NTM Code of Conduct

NTM is a well-known brand in the transport industry, associated with high-quality and in-demand products. It has been built since the founding of the company in 1950, and it is the responsibility of all of us to refine and develop it, so that we can create an even stronger company in the future.
The Code of Conduct is a tool that will help all of us within the company to determine what is right and guide us to act correctly, on both legal and ethical issues. How we, as individuals act in the company is what defines us and how the outside world perceives us as a company.
Ab Närpes Trä & Metall - Oy Närpiön Puu ja Metalli ("NTM") complies with all legal regulations governing our operations. In addition, we apply our Code of Conduct even when our internal rules are stricter than applicable legal requirements.

 
I THE EMPLOYEES

1.         Fair and respectful treatment
The NTM provides a high standard working environment that supports and encourages the development of both the individual employee and the entire work community. We will encourage and expect mutual respect both among employees and between our company and business partners.
NTM complies with applicable human rights legislation and conventions as well as relevant ILO standards regarding our workers, and expects the same from companies in our supply chain and other partners.
If there has been a violation of human rights within the NTM's activities, we will remedy the violation and ensure that it does not recur.
2.         Non-discrimination
NTM values diversity among its employees. NTM respects all individuals and believes that an inclusive and diverse workplace delivers the best service for our clients. NTM expects all employees to comply with applicable laws regarding discrimination.The NTM treats everyone equally and gives everyone the same opportunities regardless of distinctive features that have legal protection. The principle of equal treatment covers all aspects of the employment relationship. We do not tolerate any form of disrespectful conduct, discrimination or bullying. We reject all such behaviour and will take action if such doings are detected in the workplace.

3.         Child labour and modern slavery
We reject all forms of illegal or abusive child labour and modern forms of slave labour such as forced labour, debt bondage and human trafficking in our workplaces and supply chain
NTM respects children's right to personal development and education. A child in this context means a child under the age of 15 or a higher statutory minimum age according to local law. We recognize and take into account the special needs of employees under the age of 18.

4.         Safe and healthy work environment
NTM cares about its employees and the people who are affected by our activities. We build and develop a working environment that promotes health, safety and well-being. We invest in personal safety, accident prevention and other preventive measures in our workplace. A safe and healthy working environment is a prerequisite for our employees to perform their work to the best of their ability.
NTM ensures that our working environment complies with applicable health and safety laws and requirements.

5.         Working time, remuneration and travel
We comply with applicable legislation, collective agreements, relevant ILO conventions and other regulations regarding working hours, rest, travel, compensation and benefits.

6.         Freedom of association
NTM fully respects the right of all employees to join a trade union in order to defend their interests as employees. We also respect everyone's right to opt out of joining a trade union.
We promote our relations with social partners, trade unions and other employee representatives.
 
II THE COMPANY
 
7.         Environmental issues
NTM's activities require an environmental permit, which means that we work on the basis of established environmental objectives with an annually updated environmental report.
NTM's goal is to protect the environment and contribute to a more sustainable world. Maintaining and promoting environmental issues is a shared responsibility of NTM, our employees and our customers. We are actively working to reduce energy use and limit pollutant emissions. We also consider the environmental impact of our supply chains.
NTM also takes environmental risks and opportunities into account in the tender process. We work to reduce the environmental impact of our operations, products and services throughout their life cycle.
8.         Compliance with product requirements
NTM's products are designed, produced, marketed and sold to meet the applicable legal requirements of the respective market and the applicable quality and safety standards. Legal requirements always take precedence over customer requirements. Compliance with these is crucial to building confidence in NTM products in the marketplace.
Meeting quality and safety standards also maintains a good quality of our products and enables good service to our customers.
9.         Healthy competition
We believe in our products and our business and are convinced that a competitive and fair market is best for NTM. We compete on the basis of the merits of our products and services, and do not engage in any activity that violates applicable competition laws. Our suppliers are chosen on a professional level and are selected according to objective criteria.
We believe that competition on equal terms contributes to greater efficiency and the functioning of the market economy.
10.       Hospitality and gifts, anti-corruption
NTM neither participates in nor supports any form of corrupt activity such as kickbacks, bribes, lavish gifts and representation either directly, or indirectly, e.g. through a third party. We also do not accept suppliers or partners who offer bribes in various forms and we will take the necessary measures to ensure that such behaviour is detected.
NTM complies with applicable laws and the company's internal hospitality policy. Accordingly, the representation or gift must serve a valid business purpose and be of limited value.
We make decisions and manage potential conflicts of interest objectively and without regard to personal gain.
NTM does not participate in or support any form of money laundering. In cases of suspected money laundering, we will notify the relevant authorities in accordance with applicable law.
11.       Business principles and accounting
NTM strives for positive, sustainable and long-term business relationships with organizations that share our values. We maintain high quality in our work and focus on continuous improvement.
All financial transactions must be recorded in accordance with applicable laws, regulations and standards. The accounting shall be accurate and not misleading. Our financial reporting shall reflect actual transactions.
12.       Our assets
Our assets are important to our business. We use our assets responsibly. We protect NTM's assets from damage, theft, loss and misuse. We do not use our computers and digital communication systems for inappropriate communications.
 
III CONFIDENTIALITY AND IT POLICY
 
13.       Confidentiality
NTM and its employees adequately respect and manage confidential information relating to NTM's operations and our stakeholders. NTM ensures that confidential information is not made available to persons who do not need or are entitled to this information in their work.
We never request confidential information from previous employers when hiring new employees.
14.       Data security and protection
NTM processes information, personal data and confidential information in accordance with applicable laws and regulations, such as the GDPR. We respect the rights of our employees and stakeholders to the protection of personal data.
NTM's IT systems must never be used for any illegal or unethical activity, such as the distribution, downloading and viewing of illegal, offensive or otherwise inappropriate material.
Our aim is to continuously develop and improve the security of our operations.
15.       Social media
NTM and its employees use social media responsibly, in accordance with the law and ethical standards. We do not use social media to share confidential information, and we do not tolerate harassment, discrimination or retaliation on social media. Social media conversations and postings should be respectful and professional.
 
III THE WHISTLEBLOWER DIRECTIVE AND THE REPORTING CHANNEL
 
The NTM has set up a reporting channel in accordance with existing whistleblowing legislation on infringements of Union law in certain specific areas. Suspected breaches of the Code of Conduct can also be reported through the reporting channel.
The NTM has developed separate whistleblower guidelines on the scope of the reporting channel, how an employee should report suspected violations, and the handling and follow-up of the report, including the notifier´s right to anonymity and protection against retaliation.
 
IV REPORTING BREACHES
 
As an NTM employee, you have a duty to report any breaches of the Code of Conduct that you know or suspect. Reporting can be done to your immediate supervisor or other responsible person within the company. You may also choose to report through the company´s reporting channel. The notifier´s right to anonymity, the processing and follow-up of the report, the notifier´s right to protection against retaliation and otherwise, will be governed by the company´s whistleblower guidelines.
 
Ab Närpes Trä & Metall 17 November 2021
 
Kurt-Erik Nordin, CEO