ADIMA’s Code of Conduct apply primarily to members of the board of directors, managers, employees, contracted consultants, and others

acting on behalf of ADIMA. It is the line managers’ responsibility to make sure that everybody is aware of, and complies with, these guidelines.

All employees are obliged to comply with the guidelines.

Protection of personal data

ADIMA’s handling of personal data will be according to law and regulations.

Human worth

ADIMA supports international human rights as outlined, i.a., by the UN declaration and associated conventions.

We will be compliance with employees’ basic human rights as outlined in the International Labour Organization’s core conventions.

Occupational Health, Safety and Employee Security

ADIMA shall in the field of health, safety and employee security to promote good health and safe working environment in compliance with

internationally recognized standards.

Working environment

ADIMA shall be a good and professional place of work with an including working environment. Thus, you shall behave with respect and integrity

towards anyone you come into contact with through your work. We will create an environment free from any discrimination, such as in form of

religion, skin color, sex, sexual orientation, age, nationality, ethnic origin or disability. We will keep the working environment free from bullying,

harassment or similar. We do not tolerate any behavior that can be perceived as degrading or threatening.

Freedom of association and the right to collective bargaining

ADIMA recognizes the right to freedom of association and collective bargaining in mature labour environments. In such environments ADIMA

shall allow its employees to freely elect representatives among the employees, unless this would represent a breach of national laws and

regulations. Such employee representatives shall be allowed to carry out their functions unhindered at the work place. You share the

responsibility to avoid discrimination against any employee representatives.

Forced labour

Any employment relationship with ADIMA shall be freely chosen and free from threats.

Any employee shall be free to leave his/her employment after giving reasonable notice.

Child labour

ADIMA shall not employ or contract child labour. “Child labour” means any work by child or young person unless it is considered acceptable

under the ILO Minimum Age Convention 1973 (C138). “Child” means anyone under 15 years of age, unless national or local law stipulates a

higher minimum working age or higher age for completing mandatory schooling, in which case the higher age shall apply. Everyone share a

responsibility to secure that persons under the age of 18 do not perform any hazardous work, including but not limited to exposure to physical,

psychological or sexual abuse.

Property and assets

ADIMA’s property and assets, i.a. buildings and equipment, shall be managed and safeguarded in an appropriate manner. You shall observe the

Group’s security requirements concerning access to and use of the Group’s facilities, IT resources and access to electronic resources and

documents. Equipment and property owned by the Group may only be used for personal purposes if agreed in terms of your employment or if

allowed in ADIMA’s rules and guidelines.

Loyalty, impartiality and conflict of interests

ADIMA respects the individual employee’s right to a private life and private interests, but demands openness and loyalty to the Group and the

Group’s interests. You shall not allow personal interests affect your work or prioritize personal gain ahead of your work at ADIMA. Neither shall

you take part in or attempt to influence a decision or settlement if there is a conflict of interest or other circumstances exist, which could give

grounds to question your or ADIMA ‘s impartiality. Conflicts of interests should, wherever possible, be avoided.

Nature and the Environment

ADIMA will protect the environment and undertake initiatives to promote greater environmental responsibility. ADIMA shall adhere to relevant local and internationally recognized standards, minimize its environmental impact and continuously improve its environmental performance.

Information, Communication and Contact with Media

For any contact with media, Adima CEO has the responsibility for this, or can delegate it to actual staff in administration dependent on issue brought up.

Internal Control, Accounting and Reporting

All parts of ADIMA shall have good internal controls that ensure that the Group’s goals and strategies are fulfilled and complied with the Norwegian laws and regulations.

Relations with Customers, Suppliers, Competitors and Public Authorities

Customers shall be met with insight, respect and understanding. You shall always try to fulfill the needs of the customer in the best possible manner, within the business ethical guidelines that apply to the business. Customer’s personal information shall be protected in accordance with the relevant laws on protection of personal data.

Suppliers shall be treated impartially and justly. Suppliers in competition for contracts with ADIMA shall at all times be able to trust ADIMA’s selection processes. When selecting suppliers, you shall therefore follow the Group’s established guidelines and routines at all times.

ADIMA’s competitiveness in the market is based on good products and services at the right price. You shall always meet the Group’s competitors in an honest and professional manner.

Public authorities shall be met in an appropriate and open manner. Public information about the Group shall be given by ADIMA’s management or by the person responsible for public communications only, unless otherwise agreed.

Corruption and Bribery

ADIMA is opposed to all forms of corruption. You shall never offer or accept illegal or inappropriate monetary gifts or other remuneration in order to gain business or personal benefits for yourself or others. ADIMA has a firm attitude to gifts, remunerations and activities that may be perceived to include elements of a gift. This applies to both how we treat our customers and how our employees and cooperating partners should approach this issue. Special guidelines have been prepared to advise you on how to handle this kind of issues. You are expected to acquaint yourself with these guides and to comply with it.

Furthermore, you shall not use agreements with middlemen to channel payments to parties in such a manner so that it can be interpreted as contributing to corruption.

Money Laundering

ADIMA is firmly opposed to all forms of money laundering and shall take steps to prevent that financial transactions with the Group can be used by others to launder money.

Gifts and Business Courtesies

You shall always exercise caution in relation to offering or accepting gifts and business courtesies. You shall under no circumstances accept gifts or other remuneration if it can be reasonably perceived that these are for the purpose of influencing business decisions.

Political Activity

ADIMA does not give support to political parties, neither in the form of direct financial support nor paid working time. Employees participating in political activities will be granted leave from their work in accordance with the law and agreements.

Handling of Infringements

Should you become aware of an infringement of ADIMA’s rules and guidelines, you should raise this issue with your immediate superior. Should you wish to report an incident anonymously, you may report by use of ADIMA’s «whistleblower» system. The aim is for employees not to have to fear the consequences if they report something they see or hear. Failure to do so is itself a breach of the Code.

Adima has an established whistleblowing procedure. Send your concern to whistleblower@adima.no

Reporting to the CEO in ADIMA:
Email: haakon.hildre@adima.no
Tel: +47 47 83 74 43

ADIMA does not allow reprisals of any kind against those who, in good faith, report an infringement or suspicion of an infringement of the rules or guidelines.

Any questions regarding how the Code of Conduct should be interpreted or applied may be directed to the CEO.

The Board of Directors at ADIMA shall take all action it considers appropriate to investigate any violations reported to it. If a violation has occurred, ADIMA will take such disciplinary or preventive action it deems appropriate. In the event of a member of the Board or someone within Executive management is related to a case reported, the Board of Directors shall be consulted before a decision is made. If the case reported is related to other employees, the Compliance Officer shall be consulted before a decision is made.

Any changes or waivers to the Code for board members, managers or employees of ADIMA can be granted by the Board of Directors only.