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Ethical guidelines

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We all have a responsibility

Veidekke is one of Scandinavia’s largest construction and property development companies. We are literally helping to build society and we are a major contributor in resolving key tasks in both the private and public sectors. This makes us proud.

We encounter ethical challenges and dilemmas in society in general and while carrying out our many assignments. We may, for example, face situations that are on the borderline between legal meetings and criminal corruption, or on the borderline between safe job performance and a violation of safety rules. There may also be situations where legitimate business practice or actions may be ethically questionable. Society, customers, suppliers and employees must be confident that these challenges are taken seriously at Veidekke, that we do not break laws and regulations, and that we speak openly, honestly and con-structively about the ethical problems that may emerge. This enables Veidekke to conduct its business in an ethical and legally compliant way.

Veidekke’s organisational model allows our managers great manoeuvrability at local level, with a clear responsibility for working within the framework of Veidekke’s values and rules.

We have a participative work approach, which means we rely on the efforts of each individual. Those of us who work at Veidekke shall be open to dialogue and discussion about what is right and wrong in order to ensure that the company complies with internal values and guidelines, and society’s laws and regulations. We shall be constantly committed to making the right and wise choices. In case of doubt, we shall seek the advice of our colleagues and managers.

Rules and attitudes in society are constantly changing. Veidekke’s ethical guidelines shall reflect such changes and what society expects of us at any given time, combined with fundamental ethical norms that remain firm over time and help to define who we are as individuals and as a Group.

November 2014

Arne GiskePresident and CEO

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PURPOSE

These guidelines are the framework for how we at Veidekke act and behave, ensuring that our operations are conducted in an ethical and socially responsible way. Every-one who works for or represents the company, individually and collectively, has a responsibility to act ethically correctly.

ScopeVeidekke’s ethical guidelines apply to everyone who works in and for the Veidekke Group. We also expect our sub-con-tractors and suppliers to follow our ethical guidelines

ComplianceEveryone shall familiarise themselves and comply with the guidelines. The guidelines shall represent the foundation of all training in ethics, values, legislation and regulatory compliance, and shall characterise us in our daily work.

Violations of the ethical guidelines will result in punitive measures, which will depend on the severity of the vio- lation. Violations may also result in reporting to the relevant public authority.

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+ professional+ reliable

+ enthusiastic+ ground-

OUR VALUES:

breaking

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VEIDEKKE’S VALUES

The Veidekke House is our management and behaviour model, and helps us to navigate correctly in our daily work.

The values shall form the basis of all our behaviour:

ProfessionalWe shall behave ethically correctly, know and comply with laws and regulations and give colleagues, customers and partners our best advice. We shall have thorough know-ledge of the markets in which we operate and treat every-one in our environment with respect and as equals.

ReliableOur behaviour shall be characterised by openness, reliabil-ity and honesty. We shall follow legislation, internal guide-lines and society’s norms. We shall keep our promises, act in an upright way and not put our own or others’ integrity to the test. We shall not unlawfully acquire or disclose confidential information or use it in situations in which it is not intended to be used.

EnthusiasticWe shall show and create enthusiasm for what we do. Together we shall make each other strong and take pride in our value creation.

Ground-breakingWe shall have a fresh approach, have ambitious targets, adopt new ways of working and be a trend-setter in the industry.

With the values as our foundation, we facilitate value-cre-ating partnerships with our customers and suppliers. The Veidekke House is both a symbol of and a guideline for conducting our operations in accordance with the values and ensuring that we reject unethical and illegal professional conduct.

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DILEMMAS AND WISE CHOICES

To secure trust and confidence, we have to make wise choices. Making wise choices requires good understand-ing and knowledge of laws and regulations, concurrence between our personal values and Veidekke’s values, and proper handling of ethical problems and dilemmas.

What is commonly referred to as the principle of public access provides a good rule of thumb for wise choices. This means that everything we do in a work context we should also be willing to stand for openly and in public: “Is it all right if what I am doing now is also publicly known?” If the answer is no, there is reason to be extra careful and choose a different way of acting. At Veidekke, we shall deal with situations where we face difficult choices or are in doubt by seeking the advice of colleagues and managers.

Wise choices are also based on the principle of equality. Identical matters shall be treated equally and we shall treat all people with the same basic respect.

Desired behaviourWise choicesEthical guidelines

Veidekke HouseLaws andregulations

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1) Openness, dialogue and notification

We want a culture of openness and safety at Veidekke. Employees are encouraged to voice their opinions, and we shall provide and receive feedback in a constructive and respectful way. We shall all be able to bring up matters we are unsure about or feel are unacceptable.

Veidekke has a notification procedure that is in accordance with the provisions of the Norwegian Working Environment Act.

2) Occupational health and safety (OHS)

As Veidekke employees, we shall work in such a way as to prevent personal injuries, with our goal being an extended number of good working years for everyone. We shall not act in such a way as to put ourselves or others at risk, and we shall make it known if we see behaviour that contra-dicts this. We shall treat everyone with whom we come in contact through our work or in work-related activities with courtesy and respect. At Veidekke, we do not tolerate bullying or abuse of authority or position.

Veidekke shall be a drug-free workplace. During business hospitality, travel, attendance at conferences and other work-related occasions where there is access to alcohol, we shall show moderation and act in a way that does not compromise Veidekke’s reputation, and our own or others’ integrity. All use, possession and/or sale of narcotic sub-stances is prohibited.

Veidekke expects its partners to comply with current guidelines. 3) Environment

Veidekke’s ambition is to demonstrate “practical environ-mental excellence”. This requires us to identify and monitor our environmental impact and continuously reduce it. We shall incorporate environmental considerations into the entire lifecycle of a project – from development, planning, design, production and operation to demolition and recy-cling. We shall use technology in a way that best serves the environment. We support a precautionary approach to environmental challenges, which means that we shall strive for clean production, clean products and the use of non-endangered and renewable resources.

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4) Market and competition

Veidekke is keen to contribute to healthy competition and rejects unlawful influencing of markets and all forms of cooperation that are contrary to competition legislation. We shall compete in a professional, honest and ethical way within current legislation. Guidelines are described in Veidekke’s “Master Policy – Honest, legitimate market behaviour – statutory requirements on competition”.

5) Anti-corruption

Veidekke rejects any form of corruption and trading in influence. Corruption undermines competition on pure commercial terms and violates our value base. The giving, soliciting or accepting of an improper advantage in connec-tion with a position, office or assignment at Veidekke (for oneself or others) is illegal and shall not occur.

Legislation is the same for both the private and public sec-tors. However, public bodies and private companies may have stricter guidelines than in legislative provisions.

All business transactions conducted by Veidekke shall be clearly documented in the company’s financial statements and be in accordance with international standards.

6) Undeclared work

Undeclared work undermines important public interests, and Veidekke shall therefore contribute to combating it. All our employees shall help to ensure that undeclared work or social dumping does not occur.

7) Fraud

All our employees shall be honest and fair to Veidekke as an employer and to our customers, suppliers and partners.

Employees are not permitted to enrich themselves at the expense of the employer or to acquire any form of financial advantage or gain from Veidekke, our customers, suppliers or partners through illegal, fraudulent or unethical behav-iour. It is not permitted to abuse one’s position at Veidekke for personal gain.

8) Conflict of interests

All employees shall behave loyally to Veidekke and the company’s interests. As with laws and regulations, Veidekke’s values, procedures, quality systems and internal guidelines provide framework conditions for such behav-iour. No-one shall work on matters or activities where a conflict may arise between the company’s interests and

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personal interests (or a related party’s interests), or where others may perceive such a conflict of interests. If there is doubt, the issue shall always be taken up and clarified with the immediate superior.

9) Business hospitality, customer care, travel and gifts

Our employees may receive and offer hospitality in the form of social gatherings, meals or entertainment when the activity has a clear professional and/or business pur-pose for Veidekke. There shall be transparency in general relationship building, such as business dinners. The cost of such hospitality shall be characterised by moderation.

All travel, accommodation and expenses for employees be-yond what is described above (even if associated with this type of hospitality) shall always be paid by Veidekke. In the event of business hospitality, the individual with the high-est position shall pay. In the same way, partners, suppliers and customers shall always pay for travel, accommodation and other such expenses for their employees.

We shall not accept or give gifts or anything that may affect our own or others’ integrity or decisions, or that may be perceived in that way. Particular vigilance shall be shown in connection with tendering processes.

10) Inside information

No-one shall trade in or advise on trading in Veidekke’s shares on the basis of inside information. See also “Proce-dures regarding inside information in Veidekke ASA”. 11) International agreements

Under a global framework agreement with the Norwegian federation Fellesforbundet, the Norwegian Union of Gen-eral Workers and the International Federation of Building and Wood Workers, Veidekke has committed to work for continuous improvement in the areas of working environ-ment, labour relations (employer – employee) and health and safety standards in the workplace.

Veidekke supports the ILO Declaration on Fundamental Principles and Rights at Work, which include freedom of association, collective bargaining, OHS and measures against discrimination, forced labour and child labour.

Veidekke supports the UN human rights convention, which states, among other things, that no one should be discrim-inated against on grounds of race, gender, sexual orienta-tion, language, religion, political or other opinion or national or social background.

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Våre verdier

Correctbehaviour

Wise choices/seeking advice

Lawsand

regulations

VeidekkeHouse

Ethicalguidelines

Policydocuments

Knowledgeand

training

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Revised Novem

ber 2014