Privacy Policy

INTRODUCTION

This Policy is a tool describing the ethical principles to which the Company is committed and is intended to affect behaviour and the company culture within the Company.

PURPOSE

The purpose of the Ethical Guidelines is to provide basic principles for behavior and business practice. Adherence to these Ethical Guidelines is a prerequisite to maintain a good standing and trust in the market and shall ensure that our conduct complies with relevant legislation and our core values both internally and externally. We shall treat other people with dignity and respect and maintain a good reputation as a trustworthy business partner.

APPLICABILITY AND SCOPE

This Policy applies to all entities within the Company, including all Co-workers. It is a manager responsibility to ensure that the Policy is distributed and made available to all Co-workers and to ensure compliance with the Policy.

LEGISLATION

This Policy is governed by the Norwegian Penal Code and the Norwegian Working Environment Act, anti-discrimination legislation, applicable Norwegian rules pertaining to Securities Trading, the Norwegian Competition Act, and the Norwegian Marketing Act, all with ancillary regulations. code of conduct

Working environment and personal policy INRIGO shall be a valuable workplace ensuring personal development and an including working environment. We shall act with respect and integrity towards each other and all persons we meet in our work. Discrimination, harassment, bullying and the like is not accepted. Co-workers shall be given the opportunity to use their skills and qualifications in order to contribute to the value of the Company and their personal development.

Equality and diversity

INRIGO respects diversity and views it as strength. Our employment policy is open and fair. Discrimination of any kind is not tolerated, including discrimination based on ethnicity, colour, gender, age, disability, HIV-status, marital status, sexual orientation, religion, political or other opinion, national or social origin, or other status. Our goal is to have a workplace that is free from all discrimination and harassment.

Sexual harassment

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.

Sexual exploitation

Any sort of sexual exploitation is forbidden. Sexual exploitation is coercion and/or manipulation by a person in a position of power or influence where such person provides any type of employment related benefit to another person in exchange for any type of sexual act. 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. INRIGO is against purchase of sexual services. Purchase of sexual services may be interlinked with trafficking. Trafficking is illegal and involves breach of human rights. INRIGO’s Co-workers may not accept or solicit sexual services during or after working hours when on service on behalf of INRIGO.

Substance use

INRIGO is a drug free workplace. Accordingly, being under the influence of intoxicating substances, including alcohol, is strictly forbidden while at work. 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 act that is incompatible with alcohol consumption. No one should use or encourage others to use substances in a manner that can place the user, the Company or any of its Business Associates in disrepute or embarrassment.

Health, Security and Environment (HSE)

All activities shall be planned and executed in a safe manner to ensure protection of human life and health, the environment, equipment and property. Inrigo’s HSE strategic goal is zero incidents. All Co-workers must take personal responsibility for HSE by focusing on his or her own behaviour an openly communicate HSE issues and performance, practice knowledge sharing and by taking active steps to learn best practices. HSE performance is an important tool when hiring staff and to improve, evaluate and reward staff performance. Line management shall prove HSE leadership and implement all HSE policies.

Climate and environment

As a heavy industry enterprise, INRIGO is subject to extensive and changing laws and regulations designed to protect the environment. These include laws and regulations relating to air and water quality, imposing limitations on discharge of pollutants into the environment and establishing standards for treatment, storage and disposal of toxic and hazardous wastes. INRIGO takes the environmental responsibilities and corporate and citizenship seriously. We are highly aware of the environmental effects our activities may cause, and thus we take necessary steps to limit the impact by continuously developing technologies, practices and business opportunities compatible with sustainable development.

Society

We shall be a responsible Company and always pay respect to the societies we are part of, including their environment, culture and religion. INRIGO sees social contributions as strength in terms of taking positively part in the social development and showing responsibility towards the societies that we are part of. Our presence and operations in developing countries brings extra awareness to our role in the societies we are a part of. We shall see social contributions in the local context, considering government systems, laws and ethics as well as specific needs. In particular, we shall focus on the important role education and training plays as a method for social development and aid.

Conflict of interest and impartiality

Co-workers shall not seek to obtain advantages for themselves (or related persons) that are improper or in any other way may harm INRIGO’s interests, whether or not this constitutes criminal fraud. If you become aware of a potential conflict of interest, you shall without delay notify your immediate superior.

Confidentiality

The principle of confidentiality applies to all Co-workers. Business information must not be disclosed to third parties. The confidentiality obligations continue after the Co-worker has left the company. Strictly confidential information includes, but is not limited to:

  • Contracts and agreements – existence and content
  • Business plans and strategies
  • Technical information concerning products, vessels and equipment
  • Designs and drawings
  • Sensitive employee information such as private telephone numbers and addresses

Company resources

INRIGO’s intellectual property is highly valued. It comprises knowledge, ideas, structures and work methods. These values shall be protected and managed to the best of the Company’s interests. INRIGO shall respect the similar rights of third parties. Personal use of Inrigo’s resources is forbidden. Resources include funds, property, equipment, and other assets. The company’s resources must not be loaned, sold or donated without approval from the employees immediate superior. Co-workers shall do their best to prevent theft, damage or misuse of the company’s resources by reporting wrongful or suspicious actions by other Co-workers to the proper management level.

Information systems

Electronic communication is considered company records. Information produced and stored on Inrigo’s IT system is regarded as Inrigo’s property. INRIGO therefore reserves the right to access all such information except where limited by law or agreement. Personal use of information systems must be approved by management. The viewing of offensive material such as pornography on Inrigo’s systems is never permitted. Any downloading, storing or dissemination that is in breach of any copyright law or provision is prohibited. Any use of software in breach of any copyright law or provision is prohibited.

RESPECTING HUMAN RIGHTS

INRIGO openly supports the United Nations Universal Declaration or Human Rights and the standards advocated by the International Labour Organisation. We shall make sure that all our activities worldwide are conducted in accordance with these basic human rights standards. The most important human rights matters related to business are:

  • Freedom of expression
  • Freedom of association and collective bargaining
  • Labour standards
  • Forced labour
  • Child labour
  • Minority rights
  • Use of security forces

COMBATING CORRUPTION AND IMPROPER PAYMENTS

Accurate information, accounting and reporting All internal and external business information shall be communicated accurately and thoroughly. All accounting information shall be accurate, registered and quoted in compliance with applicable laws and regulations, including relevant accounting standards. All intentional actions which communicate incorrect accounts will be treated as fraud.

Corruption

Corruption undermines legitimate business and involves distortion of competition, is detrimental to the business reputation and exposes the company and individuals for risk. INRIGO is against all forms of corruption and shall work actively to ensure this does not exist in the Company. Co-workers must not offer any party anything of value in order to obtain an improper advantage in selling goods and services, conducting financial transactions or representing Inrigo’s interests to governmental authorities. The Company and its Co-workers shall not accept gifts or services (including dining and similar entertainment) of more than symbolic, nominal value, unless approved in writing by appropriate senior management. Any demand for or offer of sensitive material or questionable payment in any form made to any INRIGO Co-worker must be rejected and reported immediately to management. Examples of items that never is acceptable to give or receive, regardless of value:

  • Cash and checks
  • Drugs or other controlled substances
  • Product and service discounts not available to all employees
  • Personal use of accommodations or transportation
  • Payments of loans used to purchase personal property

INRIGO Co-workers shall not, in order to obtain or retain business or other improper advantage in the conduct of business, offer, promise or give any undue advantage to a public official or a third party to make the official act or refrain from acting in relation to the performance of her/his official duties. This applies regardless whether the advantage is offered directly or through an intermediary. Corruption is not tolerated in INRIGO and violations will lead to disciplinary actions.

Financial inducements

Financial inducements are considered as corruption at INRIGO. Co-workers may never receive or offer payments, grant services etc. in order to induce others to act illegally or dishonestly. Bribes or secret payments or commissions received or made by Co-workers are strictly prohibited.

Public Officers

INRIGO shall not accept gifts or payments or offer any value to Public Officers, except when this is explicitly accepted by the CEO. INRIGO may within reasonability, cover expenses for Public Officers in connection with business activities. Such costs may be reasonable travel, lodging and training costs when this is legitimate due to business reasons. In no event shall such expenses be covered if this represents a breach of the Public Officer’s duties.

Fair competition and competition law

INRIGO shall compete in a fair at ethical responsible manner within the frames of antitrust regulations and competition laws applicable to the markets in which INRIGO operates. This applies to business relations to competitors as well as customers and suppliers.

Gifts, hospitality and expenses

INRIGO’s Co-workers shall not, directly or indirectly, accept or offer gifts from or to any Business Associate or anyone closely related to a Business Associate, unless such gift is modest. Monetary gifts shall under no circumstances be accepted or offered. Gestures of etiquette such as social gatherings, meals or entertainment may be accepted or offered if it is based on commercial interests and the cost is at a modest level. Travel and lodging costs of Company employees shall in no event be covered, either directly or indirectly, by a Business Associate. Neither shall INRIGO offer to cover such expenses for any employee of a business associate.

BUSINESS RELATIONS

Due diligence on corruption and human rights INRIGO shall manage its business in a trustful manner. All Business Associates is expected to have implemented ethical standards corresponding to those of INRIGO. Before making significant commitments or enter into major projects with new Business Associates, we must ensure that we have sufficient information about such potential Business Associates to determine whether the business relationship may expose INRIGO to corruption or human rights issues. The closer the cooperation/relationship, the more important it is for INRIGO to have detailed information of the Business Associate. Thus, it may be appropriate to perform a thorough due diligence investigation of the potential Business Associate, including the evaluation of reputation risks.

  • Inform existing and potential Business Associates about INRIGO ethical guidelines and views on human rights and corruption. Obtain the same information from the relevant business associate. Determine differences and prepare an action plan if relevant.
  • Require representations and warranties on adherence to human rights and anti-corruption legislation in the contract, as well as a right to terminate immediately in the event of breach of such representations and warranties.
  • Consider to perform due diligence investigations covering integrity and human rights when entering into projects with unfamiliar Business Associates.

COMPLIANCE

Disciplinary actions Non-compliance with the Policy and/or relevant legislation may involve disciplinary actions or dismissal and may be reported to relevant public authorities.

Complaints and expressions of concern

Employees who feel the need for advice or support in the face of an ethical dilemma should consult their line manager or another in INRIGO they trust. Employees are encouraged to notify violations of the Company's ethical guidelines or current law so that the business can be corrected. Enquiries will be handled confidentially, if desired.

Protecting the “whistle-blower”

INRIGO will not impose sanctions or other forms of retribution against any individual who notifies of censurable conditions at the Company provided that the individual adheres to the Whistle-Blowing Policy.

IMPLEMENTATION

This Policy has been approved by the Board of Directors or the CEO of Inrigo and shall be effective as of 01.01.2019 and the Policy will be reviewed periodically and may be amended to meet changing circumstances. Any exceptions to this Policy, where absolutely necessary, will only be granted in exceptional circumstances and only with approval of the CEO of Inrigo or a representative expressly appointed by the CEO.