Code of Conduct

1. Core Values and Workplace Behavior

1.1 Integrity and Responsibility

• We act honestly and with integrity in all interactions and decisions.
• Employees are accountable for their actions, decisions, and their consequences.
• Transparency, fairness, and ethical conduct are fundamental in achieving Nordmet SA goals.
• Every employee is expected to communicate respectfully, provide accurate information, and ensure that their professional behavior reinforces Nordmet’s reputation and public trust.
• Decisions should be guided not only by compliance with laws and regulations but also by the principles of fairness, objectivity, and ethical reasoning.

1.2 Well-being

• Nordmet SA prioritizes the physical and mental health of all employees, recognizing that well-being is essential for productivity, collaboration, and a positive workplace culture.
• We actively promote awareness of work-life balance, stress management, and mental health support.
• Each employee is expected to look after their own well-being and that of their colleagues, fostering a safe, supportive, and respectful working environment.
• Managers are responsible for creating a culture where concerns about safety, health, or mental well-being can be raised without fear of retaliation.

1.3 Collaboration and Excellence

• We encourage teamwork and the sharing of knowledge, skills, and expertise to achieve the best outcomes for the Nordmet SA and its stakeholders.
• Commitment to excellence means striving to meet and exceed expectations, delivering high-quality results, and continuously improving processes.
• Employees should proactively contribute to a culture of collaboration and open communication.
• By supporting each other and sharing best practices, we create an environment where everyone can succeed while maintaining ethical standards.

1.4 Inclusion, Fairness, and Respect

• We embrace diversity and inclusion, treating all individuals equitably regardless of race, nationality, religion, gender, age, sexual orientation, disability, ancestry, social origin, political belief, or other characteristics.
• Discrimination, harassment, bullying, or any form of abusive behavior is strictly prohibited.
• Decisions regarding hiring, promotion, rewards, and professional development are based on merit, capability, ethical behavior, and alignment with Nordmet’s values.
• Employees are encouraged to recognize and appreciate differing perspectives, creating an environment where diverse viewpoints are respected and leveraged for better decision-making.

1.5 Human Rights and Sustainability

• Nordmet recognizes and respects the fundamental rights of all individuals.
• Child labor, forced labor, exploitation, or other human rights abuses are not tolerated.
• The Nordmet SA is committed to responsible, sustainable, and transparent business practices, including in sourcing, operations, and engagement with communities.
• Employees and partners are expected to uphold the highest standards of ethical conduct, ensuring that all activities contribute to positive social and environmental outcomes.

2. Reporting Concerns and Speaking Up

• Nordmet SA actively promotes responsible conduct, integrity, and ethical business practices. Our reputation depends on the actions of every employee and all persons acting on our behalf.
• Employees are encouraged to speak up if they believe that they or others — including colleagues, managers, clients, suppliers, or third parties — may have violated the law, this Code, or any Nordmet SA policy, or have otherwise engaged in misconduct.

2.1 Duty to Report

• All employees are required to raise concerns about potential breaches of this Code, Nordmet SA policies, or applicable law.
• Managers have an additional responsibility to take appropriate steps to stop any misconduct they are aware of and to prevent its recurrence.
• Prompt reporting allows the Nordmet SA to investigate, address, and prevent misconduct, protecting employees, business partners, and the organization’s reputation.

2.2 Reporting Channels

• Concerns should first be raised with your manager or supervisor, who is usually best positioned to address them quickly.
• If this is not possible or comfortable, concerns may also be reported to Human Resources or the Legal Department.
• Anonymous reporting is available where permitted by law, ensuring that employees and third parties can report concerns without fear of identification.

2.3 Confidentiality and Protection

• All reports will be handled promptly and treated as confidentially as reasonably practicable.
• No employee will face retaliation for raising concerns in good faith or for participating in an investigation. Retaliation against whistleblowers or witnesses is strictly prohibited.
• Employees who report misconduct are encouraged to provide as much detail as possible, enabling thorough investigation and effective resolution.

3. Fair Trading and Competition

3.1 Competitors

• Nordmet is committed to fair, transparent, and ethical business practices and competes based on quality, innovation, and service.
• Employees must never spread misinformation or disparage competitors.
• Information about competitors must never be obtained through illegal or unethical methods, including industrial espionage or misuse of confidential relationships.
• Collusion, price-fixing, market allocation, bid-rigging, or any collective agreements to limit competition are strictly prohibited.
• Care must be taken when participating in trade associations or industry meetings where competitors are present.

3.2 Customers and Suppliers

• Relationships with customers and suppliers are based on fairness, loyalty, and mutual respect.
• Accurate, transparent information must be provided at all times, and material facts must not be misrepresented.
• Decisions regarding customers and suppliers must be based on legitimate commercial considerations, without favoritism or discrimination.
• Business partners are expected to uphold the same standards, including compliance with national and international competition laws.

4. Conflicts of Interest, Anti-Corruption, and Gifts

4.1 Conflicts of Interest

• Employees, representatives, and third parties acting on behalf of Nordmet SA owe a duty of loyalty to the Nordmet SA.
• A conflict of interest arises when personal interests interfere, or appear to interfere, with Nordmet SA’s best interests.
• Situations where conflicts may arise include:
  • Outside employment, activities, or directorships;
  • Financial interests in customers, suppliers, or competitors;
  • Business dealings with friends or family;
  • Receiving or offering gifts, entertainment, or favors;
  • Personal benefits arising from ESG or other business opportunities.
• All actual, potential, or perceived conflicts must be promptly disclosed to a supervisor, Human Resources, or the Legal Department. Managers must take additional steps to mitigate conflicts appropriately.

4.2 Anti-Corruption and Bribery

• Nordmet SA has zero tolerance for bribery or corruption.
• Employees may not, directly or indirectly, offer, promise, give, request, or accept anything of value to improperly influence a decision or gain an unfair advantage.
• Special care must be taken in dealings with public officials to avoid any perception of bribery.
• Political contributions or support for candidates, parties, or affiliated organizations is prohibited.

4.3 Gifts and Entertainment

• Gifts and hospitality must:
  • Be occasional, modest in value, and appropriate in context;
  • Never be intended to influence business decisions;
  • Never include cash or cash equivalents;
  • Be transparent and approved where necessary.

4.4 Anti-Money Laundering and Financial Integrity

• Nordmet SA does not engage in or facilitate money laundering, tax evasion, or related criminal activities.
• Employees must:
  • Conduct due diligence on business partners;
  • Remain alert to unusual or suspicious transactions;
  • Refuse assets known to come from criminal activity;
  • Work only with partners committed to ethical business practices.

5. Confidentiality, Data Protection, and Nordmet SA Assets

5.1 Confidential Information

• Confidential or proprietary information must only be used for legitimate business purposes.
• Sharing internally should be limited to what is necessary for performing duties.
• Disclosure to third parties requires authorization, and the duty of confidentiality continues after employment ends.
• All documents, records, and electronic files remain Nordmet SA property and must be returned upon termination.

5.2 Data Protection (GDPR Compliance)

• Personal data is collected, stored, and used only for lawful business purposes.
• Sensitive personal data (health, biometric, religious, political beliefs) must be handled with extra care.
• Data is shared only when legally required, requested by the individual, or justified by legitimate business interest.
• Suppliers and partners must comply with data protection laws and treat personal and confidential information responsibly.

5.3 Nordmet SA Assets

• Employees are responsible for safeguarding tangible and intangible assets, including intellectual property, trade secrets, and business plans.
• Assets must be used only for legitimate business purposes and protected with care.

5.4 IT Systems and Electronic Resources

• Nordmet SA IT systems (computers, phones, email, intranet, software) are primarily for business use.
• Employees must follow security procedures and report any suspected breaches immediately.

6. Health, Safety, and Environment (HSE)

6.1 Commitment to a Safe and Healthy Workplace

• Nordmet SA provides and maintains a safe, healthy, and respectful workplace.
• Compliance with occupational health and safety laws is required.

6.2 Employee Responsibility

• Employees must:
  • Take care of their own safety and that of others;
  • Report hazards, unsafe conditions, or near misses;
  • Stop work if unsafe;
  • Follow all safety and emergency procedures.

6.3 Workplace Well-Being

• Nordmet SA promotes mental and physical well-being through:
  • Ergonomic workstations;
  • Awareness of stress management;
  • Respectful workplace behaviour;
  • Support for reintegration after illness or injury.

6.4 Environmental Responsibility

• We minimize environmental impact by:
  • Reducing energy and paper usage;
  • Promoting recycling and responsible waste management;
  • Encouraging the use of sustainable modes of transportation, such as public transit, carpooling, cycling, or walking, to reduce carbon emissions associated with commuting;
  • Using resources efficiently and sustainably.

7. Compliance and Enforcement

7.1 Compliance with Laws

• All employees, contractors, and third parties must understand and comply with relevant local, national, and international laws.
• Misconduct or actions creating the appearance of impropriety are prohibited.
• Employees should seek guidance from supervisors or the Legal/Compliance function if uncertain.

7.2 Human Rights

• Nordmet SA respects human dignity and rights.
• The Nordmet SA prohibits child labor, forced labor, human trafficking, and any human rights abuses.
• Suppliers and partners are expected to maintain the same commitment.

7.3 Accurate Records and Reporting

• Financial and business records must be accurate, complete, and comply with applicable standards.
• False or misleading entries, misclassification, or off-the-books transactions are prohibited.

7.4 Consequences of Non-Compliance

• Violations may result in disciplinary action, including warnings, termination, or legal action.
• Third parties who fail to comply with ethical and legal obligations may face contract termination or other legal consequences.

8. Acknowledgement

• All employees are required to read, understand, and comply with this Code of Conduct. Acknowledgement of this obligation forms part of the employment or contractual agreement with the Nordmet SA.

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