CORPORATE SOCIAL RESPONSIBILITY POLICIES

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1 CORPORATE SOCIAL RESPONSIBILITY POLICIES

2 csr 1. TAKING OVERALL RESPONSIBILITY Taking overall responsibility is an important core value at Data Respons. The group aspires to be a responsible corporation in terms of labour standards, human rights and environmental protection. Furthermore, Data Respons encourages all stakeholders to follow the same policies and expect them to follow international conventions, such as human rights, as well as local legislations. This document outlines the group s Corporate Social Responsibility policies, and shall be a guideline for the employees as well as a directive for how Data Respons shall conduct its business. Data Respons Corporate Social Responsibility Policies are in accordance with the UN Global Compact Principles. These Corporate Social Responsibility policies have been approved by the board of Data Respons ASA and are publicly available on the company s web page Employees are informed through and the group s internal web.

3 2.GOVERNANCE AND INTEGRITY MANAGEMENT 2.1 PROFESSIONAL SECRECY Employees have an obligation of professional secrecy regarding all business matters and other situations that could give outsiders access to confidential information. Basically, all business matters not made public are to be considered confidential. Caution should be exercised when discussing the group s internal affairs in front of outsiders. The same applies to discussions and distribution via open and/or external Internet-based media and any other electronic media. 2.2 TREATMENT OF INFORMATION As a listed company, Data Respons is subject to stringent regulations regarding information that could affect the share price. No employees or elected officers with precise and confidential inside information can give advice or trade, themselves or through close associates, in securities issued by Data Respons. Inside information is defined as information which has not been made public and is not commonly known and is likely to have a significant effect on the price of the securities. This also applies to information that for different reasons is not made public by the company. The responsibility for assessing whether one possesses inside information lies with the individual, regardless of the trust in the company s ability to fulfil its information obligations to the stock exchange. Data Respons has implemented an Insider Trading Policy. Further reference is made to the Securities Trading Act and Oslo Stock Exchange. 2.3 CUSTOMERS Data Respons is a customer oriented company and all customers shall be treated with respect and integrity. We will fulfil our customers needs in the best possible manner within the commercial and ethical framework that applies to Data Respons. 2.4 SUPPLIERS Suppliers shall be treated impartially and fairly. An integral part of Data Respons strategy is to be independent from suppliers and to always choose solutions best suited for our customers. 2.5 CONFLICT OF INTEREST All employees are expected to be loyal to the group and the group s interests. Employees shall not, directly or indirectly, participate in any activity that is inconsistent with or opposed to Data Respons best in- terests, or that gives the appearance of impropriety or divided loyalty. Each individual is asked to exercise good judgment and contact their immediate superior if a potential conflict of interest arises. 2.6 RELATIONSHIPS BETWEEN EMPLOYEES Data Respons shall respect the personal life of the employees. If however, two employees enter into a relationship, and one party has a supervisory function for the other, or if other circumstances entail that the relationship could affect their work or create a potential conflict of interest; the relationship shall be brought to the attention of an immediate superior. In such situations the company shall seek to find the best possible solutions for the involved parties. 2.7 CORRUPTION Data Respons has a zero tolerance policy for all forms of corruption. Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted. 2.8 UNLAWFUL COMMERCIAL PRACTICES All employees at Data Respons shall follow all rules and regulations that apply to the group in addition to the local legislations in the area they operate. 2.9 BUSINESS EXPENSES All employees must follow Data Respons policies and procedures regarding business expenses, such as meals and travel expenses. Employees must submit accurate expense reimbursement forms GIFTS In general, employees may not give or receive gifts or entertainment, to or from current or potential suppliers, customers, or other business associates. Gifts that are classified as insignificant, and therefore not taxable according to local tax authorities, may be given or received provided that the purpose of the gift is not to obtain favourable treatment. Under no circumstances may gifts be given to government officials in any jurisdictions SUBSTANCE USE OR ABUSE Use of alcohol or other drugs at or before work can cause safety issues, damage customer relations and hurt productivity and innovation. All employees are asked to use good judgment and keep in mind that they are expected to perform to their full ability when working for Data Respons. The group discourages any use of illegal drugs.

4 3.HUMAN RIGHTS AND LABOUR STANDARDS 3.1 HUMAN RIGHTS Data Respons support and respect internationally acknowledged human right standards. Any violation or discrimination due to gender, ethnicity, religion or sexual orientation will not be tolerated. Data Respons does not accept any form of forced labour or child labour. Data Respons practices freedom of association and the right to collective bargaining for all employees in the group. 3.2 LABOUR STANDARDS WORKING ENVIRONMENT Data Respons aim to be a stimulating place to work with an inclusive working environment. We shall conduct ourselves with integrity and show respect for colleagues and other people we meet through work WORKING HOURS Data Respons believes that its employees perform best when there is a reasonable balance between work and leisure. Employees are asked to inform their immediate superior if they experience a significant discrepancy between their personal needs and their work situation. Furthermore, Data Respons shall comply with local legislations concerning working hours and overtime WAGES All employees shall be secured a total salary that is fair, competitive, and in accordance with the local industry standard. Equal pay for work of equal value, regardless of gender is emphasised at Data Respons. The remuneration of employment for comparable positions is the same for women and men DISCIPLINARY PRACTICES Data Respons follows the local regulations regarding the working environment in its countries of operations EMPLOYMENT CONTRACTS All employees in Data Respons shall have employment contracts describing their position and tasks, the remuneration, the period of employment (permanent, deputyship or freelancers), and other general terms that may apply. The remuneration is reviewed once a year and other general terms are reviewed if needed. The employment contracts shall be signed by the employee and their superior with authority to sign RECRUITMENT, PROMOTION AND DEVELOPMENT OF STAFF The recruitment, promotion and development of the staff are based on merit and equal opportunity regardless of ethnicity, colour, religion, gender, age, national origin, sexual orientation, marital status and disability DISCRIMINATION AND HARASSMENT Discrimination, bullying or harassment is not accepted at Data Respons. Employees are asked to report incidents of such behaviour to their immediate supervisor, the employee representative or by using the anonymous Whistle-blower function - found on the company intranet. 3.3 HEALTH AND SAFETY Our employees safety is of the utmost importance to us. Health and safety are to be safeguarded in a way that creates a high level of job satisfaction and a healthy working environment. Data Respons will monitor and take precautions to secure its employees health and safety.

5 4.ENVIRONMENTAL PROTECTION Data Respons shall design and deliver solutions to our customers that comply with all relevant environmental legislations, and make sure that products can be recycled or disposed of safely at the end of products life cycle. Data Respons shall select transportation of goods and people, which contribute to reduced pollution and CO2 emissions. This includes extensive use of new communication technology such as video conferencing to reduce unnecessary business travel. Data Respons shall embrace technology that address and solve environmental challenges. Data Respons shall continuously improve its processes in order to prevent pollution. 5.REPORTING OF VIOLATIONS All employees at Data Respons are obliged to report any detected violation of the Data Respons Corporate Social Responsibility Policies. The employees could report directly to either their immediate supervisor, the employee representative or by using the Whistle-blower. The Whistle-blower is a completely anonymous reporting system defined for this purpose and is found on the company intranet.

6 A SMARTER SOLUTION STARTS FROM INSIDE

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