Vedlegg til Elektrisk kraft til hele virksomheten
Fil: supplier-code-of-conduct---en.pdf
Vedlegg til anbudet Elektrisk kraft til hele virksomheten fra Direktoratet for samfunnssikkerhet og beredskap (DSB).
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Supplier Code of Conduct
Elmera Group ASA
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Contents
To our Suppliers .............................................................................................................................................................. 3
Part I: Understanding and applying the Code of Conduct
1. Business ethics ........................................................................................................................................................... 4
2. Scope .......................................................................................................................................................................... 4
3. Governing laws ........................................................................................................................................................... 4
4. Governance and complianc ........................................................................................................................................ 4
Part II: The Supplier’s business ethics
1. Sustainability ............................................................................................................................................................... 5
2. Climate ........................................................................................................................................................................ 5
3. Environment ................................................................................................................................................................ 5
4. Human rights .............................................................................................................................................................. 5
5. Labour rights and workplace standards ...................................................................................................................... 5
6. The Norwegian Transparency Act .............................................................................................................................. 6
7. Equality, diversity and respect ................................................................................................................................... 6
8. Health, safety and security ........................................................................................................................................ 6
9. Anti-corruption ............................................................................................................................................................ 6
10. Business benefits, gifts, hospitality and expenses .................................................................................................. 7
11. Sanctions ................................................................................................................................................................. 7
12. Fair competition ....................................................................................................................................................... 7
13. Accurate accounting ................................................................................................................................................ 7
14. Money laundering .................................................................................................................................................... 7
15. Confidentiality .......................................................................................................................................................... 7
16. Conflicts of interest .................................................................................................................................................. 7
17. Political activities ...................................................................................................................................................... 7
18. Protection of property and assets ............................................................................................................................ 7
19. Intoxicants ................................................................................................................................................................ 8
Part II: The Supplier’s business ethics
1. Where can you seek advice?...................................................................................................................................... 8
2. Where should concerns or violations be reported? .................................................................................................... 8
3. Consequences of violations of the code ..................................................................................................................... 8
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To our Suppliers
Elmera Group ASA (hereinafter Elmera or the Group) consists of the companies Fjordkraft AS, TrøndelagKraft AS,
Gudbrandsdal Energi AS, Elmera Industrial Ownership AS, Steddi Payments AS, AllRate AS, Elmera Nordic AS,
Fjordkraft Føretag AB, Switch Nordic Green AB and other companies that at any time is part of the Elmera Group.
Business ethics is the foundation for everything the Group do. All employees will conduct business operations in
accordance with internal ethical guidelines, together with good commercial utilisation. This Code of Conduct and our
commitment to business ethics are based on Elmera’s overall strategic platform.
Elmera has clear expectations of the Group’s Suppliers and other business partners. These expectations are based
on our own initiatives and existing framework conditions. Elmera is ESG committed and expects the same from our
regular Suppliers.
In recent years, our business activities have been subject to additional framework conditions, which also have a
direct impact on our Suppliers. This includes Trygg Strømhandel, as a separate certification scheme for power sales
companies, as well as the Norwegian Transparency Act, to which Elmera is subject to. Elmera has also signed
Skift’s (Norwegian Business Climate Leaders) ten principles for green procurement. In combination, this has an
impact on the requirements and expectations which Elmera makes of its Suppliers.
At Elmera, we give high priority to business ethics and we give our full support to employees who ask questions in
this area. Our commitment to business ethics can only be fulfilled if our partners and Suppliers do the same. The
background to the development of this Code of Conduct is the wish to clearly communicate our requirements to
Suppliers.
As a Supplier to Elmera, you are expected to consistently meet the requirements that are set within sustainability,
ethics and commercial activities.
Bergen. 1st of September 2025
[navn skjult]
Head of Legal & Procurement Elmera Group ASA
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Part I: Understanding and applying the Code of
Conduct
1. Business ethics
Elmera will purchase goods and services on a sustainable, ethical and socially responsible basis, and comply with
all legal requirements, wherever our business takes place. It is also our policy to adhere to relevant international
conventions and guidelines, including those from the UN and the OECD. Elmera has also signed Skift’s (Norwegian
Business Climate Leaders) ten principles for green procurement, and is a part of Future Proof.
Elmera seeks to ensure that our commitment to business ethics is also adhered to in our supply chain and in
relationships with our partners.
2. Scope
This Supplier Code of Conduct applies to all Elmera’s Suppliers and business partners, including all subcontractors
contributing to the delivery to Elmera. This also includes the Suppliers’ own employees at all levels, board members,
hired personnel, consultants and others acting on behalf of or representing the Supplier. The Code of Conduct takes
contractual precedence before any other contractual documents.
Furthermore, Elmera expects Suppliers to do their utmost to ensure that equivalent standards are adhered to and
respected within their own sphere of influence, and in particular by their own Suppliers.
3. Governing laws
Suppliers must comply with all applicable laws and regulations in their domicile country, as well as applicable laws
and regulations in countries in which they operate. Suppliers are expected to act in accordance with relevant
international conventions and guidelines set by international organisations, including the UN and the OECD.
Where there are variations between applicable laws, regulations and the Supplier rules or requirements in a contract
with the Supplier, the Supplier must adhere to the strictest requirements.
4. Governance and compliance
Suppliers will identify, manage and comply with the business ethics requirements set out in the Code of Conduct.
This means that the Supplier must provide – and clearly communicate – the appropriate principles, procedures,
management systems, quality improvement activities, internal control systems and manpower necessary to comply
with the Supplier's rules.
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Part II: The Supplier’s business ethics
1. Sustainability
The Supplier will recognise and, to the extent possible, focus on the UN’s Sustainable Development Goals (SDGs).
Suppliers must operate on a sustainable basis and seek to establish regular and open dialogue on sustainability
issues with local communities and other stakeholders. The Supplier will at all times give priority to sustainable
alternatives and, where possible, achieve universal design.
In addition, the Supplier should actively work to reduce greenhouse gas emissions, minimize resource consumption,
and prevent pollution throughout the value chain. The Supplier is also expected to uphold human rights, ensure fair
labor practices, and support diversity, equality, and inclusion in their operations. Environmental and social
performance should be monitored and improved continuously, with transparent reporting where applicable.
2. Climate
Elmera expects all our Suppliers to keep track of its climate footprint and take action to reduce its climate footprint.
This means that Elmera requires all regular Suppliers to:
a. Keep climate accounts
b. Have measures and action points to reduce their own carbon footprint.
c. Compensate for emissions through the purchase of approved climate credits, preferably EUA quota.
Norwegian Suppliers must document the aforementioned at Klimahub.
As an alternative to the aforementioned methodology, Suppliers whose targets have been approved as Science
Based Targets can also be approved. Read more about this here: Ambitious corporate climate action - Science
Based Targets
At any stage of the contractual relationship, Elmera may require documentation that the requirement has been
fulfilled. In the event of a Supplier’s breach of any such obligation as stated herein, the Supplier agreement may be
terminated with immediate effect.
3. Environment
Suppliers must support the precautionary principle in addressing environmental challenges, take initiatives that
promote increased environmental responsibility and encourage the development and dissemination of
environmentally friendly technologies.
4. Human rights
Within their area of influence, Suppliers must support and respect internationally recognised human right principles
and ensure that they do not promote human rights violations.
At any stage of the contractual relationship, Elmera may require documentation that the requirement has been
fulfilled. In the event of a Supplier’s breach of any such obligation as stated herein, the Supplier agreement may be
terminated with immediate effect.
5. Labour rights and workplace standards
5.1 Child labour
Suppliers may not use child labour or any other form of labour that deprives children of their childhood, potential or
dignity, or that is harmful to the child’s physical or mental health or development. Suppliers may not use a child as
labour if the child is under 15 years of age. If current legislation sets a higher age limit, this limit will apply.
Exceptions may be made for light work or training if this is permitted under the ILO’s Minimum Age Convention
(C138).
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In no case may Suppliers allow children under the age of 18 to perform hazardous work, including work that could
jeopardise their health, safety or development.
5.2 Right of association and the right to collective bargaining
Suppliers must safeguard and recognise the right of association and, in cases where a significant proportion of
employees consent to this, the right to collective bargaining. Suppliers may not practice discrimination against
employee representatives or trade union members, who must also be able to perform their work as workplace
representatives.
In cases where the right of association and the right to collective bargaining are restricted by national laws, Suppliers
must allow employees to freely elect their own representatives.
5.3 Forced labour
Suppliers may not use forced labour or other involuntary labour. Suppliers must ensure that the work is performed of
the persons’ own free will and without any threats.
In addition, Suppliers must ensure that all employees are free to leave their employment after an appropriate and
reasonable notice period.
5.4 Terms and conditions of employment
Suppliers must remunerate their employees in accordance with national legal minimum pay standards. They must
also ensure that working hours are not unreasonable and comply with local laws concerning working hours.
Suppliers must ensure that all employees have written employment contracts that describe the terms and conditions
of employment in a language that the employee understands.
6. The Norwegian Transparency Act
As a consequence of the Norwegian Transparency Act that came into force on 1st of July 2022, the Supplier must
ensure that human rights and decent pay and working conditions are safeguarded in the supply chain. The Supplier
must have an overview of their supply chain, and must, at Elmera's request, provide information about and
document the value chain in its entirety, as well as reported human rights violations in the value chain, and other
adverse incidents and remediation.
7. Equality, diversity and respect
Suppliers must work actively to create a working environment characterised by equality, diversity and mutual
respect. Employees or other parties involved in the performance of a contract with Elmera must be selected and
treated in a manner that does not discriminate on the basis of gender, skin colour, religion, age, disability, sexual
orientation, citizenship, social or ethnic origin, political convictions, or trade union membership, or otherwise.
Suppliers may not condone any form of discrimination or harassment at any of their workplaces.
8. Health, safety and security
Suppliers must work actively to ensure an injury-free and health-promoting working environment and to promote an
open and preventive health and safety culture. Suppliers must plan and act to avoid injuries and work systematically
to manage risk.
Suppliers must also to the best of their ability protect their employees from harm from circumstances beyond the
Suppliers’ control, such as natural disasters and threats to employees’ safety. Protection measures against threats to
employees’ safety must be proportional to the threat.
9. Anti-corruption
Suppliers shall not tolerate and must oppose all forms of corruption in both the public and private sectors. Suppliers
may not offer, solicit, give, approve or receive bribes or other improper advantages for business or personal gain,
either directly or indirectly, for themselves or for other parties.
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10. Business benefits, gifts, hospitality and expenses
Suppliers must prohibit the offering or receipt of business benefits - gifts, hospitality, expenses or other benefits - that
may constitute, or appear to constitute, an improper influence.
Furthermore, Suppliers shall not, directly or indirectly, offer gifts to Elmera’s employees or representatives, or their
close associates, unless the gift is modest and appropriate in terms of time and place. Hospitality such as social
events, meals or entertainment may be offered if this is necessary for business purposes and the cost is within
reasonable limits. Travel expenses for persons representing Elmera are paid by Elmera. During contract
negotiations, or bidding or award processes, all hospitality, gifts or coverage of expenses must be avoided,
irrespective of value.
11. Sanctions
Suppliers may not do business with countries, groups, organisations or individuals that are subject to sanctions.
12. Fair competition
Suppliers must set high commercial ethical standards and compete within the limits set by the rules of competition in
the markets in which they operate. Suppliers may not engage in any form of illegal price coordination, market
sharing or other practices that are contrary to applicable competition legislation.
13. Accurate accounting
Suppliers must be committed to transparency, verifiability and accuracy in everything they do, while complying with
their confidentiality obligations. All accounting information must be correct and registered and recorded in
accordance with laws and regulations.
14. Money laundering
Suppliers may not take part in any form of money laundering and must ensure that financial transactions are not
used to launder money.
15. Confidentiality
Suppliers must observe a duty of confidentiality and may not misuse information concerning
Elmera that is of a confidential nature. Such information may be further defined in the contract between Elmera and
the Supplier.
16. Conflicts of interest
Suppliers must avoid conflicts of interest while they are working for Elmera. A conflict of interest arises when a
representative of a Supplier attempts to promote personal interests, or the private interests of a friend or relative,
as an element of their position as a representative of the Supplier. Suppliers must report any situation where there is
a possible or perceived conflict between their personal interests and Elmera’s interests.
17. Political activities
Suppliers may not support political parties or politicians in connection with contracts entered into with Elmera.
18. Protection of property and assets
Suppliers are responsible for safeguarding and only using Elmera’s assets in their possession in a responsible
manner. Elmera’s assets may not be used for personal gain.
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19. Intoxicants
It is not permitted to be under the influence of intoxicants, including alcohol and drugs, while working for Elmera.
Limited amounts of alcohol may be consumed when local customs and occasions indicate that this is appropriate,
provided that this consumption is not combined with the operation of machinery, driving or other activities that are
incompatible with the consumption of alcohol.
Part III: Handling cases of doubt and violations
of the code
1. Where can you seek advice?
If a Supplier is or becomes uncertain about the significance of the Code of Conduct, or what constitutes appropriate
behaviour in the light of this code, they must seek advice and raise the matter with their contact person at Elmera.
Suppliers can also contact Elmera’s Legal & Procurement department or Elmera’s contact person to the Supplier.
2. Where should concerns or violations be reported?
Suppliers must have internal arrangements for reporting and handling concerns or violations, inform Elmera of all
concerns and possible violations, and offer full cooperation in Elmera’s investigation of the matter.
Suppliers may not take any retaliatory measures against anyone who raises or contributes to raising a genuine
concern related to business ethics.
Reporting may take place anonymously to Elmera’s Legal & Procurement department
3. Consequences of violations of the code
Failure to act in accordance with the Supplier’s code of conduct is considered to be a serious matter that could lead
to termination of contract, claims for proportional compensation, disqualification as a Supplier and reporting to the
relevant authorities.
Elmera may require documentation that the Supplier requirements and obligations in this Code of Conduct are
fulfilled at every stage of the contractual relationship.
In the event of a Supplier’s breach of any such obligation as stated herein, the Supplier agreement may be
terminated with immediate effect.
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