Ethical guidelines for Avinor

Ethical guidelines for Avinor For trust and good reputation

I. Introduction from the CEO . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

II. Ethical guidelines in the Avinor Group . . . . . . . . . . . . . . . 6

III. Basic rules of personal conduct . . . . . . . . . . . . . . . . . . . . . . . . . . 9

IV. Rules for business practice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

V. Avinor’s surroundings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

VI. Handling of blameworthy conditions . . . . . . . . . . . . . . 18

Content

2 ETHICAL GUIDELINES FOR AVINOR

D. H. Lawrence English author

Ethics and equity and the principles of justice do not change with the

calendar.

3

Values platform

Avinor’s aim is to develop and operate a safe, efficient and sustainable aviation system across the country

All our staff, working together as a team. But also working with our partners.

We enable and facilitate through creativity and innovation.

We create values: for the individual, for companies and for the community. Values are created when people come together.

Connecting people and places. Establishing long-lasting bonds and relationships. We notice and get to know our customers.

MISSION

VISION We create valuable relationships!

Open:

• We are direct and honest

• We aim for cooperation and generosity

• We are inquisitive and willing to change

Dynamic:

• We look, listen and act

• We set clear targets

• We create results

Responsible:

• We keep our promises

• We show respect

• We work for what is best for Avinor

Customer oriented:

• We respond quickly to needs and changes

• We help those who help our customers

• We always look for safe and efficient solutions

VALUES

I. Introduction from the CEO

At Avinor, we administer public funds via our social mission. We value trust and having a good reputation in the community. Every single employee of the company, including you, me, the board, managers and every one of your colleagues, has a responsibility to safeguard this trust.

We can do this in the way we interact with passengers, airlines, partners, colleagues and the general public, using fundamental values such as loyalty, confidentiality and impartiality.

Conduct is a constant focus of ours, and helps to ensure that we build a strong ethical culture in the company. The Code of Conduct acts as a guide when we face dilemmas, and is intended to help us do what is right. The Code is a fundamental part of how we conduct our business. Everyone has a responsibility to make themselves aware of it and follow its rules.

The notion of what is acceptable behaviour has changed consider- ably in recent years. This includes developments to acts and regulations and how we apply these. What was acceptable five

or ten years ago is not necessarily acceptable now. Think about every thing you do. If you are in doubt, ask your immediate supervisor or another professional for advice. Alternatively, you can contact Mari Wiker (Compliance Officer) or use our alert channels.

We all have a responsibility to comply with the Code of Conduct. Thank you for working actively to improve Avinor’s ethical culture.

Dag Falk-Petersen Group CEO

5INTRODUCTION FROM THE CEO

II. Ethical guidelines in the Avinor Group

Avinor manages public funds, and how we conduct our business is of great importance to society and our business partners. Avinor is thus dependent on trust and a good reputation in the population. This is established through the actions and conduct of individuals.

Avinor’s guidelines express the Group’s attitudes in its interaction with customers, suppliers, colleagues, and the wider community. The purpose of the guidelines is to strengthen our awareness, help us make the right choices when we as a business or individual employee face ethical dilemmas, and thus reduce the risk of irregularities. Ethical guidelines are a part of Avinor’s governing documents and an integrated part of the way we do business. The requirements specified here for business practices and personal conduct apply to employees, board members, hired personnel and others who act on behalf of Avinor.

However, the guidelines do not provide answers to all dilemmas you may face. Sound judgement is required to determine whether a specific action or decision is ethical or not. If you are at all in doubt, it is important to initiate an open and confidential dialogue about the issue with your immediate manager or other trusted individuals.

Avinor’s suppliers must be made aware of Avinor’s ethical guidelines prior to signing contracts. Dedicated supplier conduct principles have been drawn up and suppliers are expected to follow ethical standards that are in line with Avinor’s ethical requirements.


7ETHICAL GUIDELINES IN THE AVINOR GROUP

III. Basic rules of personal conduct

CONDUCT

There must be coherence between what we say and what we do. Management must lead the way, also with regard to ethics. Proper ethical conduct must always be valued highly.

All employees shall contribute to a good working environment in which everyone is treated with respect, cared for and given responsibility. Tolerance must be shown for the opinions and attitudes of employees. No one must be subjected to discrimination or harassment. Various forms of abuse of power are not tolerated. There must never be any doubt about the integrity of Avinor employees. Personal interests must not affect decisions such that they conflict with Avinor’s interests or harm Avinor’s reputation. Avinor employees must act with respect and a sense of equality towards others, regardless of gender, ethnicity, political views, religion or philosophy.

INTOXICANTS

Intoxication is prohibited while at work, as are absences due to intoxication.

SEXUAL SERVICES

Avinor has zero tolerance for the purchase of sexual services. This also applies to work-related international travel.

THE USE OF THE GROUP’S EQUIPMENT AND PROPERTY

All Avinor employees are required to maintain Avinor’s fixed and movable property well. IT equipment, materials and other property shall predominantly be used for work-related purposes or for activities that are relevant to the work. The use of Avinor’s equipment for purposes that may be perceived as offensive must not occur.

9BASIC RULES OF PERSONAL CONDUCT

LOYALTY

Avinor imposes requirements regarding openness and loyalty to the Group’s interests and framework conditions and the realisation of goals and strategies. Employees are expected to use their competency and position to ensure good processes, including by expressing and listening to disagreements before decisions are made. Once decisions are made, employees are expected to be loyal to these.

DUTY OF CONFIDENTIALITY

Everyone has a duty of confidentiality regarding Avinor’s customers’, employees’, and others’ business or personal matters that they gain knowledge of as a result of their employment. Confidential information that employees receive in connection with processing cases must be respected and must not be communicated outside of Avinor without the express permission of a supervisor. All employees must sign a non-disclosure agreement upon appointment.

The duty of confidentiality also applies after the individual has resigned his services, task or office. The information may neither be used for own business activities nor in the service or work for others.

IMPARTIALITY

An employee is disqualified from preparing the basis for a decision and from making the decision, when he/she is a party to the case, is related to or married to/cohabiting with someone who is a party to the case, or when there are other special issues that may weaken confidence in the employee’s impartiality. It may occasionally be difficult to determine whether an employee has a conflict of interest. Whenever there is any doubt at all about this issue, it must be discussed with the most immediate supervisor. If a superior is disqualified, a decision in the case cannot be made by any directly subordinate employee; see the Public Administration Act Section 6.

SECOND JOBS

Employees may not hold directorships, ownership interests and/or operate/be employed in other activities (second jobs) if this can cast doubt on the employee’s or Avinor’s integrity, loyalty, impartiality or considerations toward proper service. Employees must demonstrate transparency and keep Avinor informed of any second jobs. If there is doubt whether directorships, second jobs, paid or unpaid assignments may


conflict with the employee’s duty of loyalty, impartiality or proper performance of their duties, this must be discussed with the immediate supervisor. Employees are themselves obliged to familiarise themselves and loyally comply with the Avinor Group’s values, management principles and ethical rules.

CONFLICT OF INTEREST

An employee cannot participate in or attempt to influence a decision if he/she has a conflict of interest or questions may be raised about the employee’s impartiality. Bribes are attempts to influence someone in the course of their tasks and duties by giving them an unfair benefit. Such unfair benefits may take a number of forms, including cash, gifts, credit, discounts, travel, accommodation or services. If this type of conflict of interest arises, the employee must always notify his/her supervisor. Conflicts of interest may involve, but are not limited to, customers, contractors, suppliers, employees, competitors or employees’ businesses outside of Avinor.

INSIDER TRADING

Inside information is accurate information that can affect the price of financial instruments significantly, and which is not publicly available or generally known in the market. Inside information must be treated with particular care, and the number of persons who receive inside information must be restricted as far as possible.

Trading of securities must not occur if this is incompatible with the interests the employee or board member must safeguard in his/her work for Avinor or Avinor’s business associates, or where trade may damage the general public’s confidence in Avinor.

11BASIC RULES OF PERSONAL CONDUCT

ETHICAL GUIDELINES FOR AVINOR12

IV. Rules for business practice

RELATIONSHIP TO OUR BUSINESS PARTNERS

Avinor must act ethically in procurement processes and in collaborations with business partners nationally and internationally, and must comply with the Public Procurement Act. Corruption, bribes and anticompetitive behaviours in violation of competition rules are not tolerated. Avinor shall meet business partners and other collaborators with openness, responsibility, respect, integrity and objectivity.

Meetings with business associates must be underpinned by Avinor’s ethical guidelines. You may refer to these guidelines when appropriate. For suppliers, separate supplier conduct principles have been drawn up.

FAIR COMPETITION

Avinor must compete in a fair, respectable and ethically responsible manner within the framework of procurement and competition law. Misuse of a dominant position is prohibited.

Employees of Avinor must not participate in nor attempt to influence a procurement process, if he/she has a personal interest in the procurement, financially or otherwise, directly or through closely related persons or others.

COMBATING CORRUPTION AND MISCONDUCT

Avinor has a zero-tolerance policy in relation to corruption. Corruption undermines legal business activities, leads to distortion of competition, damages reputations and exposes companies and individuals to risk.

Avinor has a strong focus on work with anti-corruption. We oppose all forms of corruption and will actively work to reduce the risk of corruption occurring at Avinor or in projects where Avinor is involved. We shall not offer, provide, accept or receive, directly or indirectly, bribes or other improper benefits for business or personal gain, either for ourselves or others.

13RULES FOR BUSINESS PRACTICE

Employees and members of the board must not use their positions to obtain an unwarranted advantage for themselves or others. This also applies in cases where these advantages do not affect their service actions. An irregularity is when an action is performed or avoided in order to achieve an unlawful advantage for oneself, the business or others, including both criminal and non-criminal matters.

GIFTS

Employees must not on their own behalf or on the behalf of others accept gifts, commissions, services or other benefits that may, or are intended by the donor to, influence business-related actions. This does not apply to smaller promotion items and gifts of little value and where it is clear that the benefit is not appropriate to influence business-related actions

If there is any doubt of whether a gift or benefit may be accepted, the question should be submitted to the immediate supervisor. Gifts to Avinor’s business associates may only be provided subject to consent from the supervisor and in accordance with good business practices. Gifts must be of a modest nature.

REPRESENTATION AND EVENTS

Employees may participate in social events if they have a business character and are related to Avinor’s business. Business associates who we are negotiating with are not included in this.

It is important for Avinor’s reputation that relationship building with external parties happens in a legal and ethical manner. When suppliers and other businesses offer visits to private businesses, trips to trade fairs, etc., it is a precondition that Avinor covers all travel and accommodation expenses for its own employees. Costs must be kept to a sensible level. Such trips and representation must always be approved by a supervisor.

MONEY LAUNDERING

Money laundering may be defined as transforming gains from criminal activities to a part of the legitimate economy. It is often connected to other types of criminal activity such as drug trafficking, terrorism, corruption and tax evasion. Avinor strongly opposes all types of money laundering, and will comply with all applicable statutes related to money laundering and take measures to prevent that others use our financial transactions for money laundering purposes.


Before Avinor enters into a contract, we shall ensure that the supplier is legally registered, that we know the real holder of rights and that they operate a legitimate business. We shall take reasonable measures to prevent and uncover illegal forms of payment, and thereby prevent Avinor’s financial transactions from being used to launder money.

PROCESSING OF PERSONAL DATA

Avinor’s processing of personal data must comply with statutes and regulations. Avinor must only collect, process and store personal data for legitimate business purposes and not store such data any longer than required for the purpose that the data was collected for. It is the responsibility of the individual to ensure that sensitive information is stored in a proper manner. All statutory and regulatory provisions regarding confidentiality and privacy must be complied with.

15RULES FOR BUSINESS PRACTICE

V. Avinor’s surroundings

EMPLOYEE RIGHTS, HUMAN RIGHTS AND SOCIAL DUMPING

Avinor actively works to ensure that the business operates in compliance with internationally recognized principles for business ethics and corporate social responsibility. When we select suppliers, the supplier’s work on human rights and employee rights, combating corruption and work on the climate and the environment, shall be included as one of several assessment criteria.

Avinor has developed its own principles for supplier conduct to ensure this. These principles apply to the entire supply chain. If irregularities related to the supplier principles are discovered, measures must be implemented to remedy this.

HEALTH, SAFETY AND THE ENVIRONMENT

At Avinor taking care of health, safety and the environment is an integrated part of our business and is a part of our business idea of taking responsibility. We shall act in a responsible manner and our goal is to reduce our environmental impact. This includes discharges to water, air and ground and the consumption of resources, including energy consumption, water consumption and waste processing. We shall focus on reducing direct and indirect emissions of greenhouse gases in our operations.

All employees share responsibility for ensuring that work is carried out in safe conditions and in a manner that safeguards and promotes health, safety and well-being among individuals and protects the enviroment.

17AVINOR’S SURROUNDINGS

VI. Handling of blameworthy conditions

COMMUNICATION

At Avinor we practice open communication characterized by respect, internally and externally, both when discussing the company and in dialogue between individuals. Information is treated with the necessary caution and in accordance with applicable rules for information security.

If individuals wish to express their personal opinions in the public sphere, including in social media, they must do so on their own behalf. In this context, it is not permitted to use clothing with Avinor’s logo or other Avinor-related items, or in any other way give the impression that statements are made on behalf of Avinor.

NOTIFICATION

The Group shall have an open culture in which employees can address issues with their immediate manager or others in the Group. All employees are encouraged to notify the Group of reprehensible conditions, cf. the Working Environment Act

section 2-4. Examples of reprehensible conditions include breaches of Avinor’s ethical guidelines and breaches of laws and regulations. Employees can notify the group by going through the line to the immediate manager, employee representatives, safety officers, or by contacting the internal or external notification committee. The notification must be made in a prudent manner.

RESPONSIBILITY AND FOLLOW-UP

All Avinor employees are required to read and comply with the ethical guidelines. Managers have a particular responsibility for ensuring that their own and their employees’ behaviour complies with the regulations.

Breaches of the guidelines will face a reaction appropriate for the nature and scope of the transgression, and may have consequences for employment through warnings or dismissals, depending on the level of seriousness.


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AVINOR AS Org. No. 985 198 292 Dronning Eufemias gate 6 0191 Oslo, Norway

P.O. Box 150 2061 Gardermoen

avinor.no

Ethical guidelines for Avinor

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