Ethical Guidelines

Ethical guidelines

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Contents

Dear colleagues

Dear colleagues

3

High ethical standard and an open corporate culture

4

Group responsibility

7

Individual responsibility

9

Safety and crime

9

Gifts and benefits

9

Alcohol and drugs

10

Politics and religion

11

Punishable offences

13

Conflicts of interest and legal misconduct

15

Communication

16

Professional secrecy Reporting of ethically reprehensible activity

16 19

Violation of the Ethical guidelines

20

Test your ethics

20

Notification

22

We thrive on delivery. In order to deliver, we must have both our customers’ trust, and motivated employees.

Two of our corporate values are honesty and respect.

These are core values in relation to customer trust, and a good working environment. The Ethical guidelines are built on the group’s core values, creating a norm for what is considered responsible conduct.

The guidelines apply to all employees in the group, and describe our culture for dealing with each other and the environment. We shall have an open corporate culture where discussion of ethical dilemmas in the workplace is encouraged.

Many know from experience that it is not easy to know where the boundary lies, or know exactly how to proceed given a particular situation. These Ethical guidelines do not provide answers to all dilemmas, but are rather meant to be a source of help and guidance in order for you to manoeuvre safely within the stipulations of applicable laws and regulations.

Given a particular situation where you are in doubt about how to proceed, I encourage you to talk with your colleagues, or take up the issue with your manager. The ethical dilemma test found in the back of the folder can also be of assistance.

I ask that you become well-acquainted with the Ethical guidelines. Following the Ethical guidelines is crucial to our company culture, so that we achieve our common goals.

Dag Mejdell President & CEO

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The group shall be characterised by a high ethical standard and an open corporate culture What are ethics, and why do we need Ethical guidelines?

Ethics are about what is right and wrong, and provides a framework for our behaviour. Ethics are value-based obligations that we impose on ourselves, our employer and the community to which we belong. We relate to our ethical obligations on the basis of general community values, as well as the group’s company-specific values.

These Ethical guidelines are built on the group’s values.

By founding our behaviour on the group’s shared values, and by acting in accordance with these guidelines, we can contribute to a high ethical standard affecting the whole of the group.

A high ethical standard is fundamental to a good working environment and a sound and open corporate culture. By manifesting high ethical standards and a strong corporate culture, we aim to establish trust and a good reputation to demonstrate to our customers that we are to be trusted.

The Ethical guidelines are not exhaustive, but rather they create a norm for what the group judges to be good and responsible behaviour. The guidelines are also intended to be a source of help and guidance in order to

manoeuvre safely within the stipulations of applicable laws and regulations. The individual employment contract further describes provisions and requirementsthat are to be met by each individual employee within his or her areas of responsibility.

To whom do the Ethical guidelines apply, and what is your responsibility?

The Ethical guidelines apply to all companies that are part of the group, and to all of the group’s employees.

The guidelines also apply to members of the Board, employees on leave of absence, external consultants, temporary employees and others employed on contract with the group.

Managers are responsible for communicating the Ethical guidelines to ensure they are understood and followed. Managers are also responsible for informing employees that non-compliance will result in a certain course of action. Furthermore as a leader you have the special responsibility of adhering to the Ethical guidelines by setting a good example of ethical behaviour through your actions.

As an employee in the group, you have the duty to be well-informed, and to comply with the Ethical guidelines.

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The group shall be a responsible employer, community player and business partner The group shall be a professional employer that adheres to fundamental human rights.

In the group we recognise our differences and use them for the common good. The group does not accept any type of harassment or discrimination based on race, religion, national origin, sexual orientation or gender. Neither do we accept any kind of behaviour that is liable to be perceived as threatening or humiliating by colleagues or other business relations.

As an employer, the group stands for good job opportunities and the fair treatment of all employees.

Objective criteria should form the basis for all decisions concerning employment, promotion and wage-setting.

Employee rights protected by law, wage agreements and international conventions shall be followed.

The group will be at the forefront of the effort leading toward creating a healthy work environment in which no one will run the risk of being injured or becoming ill due to his or her work. The individual employee is expected to contact his or her immediate superior, or the safety deputy, to report any defect or problem that may endanger life or health during work.

As a responsible community player, the group is obliged to meet the licence requirements, as well as other government requirements. The group shall work actively to reduce emissions and pollution, save energy and choose environmentally-efficient solutions.

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As a trusted third party supplier of physical and electronic solutions, the group assumes great responsibility, with respect to its customers.

This responsibility applies to money as well as post, goods and cargo, information and other valuables.

The customers must be able to trust that what they deliver to the group will arrive safely within the stipulated time-frame.

Suppliers shall be treated impartially and with fairness. The group shall not abuse its market position.

We expect our suppliers and partners to share our ethical values.

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Everyone is accountable for honest and responsible personal behaviour As an employee in the group, you are obliged to comply with all laws, regulations and internal guidelines, to show responsibility, and to do your work safely and conscientiously, given your current level of authority.

You should behave honestly and with integrity, treat everyone with respect and demonstrate good behaviour to all business relations, colleagues and other contacts.

Safety and crime You are obliged to contribute to the prevention of criminal actions within, and against the group, and to follow the safety routines. You should be vigilant and honest when handling the group’s assets, postal items, goods and cargo, information and other valuables that are handled for customers. You are also required to provide information of any criminal actions taken within or against the group.

Gifts and other benefits You shall not, on behalf of yourself, or others, accept any gift, commission, service or other benefit that would be likely to, or on the intention of the giver, improperly influence your work for the group. You should also refrain from giving, or offering, such benefits. In this context, benefits also include invitations to meetings and events, travel offers and other similar benefits paid by others than the group. Attendance to such meetings and events must be approved by your immediate superior. It is prerequisite that the group, at a minimum, covers travel expenses, including lodging and meals. When you participate in these types of meetings

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and events, you will always be a representative of the group, which must be reflected in your behaviour.

Modest forms of hospitality and social gatherings are customary in all business relationships. It is acceptable to both give and receive gifts of small value in connection with Christmas, holidays or other special occasions.

However, favouritism must not be developed to the extent that it affects the decision-making process, or gives cause for others to believe that it does so.

If you receive a reward or benefit of substantial value, or become aware of an impending offer for such a benefit, your immediate superior should be informed in order to decide whether you can receive the gift, or if it has already been received, possibly keep the gift.

The determining factor is whether your integrity would be impaired by receiving the gift, or would it create such an impression to the detriment of yourself or the group. Special caution should be exercised when benefits are offered in connection with negotiations, specific contracts or issues that are under consideration.

You shall not receive discounts when privately buying goods and services from the group’s business relations, unless a discount has been offered to a large group of employees in the group.

It is never acceptable to buy sexual services when acting on behalf of the group.

Alcohol and drugs All group workplaces shall be alcohol and drug-free. It is not acceptable to be under the influence of alcohol or other illicit drugs at work. It is expected that you report any colleague whose work is currently, or has been,

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negatively affected by alcohol or illicit drugs during the work day. Alcohol may be served in modest quantities when customary, or on special occasions provided that consumption does not take place during work activities.

Politics and religion Your political or religious affiliations, participation in societies and associations etc. are not a concern of the group. Nevertheless, you must appear impartial when acting on behalf of the group. Furthermore, we expect that you display a loyal attitude in both personal and professional situations so that you do not harm the reputation of the group.

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We uphold zero tolerance for corruption and other criminal offences The group does not tolerate any type of corruption, or other criminal offences committed in connection with work for the group.

Zero tolerance for any corruption and criminal offence means that these actions shall incur strong and consistent reactions resulting in dismissal. Circumstances that are considered liable to penalty will, as a general rule, be reported to the police. Corruption includes bribery and undue business influence.

Corruption undermines legal business activities, distorts competition, impairs trustworthiness and the group’s reputation, and exposes the company as well as individuals to undue risk. Apart from being ethically unacceptable, corruption and complicity in corruption are actions liable to penalty, whether the matter concerns the acceptance or offering of bribes.

Criminal offences committed by employees in the group that negatively affect customers are considered particularly serious and will be considered aggravating factors when determining the appropriate sanctions.

Like corruption, such offences are particularly destructive to the trustworthiness, and reputation of the group. Additionally, they may negatively affect the working environment.

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Conflicts of interest and misconduct shall be avoided As an employee in the group you shall not try to obtain benefits, for yourself or any other person closely related to you, which are improper, or in other ways likely to impair the interests of the group. You are not allowed to have salaried work, owner’s interests or other influential positions in the business arena that may undermine your loyalty towards the group.

Serving on the board of directors of other for profit companies shall be approved by your immediate superior, or his or her manager.

You may not participate in, or seek influence over, any decision if there are circumstances that could raise doubts about your impartiality. Such circumstances may arise where there are personal interests in the case, for example through a family relationship, a close personal relationship or financial interests. This also pertains to owner’s interests or board membership in a company, society or association connected to the case.

If a potential conflict of interest should come to your attention, you must immediately report the matter to your immediate superior. If disqualification is disclosed, or if circumstances arise that result in diminished trust in the group, and/or the decision-making processes of the group, you shall immediately refrain from any further dealings with the matter in question.

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We shall be open and truthful in our communications We shall be open and truthful in all of our internal and external communications. All media contact shall be handled in compliance with the Corporate Communications Policy.

The duty of confidentiality must be upheld You are obliged to maintain secrecy about confidential information entrusted to you in connection with the work, or task that you carry out for the group. An important part of this obligation is to maintain confidentiality of information of a competitive nature, as well as any information that might be of interest to criminal circles.

The duty of confidentiality also applies to colleagues who have no need for the information in their work.

The duty of confidentiality is exercised in order to prevent unauthorised persons from gaining access to information that may harm the group’s customers, activities or reputation. The duty of confidentiality is also intended to protect personal information, and the integrity of individuals, whether they are customers, or group employees.The duty of confidentiality continues to apply after termination of employment or after the entrusted task has been carried out.

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Ethically reprehensible activity must be reported Raising concerns about any illegal and ethically reprehensible activity is considered a contribution to the positive development of the group. Ethically reprehensible activity is understood as the violation of all laws and regulations, these Ethical guidelines, and other internal rules that govern group activities.

There are a series of internal channels through which one can express ethical concerns. It is advised that you first contact your immediate supervisor, and when necessary follow-up with his or her supervisor, union representatives, and the safety deputy. It is a fundamental goal to ensure that problems are solved as soon as possible as to when and where they took place. The group’s senior management has the responsibility of providing a process to solve problems that arise. If the existing circumstances prevent you from accessing any of these channels, you should report the problem you are experiencing to a special hotline. In some cases it will be appropriate to report activity to external authorities, typically supervisory authorities or the police.

The group should be characterized by an open corporate culture where it is acceptable to raise concerns, and to complain about ethically reprehensible activity.

When you raise concerns in a responsible way, you can expect to be taken seriously, listened to and assured that someone will take steps to investigate your concern. You should always be informed about how the case is being handled. You should feel certain that no adverse actions or sanctions will be taken against you after your

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responsible reporting of any reprehensible activity. As a general rule reporting of ethically reprehensible activity is advised.

Violation of the Ethical guidelines may have consequences Violation of the Ethical guidelines may have consequences to your employment in terms of a warning, or dismissal. The group shall maintain a high ethical standard in the treatment of employees who have violated, or who are suspected of having violated the Ethical guidelines. Applicable laws and current agreements shall be followed. All considerations regarding legal protection and general human rights should be taken. An employee should be treated with respect irrespective of the offence committed.

The Ethical guidelines of the group do not establish any rights for customers, suppliers, competitors, shareholders or any other individuals or units.

Test your Ethics If you face an ethical dilemma, ask yourself the following questions: Is this legal?

Does this feel right?

Would you tell your family, a colleague or a friend about your actions?

Would the issue stand up to public scrutiny?

If you are in doubt, seek advice from your immediate supervisor.

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Notification of ethically reprehensible activity and misconduct in the group It is critical that ethically reprehensible activities and misconduct are reported, and resolved as soon as possible. Most often this will involve your direct supervisor, or his or her manager. When it is difficult for you to make a report directly to your manager about the reprehensible activity or misconduct you have experienced, the group has established a corporate unit for the safe reporting of misconduct.

Contacting the corporate unit for misconduct Intranet Email address: varsling@posten.no Telephone number +47 23 14 99 40 Mail address: Posten Norge AS Konsernets Varslingsinsitutt Postbox 1500 sentrum 0001 OSLO Norway Examples of ethically reprehensible activity and misconduct that can be reported Financial improprieties, embezzlement, mail and goods fraud, affecting customers or entreprises in the group.

Corruption.

Environmental crime.

Unacceptable activity not considered a violation of rules and regulations, but falls outside the group’s and/or society’s norms.

Violation of health-, environmental- and

security regulations.

Violation of corporate governing documentation, including the Ethical guidelines.

Activity not handled by the corporate unit for misconduct.

Internal activity, such as personality conflicts and the like.

Reprehensible activity based on political or ethical beliefs.

Professional disagreements.

Before making a report The procedure for reporting shall be carefully conducted. Before making a report you should ask yourself: Do I have a basis for making the report?

How can I proceed?

With whom should I speak?

It is expected that you disclose your name to the corporate unit for misconduct. The co-workers in this unit will strive for the confidential handling of your report. You should feel secure that the making of a report will not result in negative consequences.

KK Design 046-2011

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