CODE OF CONDUCT AND ETHICAL GUIDELINES
FOR
Eik Servering AS
Adopted by the Board of Directors on 19.10.2023
Content
1 INTRODUCTION..................................................................................................................................................3
1.1 Purpose and key message..................................................................................................................3
1.2 Application and responsibilities.........................................................................................................3
2 ETCHICAL PRINCIPLES ........................................................................................................................................3
2.1 Labour and working environment .....................................................................................................3
2.2 Human rights .....................................................................................................................................4
2.3 Bribery and corruption ......................................................................................................................4
2.3.1 Zero tolerance of corruption .............................................................................................................4
2.3.2 Gifts and hospitality...........................................................................................................................5
2.3.3 Company policy on gifts and business hospitality .............................................................................5
2.4 Loyalty and conflicts of interest.........................................................................................................6
2.5 Taking care of the environment.........................................................................................................6
2.6 Confidentiality ...................................................................................................................................6
3 DISIPLINARY ACTIONS ........................................................................................................................................6
4 RELATED DOCUMENTS.......................................................................................................................................7
PREFACE
At Eik, we are committed to fostering a workplace that values respect, integrity, and collaboration. Our success is not just measured in numbers, but in the positive impact we make as a team. To uphold our values and maintain a thriving environment, we expect all members of the Eik family to adhere to the following Code of Conduct.
1 INTRODUCTION
1.1 Purpose and key message
Eik Servering AS ("Eik" or "Group") is committed to and expects the highest ethical standard and integrity from all of our employees, affiliates and subsidiaries.
The purpose of this Code of Conduct and Ethical Guidelines is to describe the requirements for responsible and ethical behaviour and business practice in Eik. Commitment to ethical behaviour is important for our employees, guests/customers, business partners, suppliers, and the general community as a whole and contributes to uphold the mutual respect and trust that is important for running a successful business.
Eik has a clear ambition to be a socially responsible company acting ethically and lawfully in all aspects of our value chain. All employees must have thorough knowledge of our policies and know how to proceed if they face ethical dilemmas and detect behaviour that violates our policies. All employees are expected to use their own sound judgement when faced with ethical dilemmas.
Eik views compliance with the law and social responsibility as a competitive advantage and strive to ensure ethical business conduct in all its operations. Eik expects its suppliers, business partners, customers and stakeholders to hold themselves to the same standard.
Eik encourages reporting of suspected breach of laws and regulations, this Code of Conduct and Ethical Guidelines or any of its underlying policies, as well as other misconduct. Reporting allows the Company to rectify problems and prevent the problems from growing.
1.2 Application and responsibilities
This code of conduct applies to everyone at Eik and its subsidiaries – all employees, managers, and members of the board of directors (all of whom are included in the term “employees” as used in the following).
2 ETCHICAL PRINCIPLES
2.1 Labour and working environment
Eik shall uphold a working environment that is characterized by openness, communication, and respect for the individual. We recognize the freedom of association and the right to collective bargaining. Fair employment practises following norms, laws or any collective bargaining agreements that is legally binding for Eik shall be the basic standard in all Eik entities. As of now we follow “Riksavtalen”.
No discrimination, harassment or bullying shall be tolerated. Diversity, and a balanced work force in terms of gender, is recognized as strength and an advantage. Eik has zero tolerance on sexual harassment in the workplace. Eik's policy and regulations for handling incidents of sexual harassment in the workplace is further described in Eik's Policy to prevent sexual harassment in the workplace.
Health and safety in the working environment are very important to Eik and is to be ensured to provide a safe and satisfactory workplace. Eik shall not engage in or support any kind of forced-, compulsory- or child labour.
All employees have a duty to treat the Eik's property with due care. Damage or loss as a consequence of gross negligence may lead to claim for damages.
It is forbidden to be intoxicated while working or in the workspace or consume intoxicating substances during working hours.
The CEO may in special cases give exemptions for alcohol consumption in connection with representation or social events in Eik or in equivalent circumstances.
2.2 Human rights
Eik is fully committed to support and respect the protection of internationally proclaimed human rights and decent working conditions. We will not in any way be complicit in any sort of human rights abuses.
All restaurants in Eik shall comply with UN’s Universal Declaration on Human Rights, The UN’s Convention on Rights of the Child, International Labour Organisation Conventions (ILO conventions), the UN Guiding Principles on Business and Human Rights as well as other applicable conventions and international standards on Human Rights.
Eik is subject to the Norwegian Transparency Act of 2022. In accordance with the Act, Eik is obliged to conduct human rights due diligence of our operations and our supply chain. Due diligence involves investigating and managing the risk of negative impact on human rights and decent working conditions. Social sustainability and human rights are embedded in Eik's responsible business framework, including in this Code of Conduct and Eik's Ethical guidelines for suppliers.
The CEO of Eik is responsible for performing yearly assessment of risk relating to human rights and labor conditions in our business operations and supply chain. The CEO of Eik is also responsible for ensuring proper reporting under the Act and to respond to information requests.
Eik is committed to remedy identified violations directly linked to the operations of Eik's business operations. Type of remedy or combination of remedies appropriate will depend on the nature and extent of the consequences identified.
2.3 Bribery and corruption
2.3.1 Zero tolerance of corruption
Eik has zero tolerance of corruption in all its forms, including extortion and bribery. We make active effort to ensure that corruption does not occur in our business activities.
Corruption means offering, promising or giving any person (directly or indirectly), or requesting, receiving, accepting or soliciting for oneself or others, an improper advantage in connection with the person's performance of a position, office or assignment.1
Corruption may involve the exchange of items of value or provision of services or other favours in order to obtain personal benefit by virtue of the employment position. It does not only involve money but may extend to all manner of gifts that were intended for personal gain, derived out of an official position.
Corruption also includes bribery in all its forms – direct and indirect through third parties. Employees and business partners of Eik shall not offer or accept an offer as a bribe, facilitation payment, kickback or other improper advantage for any reason. The direct or indirect offer, payment, soliciting or acceptance of bribes in any form is totally unacceptable by Eik and is punishable by law.
2.3.2 Gifts and hospitality
Gifts may constitute, or be perceived to constitute, an improper advantage.
Hospitality expenses may be misused for bribery purposes, even though reasonable, proportionate and bona fide business hospitality expenses are not prohibited under applicable anti-corruption laws. The term ‘business hospitality’ should be taken to mean meals, travel, accommodation and entertainment that is related to a business meeting or otherwise has a clear business purpose.
2.3.3 Company policy on gifts and business hospitality
a) Gifts and business hospitality should always be given, offered and received in a transparent way and in a professional context.
b) It is not permitted to offer or give gifts or business hospitality to public officials.
c) Gifts or business hospitality shall never be offered or provided to persons exercising authority, or who may influence the decision, in a tender or contract negotiation that the Company is involved in.
d) Gifts and business hospitality must never be extravagant and should be in accordance with customary business practices.
e) Cash or cash equivalents may never be offered, given or received.
f) You must not donate gifts or other benefits on behalf of the Company (or its associates) for the purpose of achieving benefits in return for yourself or the Company (or its associates).
g) A gift may be offered or received in relation to employees when it is in line with the abovementioned requirements, it is moderate and does not exceed a value of [1,000 NOK].
h) Business hospitality may be offered or received in relation to employees when it is in line with the abovementioned requirements, it has a proper business context and does not exceed a value of [2,000 NOK].
1 The Norwegian Penal Code Section 387
2.4
If you receive or become aware that you will be offered a gift or business hospitality that is not in accordance with the requirements set out above, your immediate superior shall be informed and shall decide whether accepting such gift/business hospitality might affect your impartiality and therefore whether it may be accepted/kept or rejected. When in doubt, the superior shall consult the CEO.
All expenses must be accounted for in compliance with applicable laws and internal guidelines. You are responsible for reporting any gifts or benefits received from third parties to the tax authorities and/or other public authorities in accordance with applicable laws and regulations at any time.
Loyalty and conflicts of interest
All employees are expected to be loyal to Eik and our interests.
A conflict of interest occurs when an individual's personal relationships or interests could influence, or could be perceived to influence, the individual's decision making when acting for Eik.
Conflict of interest situations may occur and should be dealt with in an open and transparent manner. The Company aims to minimize decisions being made by employees or directors in conflict of interest situations, as this may result in the Company's interests not being properly safeguarded, and could also represent a risk to our reputation.
Employees should not participate in financial and/or business-related activities or decisions that could potentially create a conflict of interest between Eik’s interests and their own personal interests.
All staff members shall notify their superior if they have any direct or indirect personal interest in any transaction contemplated or entered into by the company. Such interests may involve personal interests in other group companies, suppliers, customers or other third parties. All Eik employees must assess for themselves whether any conflicts of interest exist. If their case is not clear, or if somebody so requires, they must submit the question to their immediate superior.
2.5 Taking care of the environment
Eik is conscious and interested in environmental issues. Our business supports a precautionary approach to environmental challenges and undertakes initiatives to promote greater environmental responsibility. It is important that we take responsibility for the environment and commit to a healthy and viable business.
2.6 Confidentiality
It is the policy of Eik that information received by an employee when performing his/her/their duties shall be treated with confidentiality. This duty of confidentiality remains in force after an Eik staff member has left the company. No individual shall exploit such information in his or her own business or in the service of or working for others.
3 DISIPLINARY ACTIONS
A failure to act in compliance with the Code of Conduct and Ethical Guidelines may result in disciplinary actions. Such failure include, among other things, violation of the code, helping others to violate the code, knowingly failing to report violation or retailing against someone who has reported a violation.
Disciplinary actions may include verbal warnings, written reprimands, suspension or dismissal, and in some cases referral for criminal prosecution.
4 RELATED DOCUMENTS
The Code of Conduct and Ethical Guidelines should be read in connection with the following documents.
Policy to prevent sexual harassment in the workplace
Whistleblowing policy
Ethical guidelines for suppliers