Policy for Responsible Business Conduct

Introduction

Norletic strives towards responsible business conduct that respects people, society and the environment.  This policy document, including our Code of Conduct, forms the foundation of our sustainability work.

Norletic considers responsible business conduct to be a prerequisite for sustainable development, meaning that today’s generation get their needs covered without compromising the ability of future generations to meet their own needs [1].  The UN Sustainable Development Goals (SDGs) is the world’s joint action plan for sustainable development.  Norletic works actively with the Sustainable Development Goals.

As a member of Ethical Trade Norway, Norletic commits to working actively with due diligence for responsible business conduct [2].  Due diligence is a risk-based approach to respect and safeguard people, society, and the environment in our own business and throughout the supply chain.  We expect our suppliers and partners to follow the same approach.

Corporate Policy

Norletic AS’s corporate policy is aimed at all our suppliers, manufacturers, distributors and partners.

Norletic AS has a strong social commitment and we work actively for sustainable and environmentally friendly business operations. Our social responsibility as a company outlines our efforts to contribute positively to the society that we depend on to succeed.  We focus on workers’ rights and safety.  Our sustainable business is rooted in the membership in Ethical Trade Norway. Here, we form the basis for our own responsibility towards society, the environment, and labour. This makes us part of a system of values ​​and goals greater than ourselves. Our social responsibility is formulated in our overall goals and reflects that we want to contribute to a positive development for society.

Norletic AS’s social responsibility and ethical trade can be divided into two categories: compliance and proactive. Compliance refers to our commitment to follow laws and regulations, as well as following the values ​​of the communities in which we operate. Proactive means that we take the initiative to promote human rights and provide assistance to local communities, and to the protection of nature.

Our compliance means that we will:

  • Respect laws
  • Adhere to adopted policies
  • Make sure all our business operations are legitimate
  • Keep our collaboration and projects open and transparent

We recognize the need to protect nature and the environment. Keeping our environment clean and minimizing pollution is for the good of the entire community. We aim to always follow the most sustainable and environmentally friendly practice in our field. Where possible, we aim to improve. We always follow best practices when disposing of garbage and using chemical substances. Norletic aims to be innovative for the best for the environment.

We are committed to protecting human rights. We are a company dedicated to facilitating equal opportunities and promoting equitable rights for workers. Norletic guarantees that none of our activities directly or indirectly violates human rights in any of the companies that we produce or partner with.

We follow the values ​​defined by the United Nations Global Compact and are committed to following the guidelines of Ethical Trade Norway. We want to promote a corporate identity as a socially engaged and responsible company. Management must communicate this at all levels. Management must also always be prepared for solutions that include social responsibility (CSR).

Norletic AS expects all of our suppliers, manufacturers, and partners to have a proven strategy for CSR and has incorporated procedures for sustainable business operations. They must have formulated CSR action plans. At the same time, they must be able to document that their business follows laws and regulations for ethical trade, anti-corruption, sustainability and the environment, workers’ rights, and human rights.

Company Values

Be Innovative & Build for Durability

At Norletic we are interested in creating products that stand the test of time.  We achieve this by rigorously testing our products, focusing on customer satisfaction, and planning long-term to attain the best results.

Evolve and Adapt

We are passionate about learning and know that we will always be working on progress and improvements.  We are not afraid to make mistakes as long as we learn from them.  Norletic is a company of people that are all here to continuously learn and develop.

Be Open & Operate with Transparency

We are accountable.  We do what we say we’re going to do. If we hit a roadblock, we work swiftly to determine the new course and communicate quickly, both internally and externally with honesty and respect.  We believe that the better our employees, suppliers, and manufacturers are informed, the better our work will be.  By granting access to the tools needed and listening to all feedback we can only become stronger.

Act with Integrity

Norletic was founded on the premise of sustainability.  We are committed to doing what’s best for our customers, and our workers and the environment.  We hold ourselves to a higher ethical standard and pursue collaborations with people that share the same vision.  We stand for honesty and transparency and believes that trust is an integral part of business.

Strategic Approach to the Sustainable Development Goals (SDGs)

Norletic was created with the Sustainable Development Goals (SDGs) in mind.  We strive to give more than we take and create a positive impact on the world.  For every company that we work with we create a tailor-made Code of Conduct that ensures that our workers, worldwide, are treated with the same rights that we would expect here in Norway.  Creating positive development in the workplace can be encouraging for entire communities.  When our workers are treated with care and fairness it gives everyone power and uplifts standards.

Norletic has the ability to work towards and influence 13 of the 17 SDGs and our Codes of Conduct cover every single one of these.

We guarantee that we:

  • Do not take risks with the health and safety of our employees and residents
  • Provide our workers with the proper training required
  • Do not penalize for sick days or mistakes
  • Avoid damaging the lives of local and indigenous people
  • Support diversity and inclusion

We work in partnership with many innovative organisations to provide the most up-to-date and environmentally friendly technology.  We believe that we are stronger together, and to that end we collaborate with Ethical Trade Norway and the United Nations Global Compact to ensure that our efforts are shared with other companies and that we work as a socially engaged and responsible company.

We invest a significant portion of our research and development budget. Norletic is always open to input and listens carefully to ideas. Our company is constantly working to improve every aspect of our business.  Norletic budgets for having the opportunity to make financial donations to local communities.

These donations aim to:

  • To develop arts, sports, education and local events.
  • Relieve those in need

We encourage volunteering for non-profits. This applies to external programs, but in the long term we aim to create our own program. Employees at Norletic AS can apply for financial support if they wish to work for voluntary organizations.

Requirements – own business

Norletic acknowledges that our business conduct can potentially have negative impact on people, society, and the environment.  At the same time, we see the potential to contribute to positive development in the supply chain.  With this in mind, we have compiled the following principles and criteria guiding our own business:

Due diligence

Norletic shall conduct due diligence for responsible business conduct.  This involves; conducting risk assessments to identify potential negative impact on people, society and the environment and to stop, prevent, and reduce such impact.  The measures put in place are monitored and their effects evaluated.  The measures are communicated to those affected by our actions.  If our activities are found to cause or contribute to negative impact on people, society or the environment, we will stop the activities and seek to provide remedy.  If our supplier is responsible for the negative impact, the supplier is responsible for providing remedy [3].

Responsible purchasing practices

Norletic considers responsible purchasing practices to be one of our most important tools for responsible business conduct.  Norletic shall adapt our purchasing practices in order to strengthen, and not undermine, our suppliers’ ability to deliver on our requirements related to people, society, and the environment.  We strive towards lasting supplier relationships with suppliers who show a particular willingness and ability to create positive developments in the supply chain.

Freedom of association and worker representation

Norletic supports the right to freedom of association and other forms of democratically elected worker representation.  We shall involve worker representatives and other relevant stakeholders in our work with responsible business conduct.

Supplier development and partnership

In dialogue with suppliers we will consider, if needed, to contribute with capacity building or resources that enable our suppliers to comply with Norletics requirements related to responsible business conduct.  This way we lay the foundation for collaboration with suppliers that show the willingness and ability to work on positive development for people, society and the environment in the supply chain.

Anti-corruption

Norletic, including all employees, shall never offer or receive illegal or inappropriate monetary gifts or other remuneration to achieve private or business benefits in their own interest or in the interest of customers, agents or suppliers.

Norletic will conduct their own checks on every supplier, manufacturer, distributor, and partner to determine answers to the current parameters for sustainability and ethical conditions.  Before entering into business with a company, or at any random point through the business relationship, Norletic will vet the company policies and treatment of the workers and the environment.  We reserve the right to conduct on-site inspections of all suppliers and manufacturers ordered through Alibaba.

Countries affected by trade boycott

Norletic, including all our suppliers and partners, shall avoid trading with partners that have activities in countries where a trade boycott is imposed by the UN and/or Norwegian Government authorities.

Requirements – conditions in the supply chain

We expect our suppliers and partners to work focused and systematically to comply with our guidelines for suppliers, hereunder our code of conduct, that covers fundamental requirements on human rights, labour rights, anti-corruption, animal welfare, and the environment. Our suppliers shall:

  • Follow our Guidelines for Suppliers, hereunder the Code of Conduct.
  • Conduct due diligence for responsible business conduct. This involves; conducting risk assessments to identify potential negative impact on people, society, and the environment and to stop, prevent, and reduce such impact.  The measures put in place must be monitored and their effect evaluated.  The measures taken must be communicated to those affected by your actions.  If the supplier is responsible for the negative impact/damage, they are responsible for providing remedy [3].
  • Show willingness and ability to continuous improvement for people, society, and the environment through collaboration.
  • At the request of Norletic be able to document how they, and potential subcontractors, work to comply with the guidelines.

If the supplier, after several requests by Norletic, does not show the willingness or ability to comply with the guidelines for suppliers, the contract may be cancelled.

Principles for responsible business conduct (Code of Conduct)

These principles for responsible business conduct are based on UN and ILO conventions and provide minimum, not maximum standards.  The relevant legal framework at the place of production shall be respected.  Where national laws and regulations address the same subjects as these guidelines, the most stringent shall apply.

  1. Forced and compulsory labour (ILO Conventions Nos. 29 and 105)

1.1. There shall be no forced, bonded or involuntary prison labour.

1.2. Workers shall not be required to lodge deposits or identity papers with their employer and shall be free to leave their employer after reasonable notice.

  1. Freedom of Association and the Right to Collective Bargaining (ILO Conventions Nos. 87, 98, 135 and 154)

2.1. Workers, without distinction, shall have the right to join or form trade unions of their own choosing and to bargain collectively.  The employer shall not interfere with, or obstruct, the formation of unions or collective bargaining.

 2.2. Workers’ representatives shall not be discriminated and shall have access to carry out their representative functions in the workplace.

2.3. Where the right to freedom of association and/or collective bargaining is restricted under law, the employer shall facilitate, and not hinder, the development of alternative forms of independent and free workers representation and negotiations.

  1. Child Labour (UN Convention on the Rights of the Child, ILO Conventions Nos. 138, 182 and 79, and ILO Recommendation No. 146)

3.1. The minimum age for workers shall not be less than 15 and comply with the national minimum age for employment, or; the age of completion of compulsory education, whichever of these is higher. If local minimum is set at 14 years in accordance with developing country exceptions under ILO Convention 138, this lower age may apply.

3.2. There shall be no recruitment of child labour defined as any work performed by a child younger than the age(s) specified above.

3.3. No person under the age of 18 shall be engaged in labour that is hazardous to their health, safety or morals, including night work.

3.4. Policies and procedures for remediation of child labour prohibited by ILO conventions no. 138 and 182, shall be established, documented, and communicated to personnel and other interested parties. Adequate support shall be provided to enable such children to attend and complete compulsory education.

  1. Discrimination (ILO Conventions Nos. 100 and 111 and the UN Convention on Discrimination Against Women)

4.1. There shall be no discrimination at the workplace in hiring, compensation, access to training, promotion, termination or retirement based on ethnic background, caste, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

4.2. Measures shall be established to protect workers from sexually intrusive, threatening, insulting or exploitative behaviour, and from discrimination or termination of employment on unjustifiable grounds, e.g. marriage, pregnancy, parenthood or HIV status.

  1. Harsh or Inhumane Treatment (UN Covenant on Civil and Political Rights, Art. 7)

5.1. Physical abuse or punishment, or threats of physical abuse, sexual or other harassment and verbal abuse, as well as other forms of intimidation, is prohibited.

  1. Health and Safety (ILO Convention No. 155 and ILO Recommendation No. 164)

6.1. The working environment shall be safe and hygienic, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Hazardous chemicals and other substances shall be carefully managed. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in, the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

6.2. Workers shall receive regular and documented health and safety training, and such training shall be repeated for new or reassigned workers.

6.3. Access to clean toilet facilities, and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

6.4. Accommodation, where provided, shall be clean, safe and adequately ventilated, and shall have access to clean toilet facilities, and potable water.

  1. Wages (ILO Convention No. 131)

7.1. Wages and benefits paid for a standard working week shall, at minimum, meet national legal standards or industry benchmark standards, whichever is higher.  Wages should always be enough to meet basic needs, including some discretionary income.

7.2. All workers shall be provided with a written and comprehensible contract outlining their wage conditions and method of payments before entering employment.

7.3. Deductions from wages as a disciplinary measure shall not be permitted.

  1. Working Hours (ILO Convention No. 1 and 14)

8.1. Working hours shall comply with national laws and benchmark industry standards, and not more than prevailing international standards.  Weekly working hours should not on a regular basis be more than 48 hours.

8.2. Workers shall be provided with at least one day off for every 7-day period

8.3. Overtime shall be limited and voluntary.  Recommended maximum overtime is 12 hours per week, i.e. that the total working week including overtime shall not exceed 60 hours.  Exceptions to this are accepted when regulated by a collective bargaining agreement.

8.4. Workers shall always receive overtime pay for all hours worked over and above the normal working hours (see 8.1 above), minimum in accordance with relevant legislation.

  1. Regular Employment (ILO Convention No. 95, 158, 175, 177 and 181)

9.1. Obligations to employees under international conventions, national law and regulations concerning regular employment shall not be avoided through the use of short term contracting (such as contract labour, casual labour or day labour), sub-contractors or other labour relationships.

9.2. All workers are entitled to a contract of employment in a language they understand.

9.3. The duration and content of apprenticeship programmes shall be clearly defined.

  1. Marginalized Populations (UN Covenant on Civil and Political Rights, art. 1 and 2)

10.1. Production and the use of natural resources shall not contribute to the destruction and/or degradation of the resources and income base for marginalized populations, such as in claiming large land areas, use of water or other natural resources on which these populations are dependent.

  1. Environment

11.1. Negative impact on the environment shall be reduced throughout the value chain. In line with the precautionary principle, measures shall be taken to continuously minimize greenhouse gas emissions and local pollution, the use of harmful chemicals, pesticides, and to ensure sustainable resource extraction and management of water, oceans, forest and land, and the conservation of biodiversity.

11.2. National and international environmental legislation and regulations shall be respected, and relevant discharge permits obtained.

  1. Corruption

12.1. Corruption in any form is not accepted, including bribery, extortion, kickbacks and improper private or professional benefits to customers, agents, contractors, suppliers or employees of any such party or government officials.

  1. Animal welfare

13.1 Animal welfare shall be respected. Measures should be taken to minimize any negative impact on the welfare of livestock and working animals.

13.2 National and international animal welfare legislation and regulations shall be respected.

[1] The Brundtland commission, «Our Common Future», 1987

[2] UN OHCHR, Guiding Principles on Business and Human Rights (UNGP)”, 2011; OECD, «Due Diligence Guidance for Responsible Business Conduct», 2018.

[3] OECD, «Due Diligence Guidance for Responsible Business Conduct», 2018.