Ethical guidelines for the Atea Group

1 Introduction

The Group’s business operations depend on trust and a good reputation. The Group’s complex activities, with numerous employees and a number of relationships with customers in the private and public sectors, suppliers, the press and securities market, require a high degree of honesty and integrity from those who act on the company’s behalf. It is expected that all of the Group’s employees safeguard and foster the Group’s reputation by acting responsibly vis-à-vis co-workers, business contacts and society at large.

The purpose of these guidelines is to ensure that all persons acting on behalf of the Group perform their activities in an ethically proper manner and in line with the standards and guidelines in effect for the company at any given time and to help the Group comply with the laws and regulations the Group is subject to, including legislation relating to combating corruption and bribery. 

The guidelines provide a framework for what the Group regards as responsible conduct but is not meant to be exhaustive. As an employee you must always seek to exercise good judgement, prudence and consideration in your service for the Group. The Group means Atea ASA and all its subsidiaries. 

The guidelines are an internal document for the Group and do not create any rights for customers, suppliers, competitors, shareholders or other persons or entities. 

The guidelines have been approved by the Board of Directors of Atea ASA. 

2 To whom the guidelines apply and responsibility

The guidelines apply to all employees in the Group in all countries and to members of the boards of directors of Group companies.

You must avoid acting in breach of these rules and not urge others to do so either, even if under the prevailing circumstances such a departure from the rules may appear to be in the Group’s interest. If you are in doubt about whether a certain activity is lawful or ethical, consult your immediate supervisor, insofar as this is practically possible.

All managers are responsible for promulgating these guidelines, for promoting their use and for ensuring they are followed. 

Breaches of these guidelines will not be tolerated and may lead to internal disciplinary measures, dismissal or – in accordance with relative statutory provisions – criminal prosecution. 

Should any undesirable practice or irregularity arise in the Group, the Group is obliged to take the necessary corrective action and take steps to avoid a recurrence. 

3 Concern reports

Any concerns, complaints or other reactions indicating a breach of the guidelines shall be reported to the Chief Financial Officer (CFO) of Atea ASA. 

Threatening, discriminating against or harassing anyone who has raised such matters will not be tolerated and will be regarded as a breach of the guidelines. 

4 Personal conduct 

As an employee or Board member you are expected to perform your job tasks and generally conduct yourself irreproachably vis-à-vis business contacts, colleagues and others.

 

The Group does not accept any form of harassment, discrimination or other behaviour that colleagues or business contacts may perceive as threatening or degrading. 

5 Equal treatment 

The Group aims to have an inclusive work culture. The Group acknowledges – and appreciates – that all people are unique and valuable and are to be respected for their individual talents. The Group does not accept any form of harassment or discrimination on the basis of gender, religion, race, national or ethnic origin, cultural background, social affiliation, functional disability, sexual orientation, marital status, age or political conviction. 

The Group shall work actively for the fair treatment of all employees. Employees and business units in the Group shall base personnel-related decisions in the Group solely on relevant qualifications such as personal suitability, education, experience, results and other professional criteria. 

6 Integrity and conflicts of interests

6.1 Conflicts of interest
The Group’s employees and members of its boards shall not seek to attain any benefits for themselves (or closely related persons) that are unsuitable or otherwise may be thought to harm the Group’s interests. This rule applies whether or not the benefit can be characterised as fraud in a criminal sense. You may not participate in or try to influence a decision under circumstances that may result in an actual or perceived conflict of interest. Such circumstances may be a personal interest in the case – financial or otherwise – directly or through persons closely connected with you. If you become aware of a potential conflict of interest, you must notify your immediate superior immediately. Conflicts of interest are not always obvious. If you are unsure or have questions, you should consult one of your superiors.

If Board members and senior executives have, or may be assumed to have, a material interest in an agreement being concluded with a company in the Group, they must immediately notify the President and CEO of this matter, who shall ensure that the matter is brought to the Board of Directors of Atea ASA.

6.2 Bribes, gifts and benefits
To gain or retain commercial or other unsuitable advantages in the conduct of your business, you shall not offer, promise or grant any improper benefits to business contacts, public servants (or other third parties) to get the person in question to perform or fail to perform any act in his or her power as employee, civil servant or the like. This applies irrespective of whether the benefit is offered directly or through an intermediary. 

Gifts or other benefits to business contacts must be given in accordance with locally accepted good business practice and the guidelines in force for the Group at the time in question. Gifts and other benefits may be given only if they are of modest value and given with limited frequency – and assuming that the time and place are suitable. 

As an employee or Board member you are not allowed to accept from business contacts any gifts of money or other benefits that may influence – or be perceived as influencing – your integrity or independence. Gifts and other benefits may be accepted only if they are of modest value and given with limited frequency – and assuming that the time and place are suitable. 

If you are offered or have accepted such benefits in excess of normal tokens of appreciation or benefits, you must immediately notify your immediate superior or the local personnel office, which will decide whether your integrity or independence may be perceived as being or having been influenced. 

6.3 Financial interests in other businesses 
As an employee or Board member in the Group you must avoid having personal ownership interests – direct or indirect – in other businesses if such ownership weakens or may be thought or perceived to weaken your loyalty to the Group. Before undertaking an investment in a company that competes with the Group or does business with the Group, e.g. a supplier, you must consult your immediate superior (investment of less than five per cent – 5 % – in a listed company is exempt, however). Even so, be particularly conscious of potential conflicts of interests that are described in Section 6.1. 

6.4 Activities with competitors, suppliers or other business contacts 
Before getting involved in activities that may be perceived as promoting the interests of a competitor, supplier or business contact at the expense of the interests of the Group, including serving on the board of directors of such companies, you must consult your immediate superior. 

Information, intellectual property rights and innovative ideas are valuable assets to the Group. Such intangible assets must be managed and protected appropriately. The Group’s general principle regarding openness and access shall not be an obstacle for the appropriate safeguarding of information that may be of value to the Group’s business activities. 

Information beyond general business knowledge and work experience that you acquire in connection with performing your job shall be regarded as confidential and treated as such. Be particularly aware of the rules against the use of confidential information for personal gain for yourself or others.

7 Compliance with laws and regulations

You must comply with all current laws and regulations when acting on behalf of the Group. Violation of laws and regulations will not be tolerated.