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Code of Conduct for Topaz

PURPOSE

  • Topaz will be operated in accordance with the owners’ goals and objectives with its ownership.
  • Topaz is dependent on serious, responsible and long-term owners and employees.
  • Topaz’ reputation in the community is essential to meet the firm’s purposes.

These guidelines are meant to clarify Topaz’ ethical platform. The aim is to encourage a corporate culture and behaviour of the individual who reflects the values ​​that are the basis for Topaz ‘business; to be positive – reliable – targeted – innovative.

The ethical guidelines will ensure that all persons acting on behalf of Topaz, perform their activities in an ethical manner and in accordance with the standards that Topaz sets. In addition, it should be made good judgment, prudence and thoughtfulness in actions on behalf of Topaz.

SCOPE

The guidelines apply to all persons acting on behalf of Topaz, including temporary employees. If in doubt about whether a particular activity is lawful or ethically acceptable, it must first – far as practicable – be consulted with the general manager.

RESPONSIBILITY

Topaz ‘ ethical guidelines are approved by the Board. The Board is responsible for the preparation and maintenance, as well as the implementation and compliance with the ethical guidelines.

Employees are expected to act according to the guidelines, content and values. It is expected that a breach of the ethical guidelines is notified. Violation of these guidelines will not be tolerated and may in accordance with relevant laws, regulations and working rules lead to disciplinary action, termination, dismissal and / or prosecution.

PROCEDURES FOR NOTIFICATION OF ETHICAL ISSUES

Topaz would actively encourage responsible ethical conduct in an improvement oriented and unbureaucratic way.

Whoever in good faith aimed at overriding or staff functions in connection with ethical issues, will be protected from sanctions by Topaz as a result of this inquiry. It will be perceived as a violation of these ethical guidelines, to discriminate or harass anyone for having raised ethical relationship with a superior or staff functions.

WORKING ENVIRONMENT, EQUAL OPPORTUNITIES AND PERSONAL CONDUCT

The working environment should be characterized by equality, openness and tolerance. Behaviour must be based on respect for human dignity. Other cultures and customs must be respected.

Topaz does not accept any form of harassment, bullying or discrimination based on gender, religion, national or ethnic origin, cultural background, social group, disability, sexual orientation, marital status, age or political opinion. Topaz shall be characterized by equal opportunity and fair treatment.

Topaz shall be a drug-free workplace. Limited amounts of alcohol may be served in connection with event and representation. This assumes that is not consumed while operating machinery, driving or other potentially hazardous conditions.

The use of tobacco shall not occur in Topaz its premises.

Use of Topaz’ brand/logos shall be practiced with caution because of its reputation.

CONFLICTS OF INTEREST, INTEGRITY AND IMPARTIALITY

It should not seek to obtain advantages for themselves or others that are inappropriate, or in a way that can damage Topaz’ reputation and interests. It shall be exercised good judgment, prudence, dedication and honesty in action on behalf of Topaz.

Bribes, gifts, benefits and corruption

There should never be offered any illegal or inappropriate monetary gifts or other improper advantage to any person, including public employees or our customers and suppliers, to achieve commercial beneficiary. This applies regardless of whether the advantage is offered directly or through a representative. Gifts or other benefits to business must comply with local business practices and recipient provisions. The value of the gift should be of limited value and administered with limited frequency.

Gifts, paid trips or other benefits from business partners may not be of such a magnitude or frequency that it may create doubts about the integrity and independence of the recipient – as long as being an employee at Topaz.

Attention and representation

General forms of hospitality and socializing belong to a polite business place. The extent of such care must not be developed so that it affects the decision-making process or could provide reason to believe that it does. Frequency and degree of attention should be proportionate to the business scope.

Impartiality

If personal interests may affect the decision on a matter where that person is responsible for, or others may consider this as likely, the matter shall be submitted to the manager. This person should inform its superiors about the real and possible disqualification, such as interests, family relationships, close friendship, business deals and relationships, then declare itself disqualified.

Employees or directors must avoid having personal interests – directly or indirectly in other businesses – if this impairs or is perceived to affect their loyalty to Topaz.

Travel and accommodation

Travel and accommodation expenses related to the employment relationship shall be borne by the company. Exceptions to this principle can only be made after the approval of superiors.

Political contributions

Topaz as company, employees or directors shall not provide financial contributions to political parties on behalf of the company. This does not prevent Topaz from supporting political views that promote Topaz its interests.

Confidential information

Confidential information received in connection with the employment relationship, must be respected and not used for personal gain or to unwanted knowledge. Information relating to prices, products, solutions and other issues of importance to the business, shall not be granted without comprehending.

Information, intellectual property and innovative ideas are valuable for Topaz. Such intangible assets must be addressed in an appropriate manner by employees and directors. Confidential information requires extensive care and caution in relation to internal and external stakeholders.

Inside trading

No one should  act with corporate securities on the basis of non-public information as when having access through their work or assignments on behalf of Topaz. This includes counseling related to such trading.

ANIMAL WELFARE

Topaz has through its activities a special responsibility for animal welfare. Concern for animal welfare should be given high priority. It attaches special focus on animal welfare through animal mortality. Animals have an intrinsic value, and handling of animals shall be made with care and respect for its characteristics. Applicable rules within animal welfare should be followed.

Hunting and killing shall happen in best humane way, when the animal does not  gets unnecessarily stressed. Topaz is concerned that most of the animal as possible will be used for processing of food or products that create good and sustainable jobs locally in the Arctic, Greenland and Canada’s east coast.

Seal hunting

Topaz support seal hunting in the Arctic, along the Labrador Sea, Greenland and eastern Barents Sea. The seals live free in their natural environment until they are hunted and harvested as surplus of natural resources. It is important to have a resource utilization of seal population in these areas, so that indigenous people can gain income without being dependent on support from the greater society and in order to continue its settlement in the northern areas.

The seal will still be hunted to keep the population down and away from parts of the coast of Europe. The animals are then not exploited for food or processed in other ways, but will instead be destroyed and discarded as waste. Therefore it is important for Topaz to use the raw substances that the seals give and to provide jobs and self-sufficiency of food in the Arctic.

Human rights

Topaz sees it as a human right that those who live in the Arctic north areas will utilize seals as food and raw materials, in order to be self-sufficient and be able to deliver their goods or products to the world’s market on an equal level as other suppliers of leather, food and cooking oil. This has to be without any interference, discrimination or restriction of the great society, like the EU.

Topaz’ guidelines for all the handling of animals shall be in accordance with official requirements, laws and regulations. Anyone who handles animals must have proper training and knowledge.

ENVIRONMENT

Topaz aims to carry out its operations without harming people or the environment, and with no loss of material assets. Reduction of emissions and protection of the internal and external environment must at least be in line with the demands of society and assumptions. Topaz will be characterized by continuous efforts to improve health, safety and environment in its surroundings and in connection with our deliveries.

PRODUCTS AND CONSUMER INFORMATION

All products must be acquired, produced and handled in accordance with the agreed quality standards at Topaz. It shall be transparency in relation to any deviation on defined product characteristics, manufacturing processes, storage and transport. No product shall be labeled or declared in a false or misleading manner.

It should not run marketing for brands or products that in some contexts play on people’s lack of knowledge, handicap or lack of judgment.

Topaz requires that its suppliers proof that they do not use child labor or are engaged in other unacceptable exploitation of labor in the manufacture of products delivered.

ECONOMIC SITUATION AND TRANSACTIONS

Topaz will provide full, fair, accurate and understandable disclosure in its financial reports, other documents submitted to the government, and in all other public communications. All accounts must be kept and presented in accordance with applicable laws, regulations and practices.

All activities involving financial implications shall be properly documented. Transaction shall not be intentionally misclassified, whether in terms of accounting, departments or accounting periods.

The accounts shall give a correct expression of Topaz’ assets, liabilities, income and expenses.

COMMUNICATION

Topaz adds in its communication the basis: being attentive, open, honest and trustworthy.

The Board of Topaz Arctic Shoes AS has approved these ethical guidelines (Code of Conduct).