Code of Conduct

This Code of Conduct is the guiding framework for Norstat’s business culture. It combines two important aspects: on the one hand the claim to comply with the law and on the other hand the special requirements for ethics and integrity. For Norstat, it is both an internal demand and a promise to the outside world. It also ensures that Norstat is and remains transparent and comprehensible for everyone. At Norstat, the Code of Conduct applies to Norstat employees and our Board of Directors. In addition, it also applies to temporary employees, i.e. people who are functionally on an equal footing with employees.

The content and values of this Code of Conduct do not, however, stop at any limit. For this reason, Norstat expects its suppliers and consultants to comply with the behavioural requirements set out in its Code of Conduct and aims to ensure that they are also contractually obliged to comply with these behavioural requirements. For this reason, Norstat has defined the following principles for its Code of Conduct.

1. Preliminary remark

1.1 What does “compliance” mean?

“Compliance” means to adhere to the laws and internal regulations in all business activities. For Norstat “compliance” also means to act in an ethical manner. Norstat expects that all of its directors, officers, members, consultants, secondees and employees, whether permanent or temporary behave and act compliant in order to prevent economic and reputational damage for Norstat.

1.2 Who is responsible for compliance?

Compliance concerns all of us. Everyone at Norstat is responsible for compliance in their daily work. Only if we know, understand and adhere to the laws, regulations and our own rules and policies, we can reach our goals. Behaving and acting in compliance at all times and everywhere, also protects each Norstat representative against personal liability.

This requires each of us to pay constant attention to the topics mentioned in this Code of Conduct and all the other Norstat policies, rules and procedures.

1.3 To what extent does the Code of Conduct apply?

This Code of Conduct (as well as all of Norstat policies, rules and procedures) applies to all internal, external, national and international matters, relations and business situations. This Code of Conduct represents the minimum compliance standard for the activities of all Representatives of Norstat. In any case, the applicable laws of the country or countries a matter, relation or business situation is connected or related to, apply additionally and – to the extent they collide or deviate – precede this Code of Conduct.

2.Compliance with law

We as Norstat have a high standard on the integrity of our actions. Norstat and all our Represenatives are obliged to observe all applicable laws and legal regulations. This principle of compliance also applies explicitly if Norstat and/or one or more persons in Norstat would expect to gain advantages by violating laws or guidelines.

3. Adherence to human rights

Norstat supports and respects the protection of international human rights as set forth in the Universal Declaration of Human Rights of the United Nations and the fundamental conventions of the International Labour Organization. Norstat expressly rejects child and forced labour or labour favoured by human trafficking and makes this a criterion in the selection of suppliers and business partners.

4. Research ethics

4.1 ESOMAR CODE

All Norstat companies are corporate members of ESOMAR, and all Norstat representatives shall adhere to the rules laid down in the ICC/ESOMAR International Code on Market, Opinion and Social Research and Data Analysis, wherein is described guidelines for transparent, responsible and ethical conduct.

5. Fair work

5.1 Equal opportunities and non-discrimination

Norstat stands for multicultural, beneficial cooperation and equal opportunities. Discrimination based on race, ethnic origin, gender, religion, ideology, disability, age, sexual identity or other personal characteristics has no place in Norstat.

5.2 Fair working conditions

We at Norstat ensure that fair working conditions exist both in our company and with our business partners, and always meet or surpass the minimum legal requirements for fair working conditions in the countries where we operate. We also require the same of our subcontractors.

5.3 Health and safety at work

Our employees are our most important asset. Therefore, their safety is a special concern for us. We include occupational safety in all our business considerations. All our employees are called upon to communicate suggestions for improvement to their supervisors, and take part in employee satisfaction surveys, actively pointing out areas for improvement.

5.4 Alcohol and drug abuse

Our company also stands for a safe, productive and drug-free working environment. In the premises of Norstat no one may be under the influence of illegal drugs, or other illegal substances. Alcohol intake in company events, whether in or outside Norstat premises, should be kept to a level that is responsible.

6. Fair and free competition

All employees of Norstat must comply with applicable fair competition and antitrust laws. All measures aiming at an inadmissible restriction of competition and/or violating legal regulations are to be avoided. In principle, agreements between companies, decisions by associations of companies and concerted practices which aim towards or effect the prevention, restriction or distortion of competition are prohibited.

7. Business relationships

7.1 Prohibition of Bribery and Corruption

Norstat does not tolerate any immoral business practices such as corruption, bribery or dishonest advantage. Therefore, Norstat will not improperly influence business decisions by using or accepting improper advantages of any kind. Any undue influence on public officials is strictly prohibited not only to employees but to anyone who works for or provides services to Norstat in any form. Any appearance of a bribery attempt must be avoided, for example, when obtaining official permits.

For instance, in the case of a public tender, representatives of Norstat shall not offer any incentive or gift of such a magnitude that it can be perceived as an attempt to unduly influence individuals involved in the decision making process.

Norstat representatives should act in line with generally accepted market standards also in this area.

7.2 Prevention of money laundering

Norstat fully complies with its obligations to prevent money laundering. Every Represenative must avoid unusual financial transactions and have a high awareness thereto. This applies to transactions involving cash or indirect transactions that are conducted via third parties and that could give rise to suspicion of money laundering. Possible cases of suspicion must be reported to the supervisor and/or the management of Norstat.

For instance, pay special attention to unusual transactions in connection to incentive providers, unusual amounts on invoices from subcontractors and so on.

Money laundering is often a complicated matter and difficult to detect. If you witness transactions that you are unsure what to make of, you should get in touch with our Financial Controller who will be able to help you determine if foul play is at hand.

7.3 Tax compliance

Norstat are prohibited from evading taxes or the like on behalf of Norstat, nor may they assist, aid, abet, advise or assist in tax evasion or engage in any similar legally prohibited activities for customers, business partners or other third parties.

8. Conflict of interest

Norstat respects the privacy of its employees, directors and officers and is not interested in personal matters outside the workplace. On the other hand, it is important for all employees, directors and officers to make sure that professional and private interests are clearly separated. Conflicts of interest can cast doubt on the integrity and professionalism of Norstat. They must therefore be identified and avoided at an early stage.

Personal relationships with a business partner, e.g. with family members, must not lead to preferential treatment of the business partner and our professional position must not be used for personal gain.

We report possible conflict situations or cases of doubt and solve them together with our supervisors or management. In this way we ensure that business decisions are made neutrally and in the interest of Norstat.

9. Business and trade secrets, assets

9.1 Protection of confidential company information

Trade and business secrets as well as confidential information are important assets of Norstat. Every Representative is obligated to treat information about Norstat, its business and business partners that is not publicly known as strictly confidential and to protect it from unintentional disclosure. This applies in particular to significant intellectual assets such as patents, trade secrets, intellectual property, trademarks, research and copyrights, but also to conditions granted to others as well as the content of any agreement or document.

This applies for instance to new or planned concepts and products that we become familiar with in the process of concept or product testing.

9.2 Protection of company assets

Each of us is responsible for the protection and resource-saving use of the company assets. Assets may not be removed from the company. Everyone at Norstat is obligated to use the assets of Norstat for legitimate business purposes and to protect them from loss, damage or unlawful use.

10. Data protection and information security

10.1 Data privacy

Norstat is aware that the personal data of its customers, business partners, shareholders and employees is highly sensitive, and protects that data by handling it in a careful and responsible manner. Therefore Norstat takes a variety of technical and organisational measures to ensure the confidentiality of personal data in these efforts. Every individual is responsible within the scope of his/her duties for ensuring a high level of data privacy at Norstat. The Norstat’s employees adhere strictly to the data privacy regulations and, in particular, respect and observe the comprehensive rights of those whose data they collect, process and use.

For instance, Norstatpanel members’ personal data should never be accessed, sold or used for any other purposes than those the panel members have given their permission to.

10.2 Data security

Data security is of paramount concern to Norstat. It is a decisive factor of its success and public image. That is why Norstat uses all the appropriate and reasonable technical and organizational means at its disposal to protect company data and the data of its customers, business partners, shareholders and employees against unauthorized access, unauthorized or improper use, loss and premature destruction.

All Norstat employees are obliged to read, understand and follow the IT Security instructions for users.

10.3 Social media

Social online networks offer us countless opportunities to communicate with our business partners, families, friends and the public in general. Social media includes social media messenger services (e.g. WhatsApp Messenger, Facebook Messenger, Instragram), blogs, social network websites, wikis, photo/video sharing sites and other chat applications and chat rooms. Electronic messages are permanent records of our communications that can significantly impact the reputation of Norstat. Our employees must not appear to be speaking or acting in the name or on behalf of Norstatunless they are specifically authorized to do so.

For instance, users responsible for providing content on the Norstat social media accounts on Instagram or snapchat may post on behalf of Norstat, and Managing directors or other staff may post on social media sites with Managing directors’ permission, but other employees should not appear to speak on behalf of Norstat on Social media platforms.

Leaders should also be conscious that they are role models when they are expressing their views on Social media platforms, and may be perceived as speaking as Norstat representatives even when they engage in social media as private persons. They should therefore be careful not to post content that could be perceived to go against Norstat policy, e.g. political content or content that can be perceived as promoting discrimination.

11. Compliance with rules of behavior

Norstat expects its Representatives to behave in line with the Code of Conduct. Any breaches of these rules, legal obligations, or of other internal policies and regulations may have serious consequences not only for the individuals committing them, but also for Norstat. Therefore, deliberate misconduct will not be tolerated. Without any exception, Norstat will severely sanction any such misconduct or violation of legal provisions. In doing so Norstat will take no account of the employee’s rank or position within the company. Norstat creates a climate and atmosphere free of any fear of negative consequences to encourage employees to communicate violations and misconduct, if necessary.

This Code of Conduct as well as all internal guidelines, trainings, etc., do not necessarily address all issues and questions. Every employee is therefore given the opportunity and is requested to contact his or her supervisor or the management at any time regarding questions and remarks.

12. Indications of weaknesses, contact person and monitoring

If employees observe weaknesses in Norstat’s compliance management system or possible violations of laws or this Code of Conduct, Norstat encourages them to report these confidentially to their supervisor, management, or via the whistleblower channel.

You can reach these under the following contact details:

Whistleblower platform / application
Contact person: Tone Belsvik, Quality Manager
e-mail: tone.belsvik@norstat.no
Phone: +47 936690887

The report should describe the relevant information as precisely as possible.

Details can be found in the Whistleblower Policy that Norstat has established.

When investigating a report, Norstat and the employees/managers involved will take care to protect employees who have made reports in good faith from harm of any kind. To this end, the confidentiality of the identity of the whistleblower is ensured at all times so that no conclusions can be drawn about his person and no disadvantage is incurred due to the fact that an employee has made a report.

Compliance with the requirements of this Code of Conduct and the internal guidelines is regularly monitored, e.g. by superiors, internal audit or external auditors. Management is also informed about which measures are to be introduced and implemented to further develop and improve the compliance system.