1. INTRODUCTION
1.1 These ethical guidelines have been adopted by the board of Selvaag Bolig ASA. The intention is that they will also be adopted by the boards of all Selvaag Bolig’s subsidiaries.
1.2 The purpose of the guidelines is to establish a healthy corporate culture and to preserve Selvaag Bolig’s integrity by helping its employees to comply with standards for good business ethics. They are also intended to be a tool for self-assessment and for further development of Selvaag Bolig’s identity.
1.3 The guidelines apply to directors, the president and CEO, all managers and employees in, and partners of, all the companies which form part of the Selvaag Bolig group.
2. ETHICS
2.1 Selvaag Bolig’s basic rules require that the directors and the employees maintain a high standard of ethics and personal morality in the discharge of their duties for the company. The directors and the employees must seek to act fairly, honestly and with personal integrity in their dealings with other employees, business contacts, customers, the general public, the business community, shareholders, suppliers, competitors and government agencies.
2.2 Neither the directors nor the employees must seek to gain unreasonable benefits through manipulation, concealment, misuse of confidential information, misleading presentation of significant facts or other dishonest methods when acting on behalf of Selvaag Bolig.
2.3 The company does not accept any discrimination of employees, shareholders, directors, customers and suppliers on the basis of ethnicity, nationality, age, gender or religion. Everyone must be treated with dignity and respect, and must not be improperly prevented from discharging their duties and responsibilities.
3. ETHICAL GUIDELINES
3.1 VALUES
Warm, customer-oriented values
In order to live up to its vision and ambitions, Selvaag Bolig has two values which will characterise everything it does: concern for others and creativity. Concern for others and creativity are precisely the way the company develops properties for the enjoyment of generations.
Concern for others
Concern for others refers both to an overall responsibility to society and to an immediate responsibility to individual customers and employees. In a broad perspective, Selvaag Bolig demonstrates its concern for others by building homes for the great majority, making a positive contribution to society and protecting the environment, life and health. Its employees show concern for each other and its customers through such small acts as helping each other, providing good advice, being trustworthy, thinking of the details and showing gratitude.
Creativity
Selvaag has been breaking new ground and setting standards for housebuilding in Norway ever since 1948. It is the ability to generate good ideas and to convert these into practical action and the creation of something which has brought Selvaag Bolig to its present position. This creativity will be applied by the company to matters both large and small. It will invest in good ideas and develop new methods and concepts. Selvaag Bolig will think innovatively and search for better solutions.
Its values are described in greater detail in its “little red book”: Concern for others and creativity.
3.2 ETHICAL STANDARDS
Selvaag Bolig is concerned to maintain high ethical standards, and its values, its behaviour and its attitudes will reflect that. The company wants everyone – customers, other external parties and employees – to feel secure in their dealings with it, and it accordingly has ethical guidelines which establish a norm for good and responsible behaviour. Selvaag Bolig’s ethical guidelines apply to all its employees and, combined with its values, will support a healthy business culture of which it can be proud. Though high ethical standards and a strong internal culture, the company creates confidence and a good reputation, and demonstrates to its customers and the world at large that it is to be trusted. The ethical guidelines establish a norm for what is regarded as good, responsible behaviour in the group, but they are not exhaustive.
The ethical guidelines apply to all directors, managers, other employees and everyone acting on behalf of Selvaag Bolig and its subsidiaries. Ensuring that everyone is familiar with, understands and complies with these guidelines is a line management responsibility. Managers must also ensure that breaches generate a reaction and take the lead in setting a good example of ethical behaviour. Employees have a responsibility to read and comply with the guidelines, and must be prepared to take the consequences of a possible breach.
3.3 HONESTY AND INTEGRITY
Selvaag Bolig’s employees will be trustworthy in everything they do, and ensure compliance with laws and statutory regulations. They keep their promises, both written and verbal. They will be honest and fair with each other and with the world at large. As employees of the Selvaag Bolig group, they undertake to comply with laws, statutory regulations and internal guidelines, show responsibility and do their work safely and conscientiously. They will behave with honesty and integrity, treat everyone with respect and behave well towards business contacts, colleagues and others.
3.4 COMPANY PROPERTY AND OTHER ASSETS
Employees will treat the Selvaag Bolig group’s property and other assets in a safe and acceptable manner. They must respect access controls and security rules which apply for the use of the group’s assets, premises, technical IT equipment and electronic information.
3.5 COMMUNICATION AND CONTACT WITH THE MEDIA
The Selvaag Bolig group is concerned to be professional and reliable, and this will also be reflected in all its communication, information and contact with the media and the public. Employees of Selvaag Bolig must respect this requirement, and be conscious of how they represent the group. Statements to the media must only be made in accordance with the authority matrix in force at any given time or in consultation with the chief executive of Selvaag Bolig. Statements to the media on behalf of the company and the group will be made by the chief executive of Selvaag Bolig, with the exception of project-specific cases where the project director can comment by agreement with the chief executive.
3.6 AUTHORITY
All decisions in the group must be taken at the correct level, by the correct person as specified in the internal authority provisions applicable at any given time. An employee may only give an undertaking on behalf of the company if they are specifically authorised to do so, and must adhere at all times to their designated authority.
They must also be familiar with their competence, and not exceed their expertise in a way which could go beyond the delivered or perceived quality of Selvaag Bolig’s deliveries.
3.7 LEGISLATION AND STATUTORY REGULATIONS
Selvaag Bolig will comply with applicable legislation, statutory regulations and official orders in the country in which the company operates. The directors have a duty and the employees have a personal responsibility to observe the standards and restrictions which apply. That includes rules related to accounting and auditing as well as internal rules (as long as these do not conflict with applicable legislation).
3.8 WORKING ENVIRONMENT
Selvaag Bolig will be a professional and positive employer, and create a good working environment. Employees will have mutual respect for each other and for the company. They will show trust in each other and help each other to achieve success through collaboration. Everyone will work to promote an open culture, where difficult issues and conflicts are tackled, but it is permissible to disagree on objective grounds. The working environment will give each individual the opportunity to achieve personal growth and development, and each employee is responsible for encouraging expertise development, for taking a responsible approach to their work and for sharing their knowledge.
The Selvaag Bolig group wants a high level of job satisfaction among its employees, and will make provision for safeguarding their health and working environment. Selvaag Bolig has adopted guidelines based on ISO standards for health, safety and the environment (HSE). These rules will also apply to all its contractors and suppliers. Neither Selvaag Bolig nor its business partners will make use of child labour.
Basic human rights are respected in Selvaag Bolig. The company accepts no form of harassment or discrimination on the basis of race, religion, nationality, sexual orientation, gender or any aspect. Behaviour which could be perceived as threatening or demeaning is not tolerated.
3.9 INTERACTION WITH CUSTOMERS, SUPPLIERS, COMPETITORS AND GOVERNMENT AGENCIES
Selvaag Bolig’s people will be recognised as trustworthy, and show mutual respect to everyone with whom they interact. The company’s ethical guidelines apply to its interaction with customers, suppliers, competitors and government agencies. The company sticks to its agreements and promises – both written and verbal.
The company treats its customers with understanding and respect, and will always seek to provide them with service in accordance with accepted internal guidelines and good business practice. It will create a competitive business, and treat both contractors/suppliers and competitors with honesty and professionalism. Selvaag Bolig is a responsible social player and treats government agencies in a responsible and open manner. Public information about the Selvaag Bolig group must only be provided by the executive management.
Selvaag Bolig will contribute to competition and combat the formation of monopolies and cartels. Under no circumstances will the company or any of its employees act contrary to applicable competition law.
The company accepts no form of corruption. Employees must display caution in accepting or giving gifts, services or other benefits from or to business contacts. Moderate forms of hospitality and social entertainment are part of normal business custom, but gifts, services or benefits which could influence the recipient’s actions in working on behalf of the group must not be accepted. Circumstances which could influence decision-making processes or could cause others to believe that such influence is being exerted are not accepted.
Selvaag Bolig is opposed to all forms of money laundering, and will take the necessary precautions to prevent its transactions from being used by others for such laundering.
3.10 PRICES AND TAXES
Internal pricing in Selvaag Bolig will be determined on the arm’s length principle. This means in principle that it operates its subsidiaries as independent companies – in other words, acts as if a subsidiary is a counterparty. That simplifies accounting and tax issues in the various units.
3.11 LOYALTY, CONFLICTS OF INTEREST AND DUTY OF CONFIDENTIALITY
Selvaag Bolig respects the private and personal interests of its individual employees, but expects them to show openness and loyalty to the group and the group’s interests. Employees must not seek to secure advantages which are inappropriate or which might conceivably harm the interests of the group. They are not permitted to have paid work, owner interests or opportunities to influence business activities if this might conceivably weaken their loyalty to the group. Employees must not participate in or seek to influence a decision in circumstances which might weaken confidence in their objectivity and independence. If they become aware of a potential conflict of interest, they must personally take the initiative to assess this and contact their superior. A conflict of interest could involve customers, contractors/suppliers, construction companies, existing or future employees, competitors or other contacts. All employees are responsible for notifying the board if circumstances arise in which the person concerned has a material interest, directly or indirectly, in a transaction or another matter in which Selvaag Bolig is a party.
All employees of the Selvaag Bolig group have a duty of confidentiality pursuant to legal enactments and their written contract of employment. They must keep confidential all commercial or other information which might give outsiders access to confidential data. They must also exercise caution in relation to colleagues who do not need to know the information in their work. The duty of confidentiality is intended to prevent unauthorised people gaining access to information which could harm the Selvaag Bolig group’s customers, employees, business or reputation. This duty also applies after the termination of employment or of the assignment. Only the chief executive and the chair, or other people to whom they might delegate this authority, are authorised to speak in public on behalf of Selvaag Bolig.
3.12 ENVIRONMENTAL ISSUES
As a responsible social player, Selvaag Bolig is concerned about its impact on the areas in which it builds homes. The company will accordingly strive to be a market leader in protecting the environment. All employees have a responsibility to be fully aware of the impact of their work on the natural environment, and to make maximum use of environment-friendly solutions.
3.13 INFORMATION WHICH COULD INFLUENCE THE SHARE PRICE AND TRADING IN SELVAAG BOLIG’S SHARES
Selvaag Bolig is subject to strict rules related to handling information which is not publically available and which could influence the market price of shares or other financial instruments issued by Selvaag Bolig. Information is regarded as likely to influence market prices if a rational investor would have reacted and taken their decisions differently were they to have had access to the information.
An employee in possession of such information is responsible for preventing it from being passed to unauthorised people or from reaching the market via channels other than the official Oslo Stock Exchange information system. Anyone who possesses or receives price-sensitive information must not trade in the relevant financial instruments before the information becomes publically available or is no longer price-sensitive. Nor must they convey such information to others, either directly or indirectly, except those who need it to discharge their duties on behalf of Selvaag Bolig.
Further information on this subject can be found in Selvaag Bolig’s internal guidelines for inside information. Anyone who is in doubt should contact the CFO or the group legal advisor. All employees must familiarise themselves with applicable legal enactments and internal guidelines on inside information before trading in Selvaag Bolig’s shares.
3.14 ACCOUNTING AND REPORTING WHEN TRADING IN SELVAAG BOLIG’S SHARES
Selvaag Bolig will establish accounting procedures and ensure that all transactions are registered in accordance with applicable legislation and rules. All employees are required to comply with the company’s guidelines for registering and documenting transactions. Each employee is responsible for reporting and documenting transactions in their entirety and in accordance with applicable accounting principles.
Selvaag Bolig’s reporting will comply for all purposes with applicable legislation and rules, and be complete, honest, accurate, timely and comprehensible.
3.15 BREACHES OF THE ETHICAL GUIDELINES
Should an employee become aware of breaches of the law or statutory regulations, or of Selvaag Bolig’s ethical guidelines, they must raise the matter with their immediate superior. If this does not feel appropriate or is not possible, they must report the incident to the group’s legal advisor, a member of Selvaag Bolig’s executive management or a director. Failure to report breaches of the law, statutory regulations or the ethical guidelines is in itself a breach of the guidelines.
Ethical self-test for employees
Should an employee face an ethical dilemma, they can ask themselves the following questions:
- is it legal?
- does it feel right?
- would I tell my family, a colleague or a friend about what I’m doing?
- would these circumstances tolerate public exposure?
3.16 CHECKS AND SANCTIONS
As an integrated part of Selvaag Bolig’s internal/external auditing, valuation and so forth, the company will regularly check compliance with all aspects of these ethical guidelines.
The board of the relevant group company will take such steps as it finds appropriate to investigate reported breaches of the guidelines. The respective boards will also report to the board of Selvaag Bolig if the breach is not insignificant.
Should a breach be discovered, the relevant board or superior will take the necessary disciplinary or preventive action – normally dismissal, cancellation of supplier contracts and so forth.
3.17 HUMAN RIGHTS
As an extension of Selvaag Bolig's own commitment to human rights, it is expected that all Selvaag Bolig's business partners and suppliers respect internationally recognized human rights in their operations and actively avoid contributing to violations of these. The supplier's approach to human rights must be in accordance with the UN's guiding principles for business and human rights and the OECD's guidelines for multinational companies.