Code of Conduct
M Vest Water's business practice: Our ability to create sustainable value in the long term, fully depends on our ability to apply high ethical standards in all that we do. This is the basis for a trust-based and binding relationship with the community, our owners, employees, partners, customers and suppliers.
Letter from CEO
At M Vest Water, our business requires trust from our customers, authorities, shareholders and society at large. To gain confidence, we are dependent on a corporate culture with deeply ingrained ethical principles. Our Code of Conduct was written with this goal in mind, to act both as a set of internal guidelines and an external statement of our corporate values and commitments.
The Code of Conduct is mandatory reading for all M Vest Water employees and those acting on our behalf. I ask you to familiarize yourself with and abide by the rules and behaviors set out in the Code of Conduct. I also ask that when interacting with customers and business partners, you actively promote our values and ethics. We all have a responsibility to act as ambassadors for our shared values by firmly rooting our conduct and decisions in the ideals of sustainability, openness and respect.
If you should experience any misconduct or violations of our applicable laws and regulations, you are obligated to report the matter. Do not keep silent. M Vest Water has routines that safeguard your security and rights in case breaches are reported. If you have any questions or if you have witnessed a potential violation of the Code, please contact your manager or report it to our whistleblowing email: firstname.lastname@example.org
Stein Edvard Giljarhus, CEO
The Code of Conduct is the foundation of our corporate culture and sets out high standards of integrity on how we do business. All MVW employees, board members, consultants and others acting on behalf of the company are expected to act in accordance with our company values. Suppliers, subcontractors and other contracting parties of MVW are also expected to adhere to standards which are consistent with applicable laws and our “Code”.
The Code of Conduct is approved by the Board of directors of MVW. It is the responsibility of the board and the CEO to ensure that the Code of Conduct is implemented and complied with. Managers at all levels have a particular responsibility to ensure that employees and other relevant parties are informed of the Code of Conduct as well as internal policies and guidelines. In addition, activities in their areas of responsibility are carried out in accordance with the preceding and applicable laws.
The individual employee or other relevant parties are responsible for familiarizing themself with and following the applicable laws. The responsibilities are presented below the relevant ethical practice as “personal conduct”. Everyone is encouraged to consult with other colleagues or managers if concerns or dilemmas regarding compliance with the Code arises. Everyone is also required to report any evidence of violations of this Code or applicable laws that you identify. Violation of the Code of Conduct may lead to internal disciplinary actions, dismissal, or even criminal prosecution. Never hesitate to report the matter to our whistleblowing email: email@example.com.
The “Code” has been divided in three parts according to the ESG framework; Environment, Social and Government.
Environment,“E” is the foundation of MVW. The markets are increasingly requesting green and environmentally friendly solutions to their challenges. MVW contributes with a technology that provides cleaner discharge water, reuse of water, and transport of large volumes of wastewater or sludges to treatment plants. Unlike conventional methods, the process is done using environmentally friendly additives, reducing micro- and nano pollutants such as plastic in the water to undetectable levels at a considerably lower cost. With that said, our company is proud to offer products and technologies that support several of UN’s Sustainable Development Goals (SDGs). A more detailed description of MVW`s wastewater treatment technology can be found in the section detailing the environment and sustainability.
Social,“S” focuses on our people and Social conditions. This includes how MVW manages its relationship with its workforce, the society in which it operates and how it responds to the political environment. More specifically, our view on work environment, community relations, human rights, workplace health, safety, diversity and inclusion. Despite being a less tangible and researched topic than financial and environmental matters, MVW acknowledges social sustainability to be of equal importance to gain long-term success and growth. Intangible assets such a copyrights, patents and R&D are created by people, the core of our business. Consequently, we believe that our people are the most essential contributors towards continued expansion and creating shareholder value.
Government,“G” focuses on our Integrity and business ethics. This entails how our company makes its decisions, how its board of directors is established, operates and remunerated, how MVW manages its risks and deals with the rights of its shareholders. Main topics are MWV`s policies on transparency, reporting, board composition and independence, money laundering, corruption and relationship with suppliers etc. MVW recognize the importance of the “G” in ESG-management. Governance is a key element of overall corporate strategy and performance, and directly affect the way resources, markets and the regulatory legal environment can be used in the pursuit of company objectives.
E - Environment
Environment and sustainability
The United Nations Sustainable Development Goals (SDGs) are 17 goals that all UN Member nations have agreed to achieve by 2030. SDG number 6 “Clean water and sanitation” is about access to, and the quality of, water and sanitation, in addition to the sustainability aspects of how we use water and manage water quality. While access is mainly an issue in developing countries, the sustainability aspects are key for all. There is a significant gap within the goal of accessing clean and healthy drinking water and adequate sanitation, viewed in a global perspective. Water sustainability is an issue in large parts of the world and correlated with unfavorable precipitation patterns and rapid population growth.
SDG 6 is directly related to MVW`s business mission. Our company is founded by a team with deep industry insight and extensive technical experience, with an aim to develop a more efficient and environmentally friendly solution to wastewater treatment.
More specifically, MVW has developed a flocculant-based technology that make discharge waters far cleaner than ever before. A flocculant is a substance (of different polymers) added to polluted waters or sludges that charges (ionizes) water and pollution in the water where sediments/particles coalesce (gather) to larger units (flocs). This allows them to be easily separated from water in a process of floatation, gravitation, or filtration (our Norwapol), purifying the water.
SDG number 13 “Climate action” speaks of urgent action to combat climate change and its impact. The changes in climate are real and a threat to our entire civilization. The effects are already visible and will be catastrophic unless we act immediately and decisively.
MVW is an environmental technology company with a singular and clear-cut mission: to realize a zero-discharge future. Our company offers a new generation of green water treatment products, reducing pollution to zero in a highly cost-effective and efficient way.
MVW has developed unique products and solutions for the water treatment industry, including the industrial as well as the municipal markets. Uniquely, our products are non-toxic and biodegradable and does not harm the environment, obtaining the highest degree of purification in a cost-efficient arrangement.
In contrast to conventional methods, our technology also removes micro and nano pollutants in discharge waters. To our knowledge, no other flocculants can demonstrate this degree of performance. The treated waters have contaminations way below the existing limitations for discharge to nature – in some cases to near undetectable levels – and we are now uniquely positioned to meet the new legislation being prepared by regulatory bodies, like ECHA in Europe.
The existing and comparable treatment chemicals used for treating wastewater today are mainly polyacrylamide and acrylate-based chemicals that produce microplastics as a byproduct. Once in the environment, microplastic do not biodegrade. They accumulate in animals, including fish and shellfish, and are consequently also consumed by humans. The new regulations proposed for Europe prohibit products from containing micro- and/or nano-plastics.
SDG number 14 “Life below water” focuses on conservation and sustainable use of the oceans, seas and marine resources. Consequently, there is a great need for new technology that can replace old and environmentally harmful technology. MVW`s non-toxic and biodegradable technology pass the imminent regulatory change in Europe and support the target of strengthening the resilience of ecosystems below water.
Production efficiency and responsible consumption
SDG number 9 “Industry, innovation and infrastructure” aims to build solid infrastructures, sustainable industry, and promote innovation by taking actions that enable production efficiency and implementing cordial relationships between dominant economies.
MVW has developed and currently offers products and technology that meet future environmental requirements and regulations, using this as a spearhead in the European markets together with solid partners. The value added by this new technology means that clients will save considerable costs related to both CAPEX and OPEX during operations, thanks to reduced need for equipment, sustainability in equipment processes and consumables used, and considerably less transport and logistics required for the water treatment operations.
SDG number 12 “Responsible Consumption and Production» aims to implement sustainable consumption and production patterns. Our planet has provided us with an abundance of natural resources. Humanity have not utilized the resources responsibly and currently consume far beyond what our planet can provide.
MVW recognizes its responsibility to contribute to the global efforts of reducing consumption, waste and carbon footprint. As mentioned above, the technology and product MVW offer contribute to a direct reduction in clients’ need for equipment and consumables. In addition, MVW has a corporate culture where environmental awareness is strongly embedded in all levels of the organization. This includes reinforcing its focus on a circular economy and concepts that contribute to reduced consumption, reuse and recycling of building materials as well as waste handling.
- Do your best to understand the environmental impact of your area of work and minimize its impact.
- Participate actively in environmental programs and courses.
- Keep learning and share environmental best practices with your colleagues.
Human and labor rights
MVW is committed to conducting our business consistently with internationally proclaimed human and labor rights. This includes the OECD Guidelines for Multinational Enterprises, the ILO Declaration on Fundamental Principles, UN Declaration and Convention on Human Rights and Rights at Work and the UK Modern Slavery Act.
It is important for MWV to maintain a good and trusting relationship with the trade unions represented in our company. MVW acknowledges all employees’ right to form and join trade unions of their own choice. MVW has zero-tolerance of child labor or working conditions that conflicts with international laws and practices. Our company also recognizes its responsibility to contribute to the global efforts to combat modern slavery and human trafficking. As a general principle, MVW intends through its operations to not cause any infringement of human and labor rights. MVW is obligated to implement and enforce effective systems to minimize risks of human and labor rights violations in our own business and our supply chain.
- Respect the rights of all individuals that you interact with, and do not contribute to circumvention of human and labor rights while preforming your work.
- Report any breaches of human or labor rights to your manager or MVW`s whistleblowing mail.
Diversity and Equal Opportunities
MVW provides equal employment opportunities to all qualified candidates and employees. MVW actively creates and promotes an environment that is inclusive of all people and their unique abilities, strengths and differences. We do not tolerate discrimination against any employee based on age, gender, sexual orientation, disability, race, nationality, political opinions, religion or ethnic background, or any other basis prohibited by law.
As we continue to grow, we believe that embracing diversity and equal opportunities in every aspect of our business is vital to long-term success. We respect diversity in each other, our customers and suppliers and all others with whom we interact.
- Decisions made on behalf of MVW shall be based on qualifications, not conditions which violate the principle of equal treatment.
- Treat everyone with dignity, respect and fairness, regardless of background or culture.
- Any case of discrimination should be reported to the company`s safety representative or MVW`s whistleblowing mail.
Anti-harassment and Bullying
Respect and courtesy are important elements in a healthy work and business environment. MVW does not tolerate any form of harassment, intimidation, degrading treatment or sexually offensive behavior towards employees or others affected by our operations. Bullying in the workplace is not acceptable. This includes abusive conduct and aggressive, offensive, malicious or insulting behavior.
In general, problems should be solved in polite manner, and one should never resort to acts or threats of violence. Our goal is to create a respectful and inclusive work environment, free from harassment and bullying.
- Everyone is responsible for nurturing and preserving a good work environment.
- Never participate in abuse, harassment, bullying, workplace violence or sexually offensive behavior in the workplace.
- Do not make comments or any other forms of offensive messages, derogatory remarks or inappropriate jokes.
- Any case of harassment or bullying should be reported to the company`s safety representative or MVW`s whistleblowing mail.
Health and HSQE
MVW's vision for safety and security is zero injuries when working at our facilities and in our offices. Our company works continuously and systematically towards preventing accidents and harm to our employees, the environment and our assets in various ways, e.g. through established routines, systematic training, risk averse supplier selection and reporting.
For its employees, MVW shall have a work environment that promotes health. This includes an ergonomic workplace and office, yearly health check-ups and offering competitive health insurance and benefits.
- In a situation where you feel unsafe during work, stop immediately.
- Safety and security are everyone's responsibility. Familiarize yourself with MVW`s safety expectations and rules, emergency preparedness procedures, lifesaving protocols and continue your focus on learning and improvement.
- Get acquainted with your benefits in regard to the company health insurance, participate in yearly health check-ups and consider whether any health problems can be prevented or minimized by ergonomic adjustments in your workplace or office.
- Report any incidents or uncertain situations immediately to the company`s safety representative.
Our company safeguards the privacy of our employees and business partners, and personal data will only be used when truly necessary. The only exception to not sharing personal data with any third parties may arise when subject to satisfactory and appropriate equivalent protections to that offered under EU law.
- Personal data shall be kept confidential and stored in a secure way.
- Make sure that you have sufficient knowledge of, and follow MVW`s requirements, for the processing of personal data if your job involves the handling of such data.
- When it’s no longer necessary to store personal data, the information shall be deleted.
- As a data subject, you have the right to access, alter and limit the processing of your personal data.
Alcohol and drug use
MVW prohibits the use of alcohol or other drugs in connection with work for the company. Limited use of alcohol served as part of the company's hospitality or corporate events may be permitted, provided that the consumption is duly authorized and is not combined with handling machinery, driving or any other act that is not compatible with the use of alcohol. Testing for drugs and alcohol can be carried out when deemed necessary and in accordance with current legislation.
- Do not work when under the influence of drugs or alcohol.
- Be aware and show restraint at events in a work context where alcohol is served.
G - Government
Integrity and business ethics
MVW has zero tolerance for corruption, agreements on price cooperation, market sharing, or other measures that restrict free competition. The direct or indirect offer, payment, soliciting or acceptance of bribes or facilitation payments, whether private or public, in any form, is unacceptable.
Bribery occurs when you offer, pay, or accept an inappropriate payment, gift, or advantage to influence a business outcome or decision. This includes money bribes, or anything else of value, such as a gift or donation, travel or entertainment benefits, employment benefits, or any other advantage. Participation or suspicions of bribery can result in penalty for MVW, but also for you personally.
Facilitation money is a term used in different ways around the world. In some countries, facilitation money is another word for bribes, and in other countries (e.g. in the US`s FCPA) the defined payment term is not illegal. However, MVW aims to act in accordance with all applicable laws and acceptance of facilitation money is therefore not permitted.
Openness is central to the work of combating corruption. We want to be open in our business, promoting transparency in our industry and support measures to combat corruption globally. MVW emphasizes that no employee or business partner will suffer harmful consequences if refusing to engage in inappropriate payment activity, even if this results in loss of business.
- Never offer anything of value to improperly influence the actions or decisions of any private or public person in pursuit of MVW`s interests.
- Facilitation payments are prohibited except when freedom of movement or security are at stake.
- The use of third-party representatives requires specific approval of the CEO of MVW.
- If you have any suspicions of bribery or facilitation payments, you are obligated to report the matter immediately to your manager, safety representative or MVW`s whistleblowing mail.
Money laundering is illegal and promotes criminal activity, including tax evasion, terrorism, corruption, drug trafficking and human rights violations. Money laundering is the processing of criminal proceeds to disguise their illegal origin. This process is of critical importance, as it enables the criminals to enjoy these profits without jeopardizing their source. Proceeds from criminal acts includes not only money, but also other assets, such as real estate and intangible property acquired through criminal activity.
MVW is committed to complying with all anti-money laundering and anti-terrorism regulations. Our company will conduct business only with trustworthy customers and business partners with funds derived from legitimate resources.
- Be attentive to attempts of cash payments involving unusual banking or payment arrangements.
- Conduct appropriate counterparty due diligence. This includes understanding the purpose of the customer relationship and the likelihood of money or property being of non-legitimate origin.
- If you notice any suspicious transactions or incidents of money laundering, you are obligated to report the matter immediately to your manager or MVW`s whistleblowing mail.
In the conduct of our business, we gain access to and produce information and assets that are necessary for our financial and corporate integrity. This applies to tangible assets, e.g. equipment, and intangible assets such as intellectual property, technology and confidential information. However, such information and assets may also be of value to our competitors and others. MVW is committed to protecting the information we process and receive when conducting business to ensure the necessary confidentiality and integrity. Any person who acts on behalf of MVW has the responsibility to prevent unauthorized persons gaining access to internal MVW information, except where disclosure is authorized or required by law.
- You have a duty of confidentiality as long as the information is considered sensitive or confidential in nature. This also applies after the termination of employment or your commitment with MVW has ended.
- Information that you either develop, maintain or have access to through your work for MVW is not to be used for personal gain or in competition with MVW.
Use of IT systems and internet services of MVW must be governed by the needs of the business and not by personal interests. Private use is only permitted to a limited extent, and information that may be considered illegal or inappropriate must under no circumstances be processed or downloaded.
Information produced and stored in MVW’s IT systems is regarded as company property. MVW therefore reserves the right to access all such information except when limited by law or agreement.
- Make sure you are familiar with and follow MVW`s requirements for information management and security classification when handling the company's information.
- The use of company IT systems must be administered by the needs of the business and not by private interests.
- Maintain electronic files and archives in an orderly manner.
- Report any security breaches or misuse of IT systems or internet services according to MVW`s internal procedures.
Conflict of Interest
MVW respects your right to manage your private individual interests and investments regardless of your employment in the company. However, a conflict of interest occurs when personal relationships (e.g. spouse or other immediate family, relatives or close friendships), participation in external activities or other employment may influence a person’s decision making when acting on behalf of MVW. This includes avoiding situations that externally may be perceived as a conflict of interest. In general, when entering a business transaction and/or relationship, maintain MVW`s best interests as being of the highest importance.
- Always act in MVW`s best interests and avoid situations that could lead to or appear as an emergence of a conflict of interest.
- Individuals acting on behalf of MVW must obtain written approval from a manager for all relationships with competitors, customers or suppliers that could possibly raise a conflict of interest.
- As a manager, ensure that an employee in a conflicted position is eliminated from an operation and/or decision-making process associated with the subject of the conflict.
- Serving on the board of directors of another organization can, in some cases, raise a conflict of interest or even a legal issue. Written approval is always required before accepting a position as a board member.
MVW supports fair and transparent financial markets. As an MVW employee or business partner you may be acquainted with information which is not publicly available or commonly known about MVW or other companies. Such information can be considered inside information. When you trade in public traded shares or other securities while in possession of such specific information capable of affecting the price of shares or securities you are involved in insider dealing. This also includes if you disclose this information to someone else or influence someone else who then trades in those shares or other securities. It is a criminal offence to trade in MVW`s shares or other securities based on inside information.
If you are in possession of inside information, even if received by coincidence, you have a duty of confidentiality under the law, and a duty to exercise due diligence to prevent that the information does not reach unauthorized persons. Any use of inside information for personal gain, whether applicable to MVW, or another listed company, is prohibited. Some people such as members of MVW's board of directors or group management, are considered as primary insiders. There are additional restrictions for primary insiders. More details and guidance are further set out in MVW’s internal Insider Procedure.
- Familiarize yourself with MVW’s internal Insider Procedure and seek advice from the company`s IR Manager in all matters involving risk of insider information.
- Do not buy or sell MVW`s or other listed companies' shares or securities or give investment advice to others if you are in possession of any inside information.
- Protect confidential business information and never spread rumors, mislead with false information or manipulate prices.
- Holders of inside information about MVW should be registered in MVW's inside database.
- If you are a board member, familiarize yourself with the rules that apply to you as a primary insider.
Suppliers and Partners
Trust and openness in business relationships is a high priority in MVW. Our company expects our suppliers and partners to comply with applicable law, our ethical standard, and respect internationally recognized human rights when working for or with us. Intermediaries (e.g., agents, consultants, lobbyists) who act as a link between MVW and other parties, constitutes a heightened risk in business. It is mandatory to perform due diligence regarding integrity for all intermediaries. Agreements with intermediaries must be in writing, provide a detailed description of the actual relationship with MVW and include an obligation to follow MVW's ethical guidelines.
- Before entering a new business relationship, you must comply with MVW`s requirements for integrity due diligence.
- Communicate and follow up our expectations clearly and regularly to our suppliers, intermediates and partners.
- Report any abnormalities from a supplier or business partner to your manager or MVW`s whistleblowing mail.
Gifts and hospitality
As a general principle, MVW does not allow gifts or hospitality where giving or accepting them could influence business decisions or violate any laws. However, business relations with our partners can be built and strengthened through legitimate social gatherings and festivities. In situations where it may seem clearly offensive to refuse, modest gifts and hospitality may be a legitimate contribution to a good business relationship. Nevertheless, all matters concerning the acceptance or offer of gifts, hospitality and similar advantages must be in accordance with the company's personnel manual and be discussed and agreed upon between the individual and their superior.
- Do not accept or offer a gift that would influence your or any other individual’s decisions. The exception is promotional items of minimal value.
- Prior to receiving or offering any hospitality, make sure it complies with MVW`s requirements and does not influence your own or any other individual’s judgement.
- Ask yourself how offering or receiving the gift or hospitality can be perceived by others, and never offer or receive anything that is or may appear to be an undue advantage.
- In cases of doubt, always consult with your manager or safety representative for guidance.
Accounting, tax and reporting
MVW has a responsibility of providing timely, accurate, consistent, complete and fair public disclosure of information. Public disclosures will only be made by authorized spokespersons.
Accounting records need to be prepared with accuracy and honesty, and in accordance with company policies and procedures. All entries in our accounting books should be supported by adequate documentation to provide a complete, accurate and auditable record of the transactions they describe.
The Auditing and Auditors Act requires that the auditor is independent of the company’s executive management. In order to contribute to greater awareness of the auditor’s independence, the board shall make sure that it receives an annual written statement from the auditor which confirms that the auditor continues to satisfy the requirements for independence. In addition, the board shall make sure that the auditor provides the board with a summary of all services in addition to audit work that has been undertaken for the company during the last year.
- All data and information included in our accounts must be accurate, complete, reliable and reported in accordance with applicable laws and standards. This includes both financial and non-financial information, such as environmental data and operational reports.
- Never enter incorrect or misleading information in our accounting systems or vouchers/journals. Any intentional action that results in material misstatement of our financial reporting may be treated as fraud.
- Be accurate and diligent, and act in accordance with best practice in the preparation of financial, operational and business information, to present complete, understandable and correct information in all public reporting and communication.
- As a member of the board, be observant of The Auditing and Auditors Act`s requirements for the independence and objectivity when selecting and working with MVW`s auditor.
- If you suspect or become aware of any indications of fraud, failure or incorrect accounting or reporting, report this to your manager or MVW`s whistleblowing mail.
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