Introduction

Simrad Optronics believes that its aim of creating competitive returns for its shareholders in the long run is best accomplished by having high standards in business ethics and integrity

Corporate governance comprises a framework of guidelines and management principles. It also relates to the company's ethical guidelines.

The aim of these guidelines is not to impose but to enable individual ethical judgements and decisions through shared values and principles.

The intention is to be as clear and direct as possible in terms of difficult issues the individual may face in his or her work

However, the guidelines do not attempt to resolve choices for the individual, or to allocate greater priority to one particular principle. Instead, they offer a framework within which the conscientious person should be able to work comfortably

These ethical guidelines apply to the organisation and to its individual employees, board members, hired personnel, consultants, intermediaries, and others who act on Simrad Optronics Group's behalf. They also apply to all divisions and subsidiaries of Simrad Optronics ASA. Further specifications to the guidelines will be made by subsidiaries to adapt to local needs and legislation.

Simrad Optronics ASA gives the largest possible scope of application to the present Common Industry Standards. In particular, we disseminate these Standards internally and within our subsidiary companies and controlled entities as well as with our agents and consultants. We encourage our agents, consultants and business partners to adopt and comply with integrity standards consistent with the Common Industry Standards.

1.  Corporate Social Responsibility

1.1. Considering the interests of society by taking responsibility for the impact of its activities on customers, suppliers, employees, shareholders, communities and the environment in all aspects of its operations.

2. Ethics of Accounting Information

2.1. Correct information, accounting and reporting

2.1.1. Simrad Optronics ASA's business information is communicated accurately and fully, both internally and externally. All accounting information must be correct and registered according to laws and regulations.

2.1.2. Simrad Optronics ASA is obligated to provide full, fair and accurate information in its financial reports.

2.1.3. Simrad Optronics ASA has a transparent and traceable financial system which provides information about the origin of all financial transactions and the persons involved.

2.2. Corruption Combat

2.2.1.Simrad Optronics ASA has systems and routines that help avoiding opportunities that aspire to fraud, corruption, nepotism etc...

2.2.2.Simrad Optronics ASA prohibits bribery in all its forms such as cash, objects, credits, discounts, privileges, travel, accommodation or services. This prohibition applies both to the party giving or offering and to the party receiving or requesting such advantage.

2.2.3.Simrad Optronics ASA shall not authorise any gift or payment for public officials or others, except what is outlined in chapter 3.3.

2.2.4.It is the policy of Simrad Optronics ASA that Simrad Optronics ASA, its subsidiary and controlled entities, its and their directors, officers and employees and others acting on its or their behalf shall neither offer promise nor give, nor seek, corruptly any benefit of any sort whatever, whether directly or indirectly, in connection with the performance of the business of Simrad Optronics ASA.

3. Ethics of Personal conduct

3.1. Discretion & Confidentiality

3.1.1. Unauthorised persons shall be prevented from gaining access to internal information that may harm Simrad Optronics ASA's business or reputation. The individuals, who have access to such information, must comply with the requirements for confidential treatment.

3.1.2. Information classified as "confidential" must not be disclosed to unauthorised personnel. This also applies to sensitive information concerning security, individuals, commercial, or technical matters and to information protected by law. The duty of confidentiality continues to apply after termination of the employment relationship.

3.2. Insider Information

3.2.1.Insider information is information that can affect the price of securities and which is not publicly available or generally known to the market. No individual may use, or contribute to others using, insider information about Simrad Optronics ASA to subscribe for or trade in securities.

3.2.2. Employees shall not use confidential information obtained in the course of their employment for the purpose of advancing any private interest or for other personal gains.

3.3. Gifts, Hospitality and Expenses

3.3.1. The individual must not accept gifts except for promotional items of minimal value (normally bearing a company logo).

3.3.2. Under no circumstances, must the giving or receiving be done with a view to anyone obtaining any form of improper advantage.

3.3.3. Hospitality such as social events, meals or entertainment may be accepted if there is a clear business reason and with the condition of keeping the cost within reasonable limits, taking into consideration the local customs and traditions.

3.3.4. The laws or customs of other countries in which we operate may be less clear than ours. It is our policy to comply with those laws or customs; however, if a local law or custom seems to contradict the principles described in this Code, contact a General Manager or our Chief Financial Officer for guidance.

3.3.5. Alcohol consumption is an issue that all employees must be alert to during business events.

The above principles in chapter 3.3 also apply in the reverse direction, so that no individual acting on behalf of Simrad Optronics ASA may offer or agree to pay for gifts, hospitality or other expenses that violate these principles. Particular care must be taken in dealings with public officials

3.4. Conflicts of interest

3.4.1.The individual must behave impartially in all business dealings and not give other companies, organisations or individuals improper advantages.

3.4.2.The company shall have an open attitude towards conflicts of interest. Employees should report any possible conflict of interest in their work.

3.4.3.The following examples are intended to illustrate the possible nature of conflicts of interest:

3.4.3.1. Ownership interest in groups with which we do business, such as customers and suppliers.

3.4.3.2. Buying, selling or leasing property from or to our company.

3.4.3.3.Acceptance of payments, services or loans from, or providing consulting services to, persons or concerns dealing with our company.

3.4.3.4. Any activities or interests such as the above performed by members of the immediate family of an employee are also considered as conflicts of interest.

3.5. Whistle Blowing
The company has a system that allows employees to report any unethical behaviour. All reports will be kept confidential and protection will be provided to the informer so there will be no risk to notify in good faith.

4. Ethics of Human Resource Management

4.1. HR management controls the employer-employee relationship, such as the rights and duties of each. 

4.2.  Simrad Optronics ASA shall not allow discrimination on the bases of age, gender, race, religion or disabilities.

4.3. HR management should also control the fairness of the employment    contract and the balance of power between employer and employee.

4.4. Sexual harassment is against the law and also violates company policy. In order to maintain a pleasant and comfortable working environment, we strongly encourage employees to report immediately any act of sexual harassment

5. Managerial Responsibility

5.1. Our leaders are role models for our employees and through their behavior, they execute the ethical standards of the company. Their relations to others inside and outside the company shall be based on our aims in ethical standards.

5.2. Our leadership principles are based on: Initiative, visibility, decision making, handling changes, openness, loyalty, care and trust towards our employees.

6. Political donations and contributions

6.1. Simrad Optronics ASA permits the making of donations and contributions to political parties, party officials, party representatives or candidates but only to the extent permitted by and in accordance with applicable law. Simrad Optronics ASA will ensure that all such donations and contributions are duly and properly recorded in its books and accounts.

7. Agents, consultants or intermediaries

7.1. Simrad Optronics ASA pays attention to the integrity profile of potential agents, consultants or intermediaries, before concluding any agreement or dealing in any way with candidates.

7.2. Simrad Optronics ASA's agents, consultants and intermediaries are aware of the integrity policies of the Company, the legal provisions containing the incrimination of bribery of foreign public officials pursuant to the 1997 OECD Convention and UNCAC and the present Common Industry Standards.

 8.Integrity programmes

8.1. Simrad Optronics ASA attaches great importance to due and proper compliance with its integrity standards and is committed to ensuring that mechanisms are in place to assist all employees in such compliance. Accordingly, Simrad Optronics ASA has designated the CEO, CFO & HR Manager with ultimate responsibility for the company's anti-corruption programme.

8.2.  The CEO, CFO & HR Manager have been appointed to take day to day responsibility for managing these issues. This will include:

8.2.1. Arranging appropriate training for employees and where necessary third parties involved in our business dealings;

8.2.2. Establishing a process by which employees can seek advice and guidance concerning these issues and if necessary report issues of concern.

9. Sanctions

9.1. Simrad Optronics ASA regards any failure to comply with the company's integrity standards as a serious issue which may cause substantial damage to its business interests and reputation. Accordingly, breaches of the company's published standards will be dealt with as a serious disciplinary matter.