+47 971 21 100 info@vk-spirit.com

Code of Conduct
Viking Spirit AS

1. Introduction

Our Code of Conduct specifies the requirements for the ethical business practice and personal conduct to which Viking Spirit is committed to. These are the principles upon which the Company culture is built, and it is intended to affect behaviour within the company, and how we treat other people with dignity and respect. Our Code of Conduct is reflected in how we do as a well reputable and trustworthy business partner.

The Code of Conduct has been approved by the Board of Directors of Viking Spirit and became effective as of [AGM dato], when Viking Spirit pledged to comply with the UN Global Compact. This document is reviewed periodically and may be amended to meet changing circumstances and legislation.

It is the responsibility of management to ensure that the Code of Conduct is made available to all parties, including our distributors, suppliers and service providers, and that they adhere to the Code of Conduct and conduct business in compliance with it. Non-compliance with the Code of Conduct will constitute material breach and may result in disciplinary actions, dismissal, or legal action including the termination of distribution, service and supply contracts.

In the event that any of our people come across conduct that might be in conflict with this Code of Conduct, it is mandatory to report it to a relevant manager. Each individual is encouraged to speak up upon discovering misconduct. The employees are obliged to notify their immediate supervisor about any infringement of the ethical codes. If it is not possible the issue should be raised with a member of the corporate management team.

Viking Spirit shall endeavour to ensure that all operations are conducted in strict adherence to the Code of Conduct.

2. Applicability

The Code of Conduct applies to all entities within the company, all employees (including temporary personnel), and directors in the Company, all agents, intermediaries, consultants, and others who act on behalf of Viking Spirit. It also applies to distributors, suppliers, service providers, subcontractors, and other contracting parties in a contractual relationship with Viking Spirit.

3. Working Environment and personnel policy

Viking Spirit is a valuable and inclusive workplace that is safe and welcoming for all, free from harassment and discrimination. We will act with respect and integrity towards each other and all the persons we meet in our work. Discrimination, harassment, bullying, and the like are not accepted. Co-workers shall have the opportunity to use their skills and qualifications to contribute to the value of the Company and their personal development.

Sexual harassment creates an intimidating and hostile work situation and is not tolerated. Sexual harassment encompasses conduct that is overt or sexually suggestive in content: the scope of such prohibited conduct is not limited to opposite-gender confrontations.

Viking Spirit is committed to having a drug-free workplace. It is prohibited to conduct any work on behalf of the company while under the influence of intoxicating substances, including alcohol, and narcotics. However, limited amounts of alcohol may be served when the occasion or local
custom make it appropriate to do so, provided the consumption of alcohol is not combined with operating machinery, driving or any other activity that is incompatible with alcohol consumption.

4. Health Safety and Environment

The health and safety of all employees is mandatory and non-negotiable. Line management is responsible for the implementation of HSE policies and ensuring that all activities are planned and executed in a safe way to protect human life and health, the environment, equipment, and property. All parties subject to the Code of Conduct must take responsibility for HSE by focusing on personal behaviour, openly communicate HSE issues and performance, practice knowledge sharing, and by taking active steps to learn best practices.

Viking Spirit is a responsible company working globally and always respectful of the societies we are part of. This includes their environment, culture, laws, and religion. We will strive to make positive social contributions by showing responsibility and positively taking part in social development.

5. Legislation and Legal Compliance

This Policy is governed by the Norwegian Penal Code and the Norwegian Working Environment Act, Anti-discrimination Legislation, Norwegian Competition Act, Norwegian Marketing Act and all applicable Norwegian rules pertaining to Securities and Trading.

Viking Spirit shall conform to all laws and regulations applicable at any time to the country of operation or related to activities and interests of the company. Persons subject to this Code of Conduct must adhere to laws, regulations, and prevailing internal routines, including instructions and authorizations that are connected to the individual’s position.

Employees are encouraged to notify violations of the Company’s Code of Conduct or current law so that the business practice can be corrected, following the Norwegian Working Act § 2-4. If necessary, inquiries will be handled confidentially. Whistleblowers are protected against sanctions and retribution in line with The Norwegian Working Act § 2-5

6. Corruption & Bribery

Viking Spirit conducts its business with full integrity and has zero tolerance for corruption, bribery, money laundering, fraud, and or any such financial crimes. All parties shall act professionally, fairly, and with integrity in all our business dealings and relationships, conducting business only with reputable customers and business partners. Distributors, suppliers, agents, and business partners are expected to adhere to ethical standards, set forth in the Code of Conduct, abiding by fundamental requirements on human rights, labour rights, anti-corruption, animal welfare, and the environment.

All transaction payments made must be proper and legal, approved by the right authority, and recorded accurately in appropriate records. It is prohibited to offer directly or indirectly through a third party anything of value or facilitation payment to improperly influence their actions or decisions. This is including but is not limited to government employees or public officials or private parties, in pursuit of Viking Spirit ’s business or interests.

In the event that a payment is demanded from you in order to avert an immediate threat to the life or health of any person, such payments are not prohibited. Safety is paramount; however, such incidents must be immediately reported.

Viking Spirit expects all distributors, suppliers, business partners, and parties to the Code of Conduct to share in our commitment in these efforts. All business associates are expected to have implemented ethical standards corresponding to ours, or better. Our Purchasing Policy defines our measures to ensure ethical purchasing and our due diligence measures.

7. Equality and diversity

Viking Spirit strives to be an organization free from any form of discrimination of its own employees, partners, suppliers, customers or any other person involved in our activities. We value equality and diversity which we view as a strength for the company. Discrimination based on ethnicity, colour, gender, age, disability, HIV-status, marital condition, sexual orientation, religion, political or other opinions, national or social origin, or another status will not be tolerated.

8. Human rights

Viking Spirit supports and respects internationally proclaimed human rights including the UN’s Universal Declaration of Human Rights and related UN covenants, and the core conventions of the International Labor Organization on fundamental principles and rights at work, including all employees’ right to form and join trade unions of their own choice. Viking Spirit does not tolerate child or forced labour, indecent working conditions, infringement of workers’ rights, or treatment that are in conflict with international laws. This applies to all persons subject to this Code of Conduct.

9. Sexual Exploitation

Any form of sexual exploitation is forbidden. Sexual exploitation is coercion and/or manipulation by a person in a position of power or influence, where such a person provides any form of employment-related benefit to another person, in exchange for any form of sexual activity. In such situations, the potential victim believes she/he has no choice other than to comply, thus there is no actual consent to the sexual act, which is exploitation. Viking Spirit is against the purchase of sexual services. Such services may be interlinked with illegal acts of trafficking and involve a breach of human rights. Viking Spirit employees may not accept or solicit sexual services during or after working hours when on service on behalf of the company.

10. Integrity and Conflict of Interest

Personal relationships, participation in external activities or interest in another venture shall not influence or could be perceived to influence decisions when acting on behalf by or on behalf of Viking Spirit. Potential conflicts of interest, personal, financial, or otherwise, shall be transparently communicated to avoid situations, decisions, and positions that may not be in the best interest of the company.

11. Company resources

All company resources must be protected and managed to the best of the Company’s interests. All intellectual property will be respected and treated in accordance with the company’s NDA. Personal use or exploitation of company resources such as funds, property, equipment, and other assets is prohibited unless specifically agreed upon in advance.

Information produced and stored on the company’s IT systems is regarded as Viking Spirit’s property. Viking Spirit therefore reserves the right to access all such information except when limited by law or agreement, when there is a relevant reason. Personal use of such information must be approved by management. The viewing of offensive material such as pornography on Viking Spirit ’s systems is not permitted. Any downloading, storing, distribution, or use of software, which is a breach of copyright law or provision.

Charman

Bent Karlsen