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Code of Conduct
It is a declared policy of Nordlux A/S to be a socially responsible company. Therefore the materials we use in-house as well as for our customers must be produced with a view to sustainability, and consequently materials imported from third countries must be produced under socially responsible conditions, all in accordance with international principles and conventions.

The supplier signs a Code of Conduct that is being checked through control forms completed by the supplier. Nordlux A/S reserves the right to monitor if the supplier observes the signed Code of Conduct that is composed within the framework of the recommendations of the Confederation of Danish Industry and the Danish Industry of Human Rights as well as applicable international standards, including those of the United Nations.

As a natural continuation of this Code of Conduct the supplier must commit his or her supplier(s) to the same standards and see to it that the standards are indeed observed, as it is the policy of Nordlux A/S not to contribute to violation of the annex of the contract per substitute. Thus, the Code of Conduct is in force for the supplier as well as his or her sub-supplier(s) in 2010, the supplier must start screening and selecting sub-suppliers with a view to their ability to meet the standards of this code and gradually establish a system to check that sub-suppliers operate in conformance with the code.

The aim of the code is not to terminate business, but to help suppliers improve social and environmental standards. Nordlux A/S is therefore ready to work with suppliers to achieve compliance with the provisions of this code, whenever the parties deem this desirable and possible.

General principles
None of the Nordlux A/S Code of Conduct principles must undermine national legislation. Any supplier is as a minimum under an obligation to observe national laws and regulations. The supplier is committed to choosing the highest standard, be it the national legislation or this Code of Conduct.

Child labour
• The supplier shall not engage in, or benefit from, the use of child labour. Whenever employing manpower under the age of 18, the supplier must make sure that national legislation regarding age limits is observed.

  • • If the supplier becomes aware that it is employing children of school age, it shall ensure that the children are given education and financial support rather than being terminated from employment. The programme shall be decided in consultation with the child and its family.
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  • • Providing this is allowed by national law, the supplier can employ children between 12 and 15 years for light work for a few hours daily. The work must not keep the children from attending school, and it must take into consideration the natural limits of the children, including their anatomical development. For full time employees under the age of 18 individual training programmes must be available.
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  • • The supplier must refrain from the employment of manpower under the age of 18 whenever the work can be of risk for health or safety.
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  • Forced labour
    • The supplier must refrain from any use of forced labour, and must ensure that all employees have free personal movement during the employment.

  • • Under no circumstances must the supplier deprive the employees of identity papers, passports or other personal papers.
     
  • Discrimination
    • The supplier must not discriminate based on a person’s race, sex, colour, sexual preference, language, religion, or political conviction.

  • • All employment-related decisions, including hiring, remuneration and benefits, shall be based on relevant and objective criteria.
     
  • Freedom of association
    • The supplier must not prevent employees from exercising the freedom of association or discriminate employees based on their use of this freedom. The supplier shall allow workers to freely elect their own representatives and workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.

    Health and safety
     • It is the duty of the supplier to ensure all employees a safe and healthy working environment, including machine safeguarding and protection against fire, against hazardous chemicals and particles as well as against accidents. The supplier must have a safety policy and a documented safety procedure for hazardous work and emergency situations. Safety procedures, including necessary training in the proper use of machinery, must be followed. Workers must not be disciplined for raising safety concerns.

  • • The supplier must provide all employees with well-lit and ventilated work stations.

  • • The supplier shall provide its employees with the protective equipment and training necessary to perform their tasks safely. The supplier should take steps to ensure that the protective equipment is used by employees in accordance with the company safety requirements. The supplier must provide the employees with satisfactory sanitary facilities, including access to lavatories and drinking water according to the needs of the employees. If the supplier provides the employees with accommodation, the supplier must ensure that the employees have access to satisfactory sanitary facilities and that the accommodation is safe and healthy to live in. The accommodation shall provide reasonable space and adequate emergency exits.
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    Working conditions
  • •The supplier must protect the employees against any kind of mental, physical and sexual assault, harassment, abuse or threats at the place of work, whether committed by management or fellow workers. This includes disciplinary measures.

  • • The employee must receive at least the minimum standard wage set by law or the local prevailing industry wage, whichever is higher. Regardless of this the supplier must make sure that the employees receive a pay that enables them to cover basic personal needs and the needs of the closest family. Overtime must be fully compensated according to local law, or, if there is no legally prescribed premium rate, at a rate at least equal to the regular hourly compensation rate. Payment of wages must take place in accordance with national law. Deductions from wages must be transparent and must never be used as disciplinary punishment.

  • • The supplier shall ensure that the regular work-week as well as overtime correspond to the requirements in national or local law.

  • • All employees shall be provided with a written, understandable and legally binding contract, including the employee’s childbirth, holidays and working hours. Employees are entitled to at least one day off per week and to be paid holiday and sick leave each year. Provisions for non-permanent and seasonal workers should be no less favourable than for permanent workers.

  • • The supplier must respect the private life of the employee.

  • • The supplier must provide employees with guidelines for access to medical assistance or health related assistance during working hours.
     
  • Product responsibility
    The supplier must exercise due diligence when designing, manufacturing, and testing products so that product defects, which could harm people’s health or the environment, can be avoided. As a minimum, the supplier must live up to the CE norms and be able to document this. It is up to the supplier to finance the costs involved in any detailed Declaration of Conformity that it may be looking for.

    The environment
    The supplier must strive to minimise the adverse environmental impact of its activities and comply with all applicable environmental laws and regulations.

    In particular, the supplier should focus on:

    • Use of scarce natural resources, energy and water
     
  • • Emissions to air and releases to water
     
  • • Noise, odour and dust emission
     
  • • Potential and actual soil emission
     
  • • Handling of hazardous substances
     
  • • Handling of hazardous and non-hazardous wastes
     
  • • Product issues (design, packaging, transport, use and recycling/disposal)
     
  • The supplier shall demonstrate continuous improvements of the overall environmental performance related to areas listed above.

    Ethical business practices
    The supplier must develop its ethical business practices in order to live up to the policy objectives laid out in the areas below:

    Sensitive Transactions
    • It is the policy of the supplier to prohibit employees from entering into sensitive transactions and business dealings generally considered to be either illegal, immoral, unethical or to reflect adversely on the integrity of the supplier and its commercial partnership with Nordlux A/S. These transactions usually come in the form of bribes, kickbacks, gifts of significant value or payoffs made to favorably influence some decision affecting a company's business or for personal gain of an individual.
     
  • Commercial Bribery
    • The supplier exercises a policy of prohibiting employees from receiving, directly or indirectly, anything of value in return for using or agreeing to use his or her position for the benefit of that other person. Similarly, commercial bribes, kickbacks, gratuities and other payoffs and benefits paid to any customer are prohibited. However, this does not include expenditures of reasonable amount for meals and entertainment of customers if they are otherwise lawful. These expenses should be included on expense reports and approved under standard company procedures.
     
  • Accounting Controls, Procedures and Records
  • • The supplier accurately keeps books and records of all transactions and the dispositions of its assets as required by law, and maintains a system of internal accounting controls to ensure the reliability and adequacy of its books and records. The supplier ensures that only transactions with proper management approval are accounted for in its books and records.

    Implementation
    • The supplier must sign all annexes to the contract and once a year complete a questionnaire before receiving a social audit mission from Nordlux A/S. In the case of gross negligence or false information regarding the Code of Conduct, Nordlux A/S reserves the right to terminate the co-operation, without notice and without further financial obligations.
     
  • • On enquiry the supplier must provide the following for control:
     
  • • Name and age of all employees,
     
  • • Hours account,
     
  • • Wages account,
     
  • • Health specifications, including accident rates and possible licences from the authorities,
     
  • • Any other documentation which is necessary for the proper conduct of the social audit.
     
  • • If the supplier does not meet this Code of Conduct and if the supplier wishes to implement a plan for the fields where the standards are not met, Nordlux A/S can offer assistance regarding analysis, strategy and implementation in order to bring the supplier up to standard.