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Compliance

Code of Conduct

NorTrade is committed to ethical, transparent, and responsible business operations. As a trading company, our primary responsibility is to represent the products of IMI and other manufacturers in the market at a high professional standard and in a fair manner, in cooperation with our customers and suppliers.

1. Introduction and Purpose

This Code of Conduct defines the principles, expectations, and operational standards that apply to all NorTrade employees, managers, partners, and suppliers. Its purpose is to ensure:

  • Fair business conduct

  • Compliance with laws and regulations

  • A transparent and responsible corporate culture

  • A respectful working environment for employees

2. Key Principles & Expectations

2.1 Integrity and Ethical Conduct

NorTrade expects, in all business activities: fair and honest communication, compliance with legal and professional regulations, avoidance of conflicts of interest, transparent and justifiable corporate and business decision-making.

  • Any form of obtaining unfair advantage is strictly prohibited

  • Providing misleading information is not tolerated

  • Applying unlawful methods is forbidden

2.2 Respectful and Safe Workplace

NorTrade is committed to creating a working environment where:

  • Everyone is treated with respect

  • There is no place for harassment or intimidation

  • No form of discrimination is acceptable

  • Mental safety, cooperation, and diversity are supported

2.3 Anti-Corruption

NorTrade applies zero tolerance towards bribery, kickbacks, granting or accepting undue advantages, inappropriate gifts of value, and non-transparent hospitality.

  • It is prohibited to give or accept any gift that may influence business decisions

  • Only low-value, business-justified, and transparent hospitality or gifts are permitted

2.4 Responsible Supply Chain

As a trading company, NorTrade plays a particularly important role in responsible sourcing. We expect our suppliers to:

  • Fully respect human rights

  • Completely prohibit child labor and forced labor

  • Ensure safe and fair working conditions

  • Comply with environmental standards

  • Operate free of corruption

  • Fully comply with applicable laws and regulations

2.5 Legal Compliance

NorTrade is obliged to comply in all countries with local and international laws, professional standards, data protection and competition law regulations, export and import requirements. Every employee is responsible for becoming familiar with the regulations applicable to their own role.

3. Implementation of the Code

3.1 Training and Awareness

NorTrade provides the necessary training, including:

  • Ethical and legal compliance training

  • Anti-corruption training

  • Data protection training

  • Occupational health and safety training

3.2 Reporting – Speaking Up

NorTrade supports open and safe communication. Every employee has the right and responsibility to report ethical misconduct, suspected corruption, human rights issues, harassment or discrimination, legal violations, or occupational health and safety risks.

  • Reports may be made to a direct manager

  • Reports may be made to HR / Compliance

  • Anonymous reporting channel available

  • NorTrade strictly prohibits retaliation against anyone who makes a report in good faith

3.3 Accountability

Violations of the Code may result in consequences, including:

  • Warning

  • Mandatory training

  • Modification or termination of a contract

  • In serious cases, legal proceedings

4. NorTrade-Specific Principles

4.1 Business Conduct

  • We provide only factual, credible technical and commercial information

  • We do not promise anything not supported by manufacturer documentation

  • Fairness and accuracy are paramount in all customer communications

  • Ethical business conduct is mandatory during negotiations

4.2 Cooperation with Suppliers

  • Decisions are made based on objective, documented criteria (price, quality, performance)

  • Corruption, conflicts of interest, commissions, or any form of private arrangements are prohibited

  • Supplier performance is regularly evaluated

4.3 Hospitality and Gifts

Acceptable: low-value hospitality related to business meetings, low-value gifts with a business purpose. Not acceptable: high-value invitations or gifts, involvement of family members, any benefit that may influence business decisions.

5. Data Protection and Information Security

NorTrade is committed to protecting data:

  • We collect and process only necessary data

  • All data is stored securely

  • Data is not shared with unauthorized parties

  • AI systems are used only in approved ways and without personal data

  • Unauthorized storage or sharing of personal data is prohibited

  • Use of company information for personal purposes is forbidden

6. Environmental Protection

NorTrade strives to:

  • Reduce energy and resource consumption

  • Apply environmentally friendly logistics solutions

  • Prefer sustainable products

  • Select partners who meet environmental expectations

7. Validity and Scope

The NorTrade Code applies to all employees, managers, consultants, suppliers and corporate partners. The Code is reviewed annually by management and amended if necessary.

Supplier Code of Conduct

NorTrade expects its suppliers to operate in an ethical, lawful, and responsible manner. This document defines the minimum requirements that all partners must comply with when cooperating with NorTrade. Any entity acting as a supplier of NorTrade automatically accepts the principles set out in this Code.

1. Legal and Ethical Compliance

Suppliers must comply with all applicable local and international laws, tax and labor regulations, environmental protection legislation, and anti-corruption regulations.

  • Bribery is prohibited

  • Granting or accepting undue advantages is prohibited

  • Fraud, tax evasion, money laundering are prohibited

  • Anti-competitive behavior is prohibited

2. Human Rights and Working Conditions

Suppliers must ensure:

  • A complete prohibition of child labor

  • A prohibition of forced or compulsory labor

  • A safe and healthy working environment

  • Fair and lawful remuneration

  • Compliance with laws governing working hours and rest periods

  • A total prohibition of discrimination

  • Protection of the human dignity of employees

3. Environmental Protection

Suppliers are expected to strive for:

  • Reducing energy consumption

  • Responsible waste management

  • Prevention of pollution

  • The use of sustainable materials and technologies

4. Business Integrity

Suppliers are obliged to provide accurate and truthful commercial information, ensure transparent invoicing and documentation, avoid conflicts of interest, and refrain from using their relationship with NorTrade for personal gain.

  • Falsification of documents is prohibited

  • Hidden commissions or kickbacks are prohibited

  • Offering unlawful gifts or benefits to NorTrade employees is prohibited

5. Supply Chain Transparency

Suppliers are required to:

  • Credibly verify the origin of raw materials

  • Allow audits upon request

  • Provide information relevant to NorTrade (e.g. quality assurance documentation)

6. Compliance and Consequences

NorTrade reserves the right to:

  • Evaluate suppliers

  • Require corrective or improvement plans in cases of non-compliance

  • Suspend or terminate cooperation in the event of serious or repeated violations