1. Introduction

In connection with the work on the Transparency Act, Eiendomsfinans Drift AS (hereinafter “the Company”) has prepared guidelines for its own internal relationships, suppliers, business and partners.
The Company’s suppliers, business and partners (hereinafter “Suppliers”) are central to the ability to carry out our business. We want our business relationships to be based on trust and transparency, and for our suppliers to share the Company’s approach to ethics and compliance.
The Company works to promote good working and environmental conditions in its supply chains, in close collaboration with our suppliers, business and partners. The Company’s Supplier Code of Conduct (hereafter “Code of Conduct”) expresses our expectations and sets out our requirements for all Suppliers.
Our Code of Conduct is based on applicable laws and regulations, key UN conventions and ILO conventions. The Company expects our Suppliers to follow applicable legislation, respect internationally recognized human rights, and follow ethical standards that correspond to the substantive content of our Ethical Guidelines when they work for and/or together with the Company. Suppliers must also ensure that the same is passed on to subcontractors who contribute to work for the Company.

2. Laws and regulations

The company respects all international and nationally recognized human rights, including the UN’s Universal Declaration of Human Rights (1948) and its related conventions, as well as Norway’s Act on Strengthening the Status of Human Rights in Norwegian Law (Human Rights Act) of 21 May ¹⁹⁹⁹¹.
The company is committed to conducting due diligence in accordance with the OECD Guidelines for Multinational Enterprises, which entails identifying, preventing, mitigating and accounting for how the company manages existing and potential negative impacts of its operations.
Our Suppliers play an important role in helping us realize these commitments and goals. It is expected that our Suppliers have guidelines that live up to the Company’s Ethical Guidelines, internationally recognized conventions and relevant national legislation in countries where the Supplier operates. The Supplier’s operations shall be legal.
Suppliers should have a particular focus on those most vulnerable to negative impacts on human rights and decent work requirements.
This document describes standards that the Company’s Suppliers are encouraged to follow.

3. Human and employee rights

3.1 Freedom of organization and the right to collective bargaining ²

The company’s suppliers must ensure and recognize the right to freedom of association and collective bargaining. Suppliers shall respect the right of employees to establish or join trade unions or employee organizations.

Employees must have the right to bargain collectively, without fear of threats or reprisals. Suppliers shall not discriminate against employees’ representatives or trade union members, who shall be allowed to carry out their work as representatives in the workplace.
Where freedom of association and collective bargaining are restricted by national law, Suppliers shall ensure that employees are free to choose their own representatives.

¹A total of nine conventions elaborate on the UN Universal Declaration. Of these, the UN Convention on Economic, Social and Cultural Rights (ECHR) and the UN Convention on Civil and Political Rights (SP), which were adopted in 1966, are the most central. In addition, the ILO’s core conventions on fundamental rights and principles in working life are mentioned.

²See ILO Convention No. 87 concerning Freedom of Association and Protection of the Right to Organize (1950), Convention No. 98 concerning the Right to Organize and Collective Bargaining (1951), Convention No. 135 concerning the Protection of the Rights of Workers’ Representatives in Enterprises and their Facilities for the Exercise of their Activities (1973), and Convention No. 154 concerning the Promotion of Collective Bargaining (1983).

3.2 Forced labor ³

Suppliers must not use any form of coercion in connection with employment or working conditions. Suppliers shall ensure that the employment relationship between the employee and the Supplier is based on voluntariness and without threats of any kind.
In addition, Suppliers shall ensure that all employees are free to leave the workplace or terminate their employment upon reasonable notice to the Supplier.
Employees shall not be required to deposit money, identity papers or the like for the purpose of being hired or maintaining an employment relationship.

3.3 Terms of employment and working hours ⁴

Suppliers must comply with the working environment regulations in the country of production, including paying their employees in accordance with any national legal standard for minimum wages. Wages shall be contractually agreed in writing and transferred to employees at the agreed time.
Suppliers shall ensure that all employees have written employment contracts that describe the terms and conditions of employment in a language that the employee understands.
Suppliers shall provide all workers with compensation, insurance and social security benefits that meet minimum legal standards, national collective bargaining agreements and internationally recognized human rights standards of equal pay for male and female workers of equal value. As a minimum, such compensation includes wages and paid leave that allow for an adequate standard of living.
We expect our Suppliers to refrain from imposing excessive hours of work and overtime that unreasonably interfere with the right to private and family life. Working hours must not endanger the individual worker’s health and safety. National working time regulations must be observed. Workers shall be able to refuse excessive overtime without risk of discrimination or retaliation.
Suppliers shall comply with national requirements for regular employment conditions, including employment contracts.

3.4 Equality, diversity and inclusion ⁵

We expect our Suppliers to have plans and strategies for working with diversity, equality and inclusion.
Suppliers shall promote equal opportunities in employment and shall have zero tolerance for direct and indirect discrimination on the basis of, but not limited to, gender, race, color, religion, ethnic, national or social origin, marital status, sexual orientation, political or other beliefs, trade union membership, nationality, disability or age. Suppliers shall prevent unfair dismissal.
Suppliers shall treat all employees fairly and strive for gender balance, diversity and inclusion throughout the business and at all management levels. Suppliers shall act actively if deviations from this are observed.
No employee or worker shall be subjected to physical, sexual or psychological harassment, humiliation or abuse.

³Cf. ILO Convention No. 29 on Forced Labor (1932) and Convention No. 105 on the Abolition of Forced Labor (1959).
⁴ Cf. ILO Convention No. 1 on the 8-hour day (1921) and Convention No. 14 on weekly rest in industrial enterprises (1923).
⁵ Cf. ILO Convention No. 100 on Equal Remuneration for Male and Female Workers for Work of Equal Value (1953) and Convention No. 111 on Discrimination in Employment and Occupation (1960).

3.5 Child labor ⁶

Suppliers must not use child labor or any form of work that deprives children of their childhood, potential or dignity, which may be dangerous or an obstacle to the child’s education, or harmful to the child’s health or physical, psychological, spiritual, moral or social development. By “child” shall be understood a person who is under 15 years of age, under the minimum age for completion of compulsory schooling or under the legal employment age in the country in question. The highest of the aforementioned age options shall apply. If national regulations set a higher age limit, this is the limit that applies.
If the Supplier uses workers under the age of 18, the Supplier must be able to document that the worker does not perform work that is harmful to health or dangerous, including overtime and night shifts.

⁶Cf. UN Convention on the Rights of the Child and ILO Convention No. 79 on Night Work for Youth (Non-Industrial Occupations) (1950), No. 138 on Minimum Age for Admission to Employment (1976), Convention No. 182 on Prohibition of and Immediate Measures to abolishing the worst forms of child labor (2000) and ILO Recommendation No. 146 on the minimum age (1973).

4. Health, safety and environment

Health, environment and safety are very important to the Company. Suppliers shall provide and maintain a safe working environment in accordance with applicable legislation and encourage good health and safety practices.
Suppliers are expected to establish sound measures to prevent accidents and occupational diseases, including taking out all legally required insurance. Work-related accidents shall be reported to relevant authorities, investigated and preventive measures taken.
Suppliers are expected to have a written policy, employee handbook, statement or similar covering health and safety that is communicated and made available to all employees and accessible stakeholders.

5. Climate and environment

We expect our business partners to work actively and systematically to minimize negative effects on the climate and environment, including reducing greenhouse gas emissions. We expect business partners to implement measures to reduce the negative impact on valuable species and biodiversity in our projects.
Business partners must comply with all statutory environmental standards, including national regulations for climate and the environment, requirements for the protection of biodiversity, site protection and pollution. Relevant emission permits must be obtained where necessary.

6. Doing business ethically

6.1 Business Integrity

The company’s suppliers are expected to act ethically, responsibly, fairly and professionally at all times. Suppliers must respect the laws that regulate their business and must avoid harming people, the environment and the Company’s reputation. It is also expected that this will be strived for using any subcontractors in the supplier’s delivery to the Company.

6.2 Anti-corruption

The company has zero tolerance for corruption and influence peddling, and bribery must not occur between us and our business partners. The Company’s Suppliers shall actively reject all forms of corruption and shall comply with laws and regulations relating to bribery, corruption, anti-money laundering, fraud and other illegal business activities.
Suppliers shall not offer, solicit, promise, receive or give any form of improper advantage, favor or incentive to anyone for the purpose of obtaining personal or business advantage. This applies regardless of whether this benefit is offered directly or indirectly through others.
Suppliers are expected to develop and implement anti-corruption guidelines, internal control measures and training that are proportionately adapted to their business.

6.3 Anti-money laundering and tax/duties etc.

The company’s suppliers must distance themselves from all forms of money laundering and establish reasonable measures to prevent and deal with the business being used for money laundering and terrorist financing. Suppliers must comply with applicable tax regulations and not contribute to tax evasion or otherwise misappropriate public funds.
All accounting information must be correct, registered and recorded in accordance with national regulations. Suppliers must fulfill their obligations to pay taxes and fees in the state in which they are established, and/or in Norway.

6.4 Competition

The company’s Suppliers must comply with competition legislation and must not cause or be part of a breach of competition legislation, such as by illegal collusion on price, illegal market collusion or any other form of behavior that entails a breach of competition legislation.

6.5 Conflicts of interest

Suppliers must avoid conflicts of interest while working on behalf of the Company. Suppliers’ business decisions shall not be motivated or influenced by personal circumstances or interests.
The Company’s Suppliers shall, without undue delay, inform the Company of circumstances that may create problems for the Supplier’s independence, or that may create, or appear as, a conflict of interest in the execution of the assignment.

6.6 Privacy and information security

Suppliers shall comply with the applicable privacy and information security legislation at all times when collecting, storing, transferring, sharing or otherwise processing personal data.
Suppliers shall have proportionate procedures and systems in place to ensure that there is no unauthorized acquisition, use or sharing of data, information or material. Suppliers must implement the necessary technical and organizational measures to protect personal data and confidential information.

6.7 Notification of objectionable conditions

The company’s suppliers are expected to have a notification process that is known to the employee and where employees must be able to report their concerns without fear of reprisals. Suppliers shall ensure the protection of whistleblowers and the appropriate investigation, handling and resolution of reported cases.
If the Company’s Suppliers discover violations of this Code, within the Company or among subcontractors, Suppliers shall notify the Company without undue delay.

6.8 Intoxication

The company has zero tolerance for the use of all drugs in the workplace. The influence of drugs (alcohol or illegal drugs) in work situations is not tolerated.

7. Inspections and reports

As part of the Company’s follow-up of Suppliers, the Company reserves the right to check Suppliers’ and subcontractors’ compliance with these guidelines throughout the duration of the contract through audits or inspections at the Supplier or subcontractor, itself or via a third party. Each of the parties covers its own costs for such checks.

Suppliers are expected to be helpful in carrying out follow-up interviews, audits and inspections, including providing the necessary documentation within a reasonable time. The company can require this documentation in the form of:

Self-declaration from Suppliers

Own or independent third-party control
Suppliers can choose to document follow-up of the requirements by adequate certification of the company.

8. Violation of ethical guidelines

In the event of non-compliance or breach of the material requirements in the Ethical Guidelines for Suppliers, the Company will preferably ask the Supplier to remedy the situation and document this within a set deadline. In the event of non-rectification or gross violations, the Company reserves the right to apply all available contractual powers, for example suspension of delivery, termination of the contract and claims for compensation, etc.