Corporate Social Responsibility Guidelines

 

1 PURPOSE 
Norwegian Energy Company ASA (“Noreco” or the “Company”) is committed to provide unique value creation for all our stakeholders by building an optimized portfolio of exploration, development and production assets. We believe that our integrity and standards are critical to our sustainability and value as a company, and that success is both about achieving the right results and delivering in the right way. The Company pursues opportunities while taking the social impact of our business operations into consideration.
This document contains the basic principles that Noreco will follow with respect to our Corporate Social Responsibilities (“CSR”). 
2 BASIC CORPORATE SOCIAL RESPONSIBILITIES PRINCIPLES
2.1 Respect for Human rights 
Noreco supports the principles set forth in the Universal Declaration of Human Rights. The Company shall ensure that our operations are conducted in accordance with basic human rights standards.
2.2 Contribution to sustainability
Noreco will act as a responsible and supportive member of the local society, and help create value for the society, develop the local industry and community by using local service providers and contractors, and by cooperating with local R&D and academic institutions. 
2.3 Environment
Noreco understands the importance of protecting the environment and strive for environmentally friendly consciousness both from us, our partners, contractors and suppliers.
Noreco will do our utmost to protect the environment by minimizing waste, emissions and other long term negative impact on the environment in all of our activities. 
Noreco also ensures environmental measures through its memberships of The Norwegian Clean Seas Association for Operating Companies (NOFO) and as a KPD-member (Chemical Product Data). 
2.4 Integrity 
Noreco shall maintain high standards of integrity. The Company shall be honest and fair in all dealings. 
2.5 Anti corruption
The Company will not permit or tolerate engagement in extortion, bribery or other forms of corruption.
3 RULES GOVERNING PERSONAL CONDUCT
3.1 Employee health, safety and working environment 
Noreco cares for our employees by taking health, safety and the environment seriously. The Company will safeguard people, our facilities and the environment from harm through continued focus on health, safety and environment in all aspects of our business. 
Noreco will strive towards our HSE vision: zero accidents, zero incidents and zero long term impact to the environment. 
3.2 Diversity
Noreco will not discriminate on the basis of gender, religion, race, national or ethnic origin, cultural background, social group, disability, sexual orientation, marital status, age or political opinion. Harassment and other improper conduct are not tolerated.
3.3 Communication on illegal or unethical conduct
Every employee has the right to, and is encouraged to, report possible illegal or unethical conduct by the Company to someone who is in a position to initiate corrective measures. Circumstances that ought to result in a report is for example breach of law, breach of corporate directives and guidelines, breach of code of conduct, bullying of colleagues, discrimination, harassment, illegal use of substances, poor working environment, corruption, cases of tax evasion, insider trading, economic disloyalty, embezzlement, theft, fraud and other forms of economic crime.
There are several ways to make such notification. In principle all employees can report, orally or in writing, to a line manager, to a designated Board Member, to the Personnel Manager, the Human Resources Director, or to the employee representative. 
4 ROLES AND RESPONSIBILITIES
The Board of Directors is responsible for developing ethical and CSR policy, guidelines and procedures, and for monitoring the performance of the CSR policy that govern the Company. 
Each Noreco employee and Board Member is responsible for abiding the core CSR principles as outlined in this document.
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Approved by the board on [14.03.11   ].

PURPOSE
Norwegian Energy Company ASA (“Noreco” or the “company”) believes that our integrity and standards are critical to our sustainability and value as a company, and that success is both about achieving the right results and delivering in the right way. The Company pursues opportunities while taking the social impact of our business operations into consideration.

This document contains the basic principles Noreco follows with respect to our Corporate Social Responsibilities (“CSR”).

Respect for Human rights
Noreco supports the principles set forth in the Universal Declaration of Human Rights. The Company shall ensure that our operations are conducted in accordance with basic human rights standards. No human rights violations are accepted in connection with our operations, and would represent a breach of Noreco’s values, policies and standards. Noreco operates in Norway, Denmark and UK. In these countries, the promotion of human rights and democratic principles is at the heart of domestic and foreign policy. Human rights are strongly regulated in these countries and Noreco complies with national laws and meets and exceeds minimum law requirements.
Safeguarding human rights is the guiding principle, and while practices of association may vary in these countries, in all our operations we endeavour to involve our employees and their appropriate representatives in the development of the company. Noreco has a well functioning Work Environment Committee with representatives from both office locations (Norway and Denmark). The committee meets at least once every quarter. To strengthen our commitment towards the company values, Noreco reviewed and renewed our values in 2014 through an initiative involving the active participation of all employees. No breaches of human rights have occurred in Noreco.

Discrimination
Noreco ensures that we act as a responsible employer and endeavour to create a strong, trust-based relationship between our people, their representatives and management. Noreco shows respect for all individuals and makes active efforts to ensure a good working environment characterised by equality and diversity. We do not accept any form of discrimination of employees or others involved in our activities. Discrimination includes all unequal treatment, exclusion or preference on the basis of race, gender, age, disability, sexual orientation, religion, political views, national or ethnic origin, or other similar circumstances that result in the setting aside or compromising of the principle of equality. Noreco does not discriminate, and harassment and other improper conduct are not tolerated. No cases of discrimination have been registered in Noreco in 2014. Noreco’s work environment is closely monitored, and an annual Work Environment Survey is carried out to ensure that this is taken care of. In 2014 the 7th edition of the Work Environment Survey was carried and the results show consistently a good and balanced work environment.

Diversity
Noreco believes in diversity and equality of opportunity. 40 % of our employees are female and there are nine nationalities represented. We care for our people through focus on health, safety and working environment, recognising that our staff and consultants represent the cornerstone of delivering Noreco's vision and strategy.

Corruption
Noreco is against all forms of corruption, including facilitation payments. We believe that ethical conduct is a necessary condition for a sustainable business. The company does not allow or tolerate any form of blackmail, bribery or other forms of corruption. Noreco operates in Norway, Denmark and the UK. In these countries anti-corruption principles and laws are at the heart of domestic policy. Noreco’s values and our expected business practice and personal conduct described in the Management System and employee manual serve as guidelines and standards of expected behavior. Through the Induction process all employees get acquainted with the Employee Manual where such guidelines are clearly stated. Topics covered include the non-acceptance of obtaining advantages, bribes, gifts or favors among other corruption topics.
Reference is also made to the Norwegian, Danish and UK Penalty Code regarding corruption and influential trading.

Communication on illegal or unethical conduct
Every employee has the right to, and is encouraged to, report possible illegal or unethical conduct by the Company to someone who is in a position to initiate corrective measures. Circumstances that ought to result in a report is for example breach of law, breach of corporate directives and guidelines, breach of code of conduct, bullying of colleagues, discrimination, harassment, illegal use of substances, poor working environment, corruption, cases of tax evasion, insider trading, economic disloyalty, embezzlement, theft, fraud and other forms of economic crime.
Concerns relating to our activities can be raised through a variety of channels: At the operational level, the corporate level and through an anonymous whistleblower channel. In principle all employees can report, orally or in writing, to a line manager, to a designated Board Member, to the Human Resources Manager, or to the employee representative. Employees are encouraged to raise issues through line management, the human resources department, and/or employee representatives. No issues of this kind have occurred in 2014.

Integrity
Noreco maintains high standards of integrity. The company shall be honest and fair in all dealings.

Contribution to sustainability
Noreco acts as a responsible and supportive member of the local society, helping create value for the society, developing the local industry and community by using local service providers and contractors, and by cooperating with local R&D and academic institutions.

Environment
Noreco follows regulations and guidelines regarding protecting the environment. We understand the importance of protecting the environment and strive for environmentally friendly consciousness both from us, our partners, contractors and suppliers. The top document in our Management System describes our vision, strategy, guidelines and values. This document contains guidelines for how to take care of health, environment and safety (HSE) in our daily operations, as well as how we work towards our HSE vision of zero accidents, zero incidents and zero impact on the environment. In addition, we have established an environmental handbook that describes demands for environmental aspects and environmental impact related to our activities, and which states our social corporate responsibility and involvement to protect nature. The environmental handbook serves as a guiding document to give an overview of Noreco’s systems and processes related to environmental control. One of Noreco’s most important focus areas is environmental understanding and implementation of this in projects and for running the business.

Emergency preparedness
Noreco plans all its projects in such a way that we reduce risk as far as practically possible. All activities involve a certain risk for dangerous incidents or accidents to occur. Noreco has an efficient emergency preparedness organisation in place to handle unwanted incidents, and emphasises the development of this. Noreco is a member of Norwegian Clean Seas Association for Operating Companies (NOFO). The purpose is to manage and maintain a spill response that includes personnel, equipment and vessels. NOFO manages over extensive oil spill response resources to reduce environmental damage by an oil spill from the petroleum industry. In addition Noreco is a member of the Operators union for emergency preparedness (OFFB). OFFB’s task is to administrate and maintain a second line of preparedness on behalf of the member organisations. OFFB is an integrated part of the members’ emergency preparedness organisations. Through practicing, courses and systematic transfer of experience between members, OFFB contribute to building the emergency preparedness competencies at each member company. We did not experience any serious incidents in 2014, and the emergency preparedness organisation was not mobilised.

Environmental mapping
As part of preparations for drilling explorations Noreco performs environmental mapping. Environmental mapping is performed to identify environmental sensitivities in the area for the drilling operation. The environmental mapping is being performed before environmental risk evaluations, oil simulations, emergency preparedness analysis and other government applications are prepared. The environmental mapping report further describes the expected presence of natural, sensitive resources and climate considerations attached to the geographical area and the planned drilling period. The results are being used in the planned drilling operation.

Mapping the seabed
Noreco performs seabed surveys before drilling of exploration wells. These surveys are performed to identify potentially vulnerable species listed on the Norwegian red list for endangered species. In the Norwegian Sea, corals and sponges vulnerable to sediments from drilling operations grow. Noreco therefore emphasises mapping such resources before drilling so that the drilling location, anchoring and handling of sediments leads to minimal damage.

Clean air
Noreco will do its utmost to avoid damaging the environment through energy efficiency and reduction of air emissions. Air emissions from our operated activities are today limited to the burning of diesel for power generation on the drilling rigs, and occasional flaring of gas. Noreco is a member of the industry NOx fund. The main purpose of the environmental agreement and the industry NOx fund is reduction of NOx emissions. The fund is a joint league of businesses who can apply for support for emission reducing measures.

Clean water
Noreco shall avoid damage to the environment by reducing the use of chemicals or health damaging chemicals. Noreco performs environmental assessments of chemicals based on information given in the Harmonised Offshore Chemical Notification Format (HOCNF).
Noreco was in compliance with the discharge application for the latest exploration well.

Waste management

Noreco shall work to reduce waste, recycle and reuse, and a safe handling of this. In all drilling projects, a waste management plan is prepared and implemented on the drilling rig drilling the well. The plan describes waste management offshore and transportation of waste to shore. The purpose of the plan is to secure a reduction in the amount of waste, reduction of harmful substances, and increased recycling. This plan shall ensure that waste management is in line with internal requirements and external regulations.

Employee health, safety and working environment
Noreco cares for employees by taking health, safety and the environment seriously. The Company safeguards people, our facilities and the environment from harm through continued focus on health, safety and environment in all aspects of our business.
Noreco strives towards our HSE vision: Zero accidents, zero incidents and zero long term impact to the environment.

ROLES AND RESPONSIBILITIES
The Board of Directors is responsible for developing ethical and CSR policy, guidelines and procedures, and for monitoring the performance of the CSR policy that govern the Company.
Each Noreco employee and Board Member is responsible for abiding the core CSR principles as outlined in this document.

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Approved by the Board of Directors on 30 April 2015.