Ethical guidelines for add energy group

This document contains the ethical guidelines for add energy group as and all its subsidiaries (below jointly referred to as add energy group or the Company).

The Company’s reputation and public confidence in the Company depend on our employees’ professionalism and competence, as well as a high level of ethical conduct. This applies to both the Company’s business operations and the conduct of each and every one of us. We therefore expect every employee to act with due care, integrity and objectiveness and to refrain from any actions that could undermine confidence in the Company

These rules are intended to be a set of standards and principles that may serve as guidelines for all of the Company’s employees and advisers.

§ 1 Whom the rules apply to
The rules apply to all employees and contract personnel. They also apply, as appropriate, to members of the executive and controlling bodies in connection with the performance of their duties for the Company.

In these rules, closely related means spouse and cohabitant, as well as their own parents, siblings and children and their spouses and cohabitants. The term also means enterprises in which the employee or any of the persons mentioned above have a decisive influence. Other special circumstances may also be of such a nature that the parties affected must be equated, following a specific assessment, with closely related parties. Spouses, partners or family members shall avoid as far as possible to work together within the same unit. They shall not have a position where one is the other’s subordinate. Persons who are in direct relation, as aforementioned, shall not co-sign on behalf of the Company. Every employee is obligated to inform his or her supervisor should this be the case.

§ 2 Relationship with other regulations
The rules in the Company’s ethical guidelines are minimum requirements. The Company must comply with all current laws and regulations, for example the Competition Act and legislation relating to corruption and money-laundering. Every single employee is personally responsible for complying with the requirements established by laws and regulations. The Company must likewise set a good example.

§ 3 Competence and authority
All decisions must be made at the right level and by the right person in the organisation pursuant to current authorisation rules. You can only bind the Company if you have been granted special authority to do so, and you must always act within the framework of the authority granted.

§ 4 Duty of confidentiality
All employees in the Company have a duty of confidentiality concerning commercial or private matters that come to their notice in connection with their work for the Company, unless they have a statutory right or obligation to provide information. This duty of confidentiality also comprises information abut the Company’s commercial operations and other matters of an internal and confidential nature. Confidential or graded information received while on service must not be disclosed to unauthorised parties or be used for personal gains.

This duty of confidentiality does not only apply externally, but also between individual units in the Company and towards other persons in the same unit who do not need to know the information concerned in their work. The duty of confidentiality applies after termination of the employment or contractual relationship and for as long as the information must be regarded to be sensitive to competition or otherwise confidential. 

Furthermore each employee and consultant shall take precautions in discussing, reading or working with Company-related matters in public places such as airports, airplane, train, etc. This includes safe and necessary steps to ensure that electronic equipment such as mobile telephone and laptop computers are secure against theft or misuse by unauthorised persons.

§ 5 Loyalty, legal competence and conflict of interests
Employees and contract personnel in the Company shall not handle or decide or participate in a case which involves personnel where a conflict of interest or other circumstances may impede confidence in the impartiality of the person concerned. In such cases, no influence must be exerted on others in the Company.

Should personal interests affect the decision in a case for  whom the employee is professionally responsible, an immediate superior must be contacted so that the employee concerned may be released from the task in question.

§ 6 Relations with business contacts, competitors and the public authorities
Employees and contract personnel in the Company shall not take any action that may place them in such a position with the Company’s customers, suppliers, shareholders or other connections which may impede the objective conduct may be impeded.

Suppliers shall be treated impartially and fairly. In selecting suppliers, the Company’s established guidelines and procedures must always be followed. The Company’s employees must not abuse their position to achieve special benefits in their contacts with the Company’s suppliers. Employees must denounce and combat any unethical business practice. The Company therefore places high importance on the behaviour of its employees and contract personnel to ensure that throughout all procurement activity the commercial integrity of the Company is maintained at the highest level.

The Company’s competitors shall always be treated in an impartial and professional manner.

§ 7 Information and reporting
Public information about the Company shall only be furnished by the Company’s CEO, CFO or information officer, unless otherwise agreed. No employee or contract personnel shall speak or convey information in any forum where public media is present without prior approval from Company management or the information officer. All information from the Company shall be reliable, correct and comply with a high, professional, and ethical standard.

The Company’s reports shall provide complete, adequate and correct information.

§ 8 Whistleblowing
The Company recognises that the practice of information brokering now appears to be widespread in the industry, It is the Company’s policy to conduct its business in a way which is lawful and consistent with the highest ethical standards, that employees and contract personnel will not utilize information brokers (intermediaries who obtain and sell information illegally).

Should any reprehensible condition in the Company be disclosed or pose a potential problem, focus shall be on the issue, not on the whistleblower. Whistleblowing is a statutory instrument to be used against any deviation from the Company’s ethical guidelines.

Should any reprehensible condition in the Company be disclosed or pose a potential problem, focus shall be on the issue, not on the whistleblower. Whistleblowing is a statutory instrument to be used against any deviation from the Company’s ethical guidelines.

§ 9 Gifts and other benefits
No employee or contract personnel shall receive gifts or other benefits of a personal nature which may impair his or her integrity or be detrimental to the employee, contract personnel or the Company.

This also applies to anyone closely related to the employee or contract personnel if the gift or benefit is based on the employment relationship. In case of doubt, an immediate superior must always be consulted. Benefits which the Company may have obtained for all employees are exempt from this policy.
 
Trips, stays and/or courses at the invitation of and paid by suppliers shall be approved by an immediate superior. Strict requirements must be made regarding professional contents and usefulness. Trips and events where the Company’s employees and contract personnel are the only guests must as a rule be paid by the Company. Such trips, stays and/or courses must not be of such a character that they may impair the receiver’s integrity or be detrimental to  the employee, contract personnel or the Company. 

Activities that may be described as customary representation must not be of such a character that they may affect any decision-making process. In case of representation or attentions from suppliers, a superior must always be informed in advance. Employees involved in a tender or negotiations process must refrain from such activities in respect of the tenderers concerned.
 
Gifts given on behalf of the Company must be kept at a sober level. It must never be possible to question The Company’s motives or the receiver’s integrity shall not be left for question. No gifts shall be given on behalf of the Company for the purpose of reciprocal favours for one’s own benefit. 

§ 10 Corruption
In everything we do it is forbidden for employees and contract personnel to bribe og receive bribes or unreasonable gifts from customers, suppliers, authorities or other parties.  Should an employee or contract personnel be offered an item or service which can be considered a bribe, the employee or contract personnel shall report the offer to his or her supervisor immediately.

It is not permitted to for consultants, agents or other intermediaries to channel payment to any of the aforementioned parties.

Agents, co-operating partners and intermediaries:
In the event that there is a requirement for cooperation with a local agent, for ex. in a contract tender process or selective internationalization, severe demands shall be enforced to the agent and cooperating partner, such as clear description of services, market conditions, openness and compliance to add energy’s guidelines and requirements.

§ 11 Openess, honesty and compliance
We are committed in aiming for honest and open dialogue with colleagues and other cooperating parties. Such openness shall however not conflict with the Company’s rules regarding confidential information.

§ 12 Respect for the individual
All employees and contract personnel in add energy shall act in accordance with the human rights Norway takes part in, and we shall show respect to all persons with whom we make contact.

The Company has a firm stance that neither add energy, its cooperating partners nor sub-contractors shall engage in use of child labour in any of its activities.  The Company may request a declaration from sub-contractors which confirms compliance to our policies and guidelines.

When one represents add energy, at home or during business travel, one shall not engage in purchase of sexual or other services which according to Norwegian standards can infringe or degrade another individual.

No employee or contract personnel shall discriminate other colleagues, cooperating partners, customers or other parties based on religion, gender, sexual preference, age, nationality, demographics, marital status, impairment or other conditions.

§ 13 Internal relations
You must not enrich yourself from the Company’s tangible or intangible assets, including property, special knowledge, methods, concepts or ideas. You must not to an unreasonable extent use the Company’s IT equipment, material or other assets for private purposes or for activities not relevant to your work. The Company’s rules and guidelines for data security must be observed.

The Company must be a good and professional workplace with an inclusive working environment. You must therefore act with respect and integrity towards any person you come into contact with through your work. No employees may act improperly in any way towards colleagues.
 
§ 14 Service and involvement in matters outside employment in add energy
Employees, contract personnel and other closely related persons  shall not take advantage of the Company’s tangible or intangible assets, including property, special knowledge, methods, concepts or ideas. Unreasonable extensive use of the Company’s IT equipment, material or other assets for private purposes or for activities not relevant to your work shall not be tolerated. The Company’s rules and guidelines for data security must be observed.

The Company shall be a good and professional workplace with an inclusive working environment. All are therefore expected to act with respect and integrity towards any person one comes into contact with through  work for and in the Company. No employee or contract personnel shall act improperly in any way towards colleagues.

§ 15 Notification of infringements
All employees who acquire knowledge of matters that are in conflict with the rules that apply to the Company’s operations or in conflict with the Company’s ethical code, must immediately inform their immediate superior and the director of the Company’s Human Resources function.

If the immediate superior is involved or is prejudiced for other reasons, notice should be given to his/her superior and the director of the Company’s Human Resources function.
 
§ 16 Follow-up and sanctions
Managers at all levels have a particular responsibility for ensuring that their own and their subordinates’ conduct complies with the regulatory framework. Each person must at any time assess whether his/her actions are compliant. If doubts arise as to whether an action is ethically defensible, the person concerned must abstain from this action or raise the question with his/her immediate superior.

The Human Resources Director is responsible for making the code of ethics available and for arranging training and updating.

Anyone infringing the Company’s rules or guidelines must be prepared for reactions adjusted to the nature and scope of the infringement and, pushed to extremes, termination of the employment relationship by notice or summary dismissal.

__________________
Per Arne Jensen
Chairman of the Board
add energy group as

Stavanger, 31 mars 2009