A comprehensive program to formulate and implement the
values that are to hallmark NCC's operations has been under way in recent years. These values have been translated into norms and rules governing how NCC employees are to behave in various situations. They were summarized in "NCC's Guidelines on Business Ethics - our Code of Conduct" - a document that was adopted by Group Management in 2003 and was revised in 2006 under the name Code of Conduct. The Code of Conduct describes the requirements that NCC - the Board of Directors, management and all employees - have to meet in terms of behavior and conduct and that NCC in turn expects its business partners to respect.
Every manager has an obligation, within his or her area of responsibility, to ensure that employees and business partners are informed about the contents of the Code of Conduct and urge to observe them. Managers within NCC must always set a good example. Adherence to the Code of Conduct is followed up continuously as a natural part of ongoing operations.
Repeated and serious violation of the Code of Conduct results in corrective action. If any of NCC's business partners repeatedly and seriously violates NCC's Code of Conduct, cooperation is discontinued. The Compliance Program, consisting of a comprehensive training program in business ethics and competition law, was introduced in 2002. The program is now an integral part of NCC's ordinary training of newly appointed managers and has been received by approximately 2,000 managers within the Group since 2002. The program is a specified part of the employment relationship.