relation to colleagues, business partners and society in general. Any violation of the Code of Conduct is expected to be reported in the same way as any criminal offence, other legal orders or prohibitions, or other set instructions or guidelines.
As a general rule, any violations must be discussed with a superior. If this is not appropriate, employees must contact another superior or manager of the company.  Alternatively, the CEO, Chairman of the Board or Chairman of the Audit Committee may be notified (see last page for contact details).

Anyone who, in good faith, reports a concern to their immediate superior, other superiors, company manager or CEO, the Chairman of the Board or the Chairman of the Audit Committee, will be protected against sanctions from the Byggma Group as a result of this action. Discriminating or harassing someone for speaking up or otherwise reporting an ethical issue will be regarded as a violation of this Code of Conduct.

Workplace, equality and personal behaviour
The workplace must promote equality, openness and tolerance. Behaviour must be based on respect for human dignity. Other cultures and customs must be respected. The Byggma Group must be characterised by equal employment opportunities and fair treatment. The Byggma Group does not tolerate harassment or discrimination based on gender, religion, race, national or ethnic origin, cultural background, social affiliation, disability, sexual orientation, marital status, age or political opinion. The Byggma Group is a drug-free workplace. This means that you must not be under the influence of drugs while working for the Byggma Group. Limited amounts of alcohol may be served in connection with events and entertainment. In such cases, consumption must not be combined with operating machinery, driving or other risk situations. Use of tobacco, snuff and suchlike must comply with the applicable laws, regulations and general rules for good hygiene. Use of Byggma’s brand logos must take the company’s reputation into consideration.

Conflicts of interest, integrity and impartiality
Attempting to obtain advantages for oneself or others that are improper or could otherwise damage the Byggma Group’s reputation and interests is not permitted. Good judgement, care, consideration and fairness must be shown when acting on behalf of the Byggma Group.

Bribery, gifts, advantages and corruption
Illegal or improper monetary gifts or other improper advantages must never be offered to anyone, including public officials, our customers and suppliers, in order to receive a business advantage. This applies regardless of whether the advantage is offered directly or through an intermediary. Gifts, paid-for trips or other benefits of a personal nature from business partners that may compromise or create doubt about the recipient’s integrity or independence or give such an impression, to the detriment of the recipient or the Byggma Group, must not be accepted. Any gifts must be of a low financial value.
Transparency must be exercised when receiving and offering gifts and other advantages.
Trips, visits and/or courses through invitation from a supplier or other business partner must be approved by a superior. Strict requirements must be set on professional content and usefulness. Such trips must normally be paid for by the Byggma Group.

Attention/entertainment
General forms of hospitality and social events are part of polite business dealings. However, the level of such attention must not develop such that it influences the decision-making process, or give cause to believe that it does. The frequency and degree of attention should be proportionate to the scope of the business.

Relationship with the employer
Employees must not profit from the company’s material or intellectual property, such as assets, special knowledge, methods, concepts or ideas.

Relationship with business partners
Employees must not act in a manner that could bring them into a relationship with the Group’s customers, suppliers or other partners of the Group which could prevent objective conduct. Suppliers must be treated impartially and fairly. Byggma Group employees must not abuse their position to obtain special advantages in their contact with business partners of the Byggma Group.

Relationship with the competition rules
The Byggma Group is a supporter of fair and open competition. Under no circumstances may the Byggma Group’s businesses or Byggma Group employees violate competition rules, for example through illegal price cooperation,
illegal market sharing or any other conduct that prevents, restricts or distorts competition in violation of current competition law.

Impartiality
If personal interests could influence the decision in a matter for which the person is responsible, or other parties could consider this to be probable, the matter must be presented to a superior. Employees must inform their superior of actual and potential bias, such as ownership interests, family relationships, close friendships, etc. in business matters and circumstances. Employees or board members must avoid having personal interests, whether directly or indirectly, in other businesses if this compromises or is perceived to compromise their loyalty to the Byggma Group.

Confidential information
Confidential information received as part of the employment relationship must be respected and not used for personal gain or brought to the attention of unauthorised parties. Information relating to prices, products, solutions and other matters of importance to business relations must not be disclosed to outsiders. If an employee becomes aware of a business secret or information of a confidential nature, including intellectual property rights or innovative ideas, during their employment, they may not pass such information on to third parties without the consent of the Byggma Group, or use such information for any other purpose than the performance of their work in the Byggma Group.

Insider trading
Employees must not trade in or give advice on trading in the company’s securities or other listed companies’ securities on the basis of non-public information which they have gained access to through their work or assignment for the Byggma Group and which, if it became publicly known, could affect the price of these securities.

Financial matters and transactions
The Byggma Group must provide complete, correct, accurate and comprehensible statements in its financial reports, and in other documents sent to public authorities as well as in all other public communications. All accounts must be kept and presented in accordance with applicable laws, regulations and good practice. All activities that entail financial consequences must be properly documented, and transactions must not be intentionally classified incorrectly, whether it involves the account, department or accounting period. The accounts must give a true picture of the Byggma Group’s assets, liabilities, income and expenses.

External communication/contact with the press
The Byggma Group’s reputation relies on our ability to communicate in a consistent and professional manner with external parties. The Byggma Group must always try to appear as open as possible and be honest, accommodating and credible in its dealings with external parties. To ensure consistent communication with external parties, general enquiries about the company or its employees and all media enquiries must be referred to the factory manager or Group management. The Group’s employees must be informed first in matters concerning their working conditions.

Corporate social responsibility
The Byggma Group requires honesty, integrity and fairness in all matters relating to our business activities. Byggma's aim is to ensure a proper and well-organised relationship with our employees, partners, the environment and society in general by always complying with our values, which are inclusive, innovative and responsible. More specifically, this means that Byggma does not make contributions to political candidates or political parties, we show respect for the culture in countries in which we operate, we seek to recruit and develop the local workforce, and promote local sourcing.

Environment and health
The Byggma Group aims to conduct its operations without harm to people or the environment, and without loss of material property. Lower pollution levels and protection of the internal and external environment must be in line with society’s requirements and conditions. The Byggma Group must promote ongoing efforts to improve health, safety and the environment in the areas it operates and the goods it supplies.

Transparency Act
The Byggma Group is required to audit all qualified suppliers. All suppliers must sign a supplier declaration confirming that they work to ensure they have a value chain that respects human rights and ensures decent working conditions. The Byggma Group’s focus on working conditions and human rights will become an even greater part of this work in the future. The Byggma Group takes a strong stance against child labour and forced labour. To ensure even better follow-up and identification of risks, we are now increasing supplier engagement through active responses in our procurement processes. The Byggma Group must map its suppliers and regularly assess them for risk. The Byggma Group must then create an overview, prioritising the areas it will focus on.

First and foremost, the Byggma Group will establish a dialogue with suppliers where it perceives a risk that the requirements of the Transparency Act are not being followed, in order to help promote respect for human rights and decent working conditions. 

Risk assessment 
Risk assessment is the Byggma Group’s work in identifying issues in the value chain where there may be a risk of a violation of the Byggma Group’s policies and Code. This is called due diligence. The Byggma Group’s due diligence process is based on the UN Guiding Principles on Business and Human Rights and the OECD’s model for Due Diligence Guidance for Responsible Business Conduct (2018).