5.1 Ensuring ethical business practices
Chapter 5
NRC Group’s business success is built on a foundation of trust. We believe that our business behaviour should reflect the highest ethical standards.
Our long-term relationships with our customers and suppliers are where we demonstrate our commitment to ethical business practice. Actively reviewing and maintaining these high standards, makes ethical
business practice a material topic.Comprehensive ethics policy and compliance programme
The Business Ethics and Code of Conduct Policy serves as NRC Group’s primary governance document for ethical business practices. This policy is available on our website. The compliance programme focuses on priority ethics areas including anticorruption, anti-bribery, fair competition and supply chain integrity. Routines and systems for whistleblowing have been established in accordance with the Norwegian Working Environment Act.
Anti-bribery management system certified to ISO37001
Since 2019, NRC Group Norway has been ISO 37001 certified, the internationally-recognised ISO standard for anti-bribery management systems. An annual risk analysis is undertaken as part of the certification process. NRC Group Norway was re-certified to the standard in 2023.
Whistleblowing reports received in 2023
0
2022: 6
All managers have completed anti-corruption training
The key features of the ethics compliance programme and whistleblowing system have been communicated to all group employees. This has strengthened internal awareness about ethical issues, including application of NRC Group’s policy on business ethics. Workshops and training have been conducted with all managers in Norway, Sweden and Finland to prepare them for handling ethical conflicts. The training includes how to identify and act in situations involving corruption, such as being offered private services or kickbacks.
Whistleblowing
It is management’s responsibility to ensure that whistleblowing reports are dealt with in accordance with NRC Group’s formal whistleblowing directive. Following a whistleblowing report, any investigations and actions are considered on a case-by-case basis. NRC Group will, as soon as possible upon receiving a whistleblowing report, draw up a draft action plan. The plan may include the initiation of internal investigations and an assessment of sanctions in accordance with labour law legislation.
Elevating whistleblowing reports
Any decisions to contact authorities, clients, contractors or other external third parties in case of an ethical breach are made by the legal counsel of NRC Group. If the matter concerns the legal counsel of NRC Group itself, or any of the legal counsel’s superiors, an independent reporting channel may be used. In matters that could have significant consequences for NRC Group, the legal counsel will confer with the chairman of the board before contacting external parties and will generally keep the chairman of the board informed of the facts of the case. All employees, as well as contracted workers in NRC Group, who report irregularities in good faith, are actively protected against any kind of retaliation.
15 whistleblowing reports were received in 2023 – 0 elevated
15 whistleblowing reports were received in 2023. The reports were followed up in accordance with NRC Group’s formal whistleblowing process and the Business Ethics and Code of Conduct Policy. Following investigation, no reports were elevated for further action.