Business Practice Principles

Compliance with the Business Practice Principles
• The Business Practice Principles are applicable to all employees within the Lindorff Group and shall be enforced at all levels within the Group
• The Group is dependent upon its customers (including debtors), subcontractors, partners, owners, authorities and the community around us. Maintaining the trust of these interest groups is an imperative precondition for achieving lasting success. It is therefore extremely important that all employees comply with these principles
• All employees are expected to work within the law, have sound moral principles and to behave in an upright and sincere way. Lindorff’s core values and other norms support this pattern of behaviour. All employees are also expected to have good control over their personal financial position. Should an employee find themselves in severe financial difficulties, they should immediately inform their superior or HR department
• The Business Practice Principles are explained to all employees at the beginning of their employment. The members of the Group Management team, together with other managers within Lindorff, are responsible for supervising employees’ compliance to the Business Practice Principles
• The Principles (as well as information about Lindorff’s ethical helpline) shall be available to employees through Lindorff’s intranet translated into relevant languages

Resolution of ethical conflict
A Lindorff employee may encounter problems in identifying unethical behaviour or in resolving an ethical conflict. The following general guidelines exist:

• The employee should discuss the matter with their immediate superior, except when it would appear that the superior is involved, in which case the problem should be presented initially to the next higher managerial level
• The Group will take all reasonable steps to respond appropriately to any breaches of the Business Practice Principles and to prevent further similar offences from occurring, including modifications of these principles
• Lindorff ensures that there will be no negative consequences to individuals as a result of reporting suspected unethical behaviour or breaches of these principles.

Customers and services offered to customers
• Lindorff has a long and binding tradition. Customer relationships are based upon mutual trust and confidence
• High-quality customer service requires an open and honest presentation of Lindorff’s services in order to provide the optimal solution to the customer. Being experts in our specialist fields, we can serve our customers without delay
• Should a customer decide to terminate their service agreement with Lindorff, the customer is always treated in a professional and polite way. We do our best to build a “golden bridge” in order to make it easy to restart a relationship later on
• Lindorff will not participate in any operations that are contrary to good business practice or support any illegal actions possibly taken by a customer
• Lindorff will not offer services to customers, whose operations are based upon unethical business practices, sale of services that can be seen as morally doubtful or whereby through serving them, Lindorff’s reputation could be jeopardized or endangered
• The final resolution of ethical conflict issues rests with the Lindorff Group Management team where there is ambiguity or doubt

Customers participating in Lindorff Customer Events
• We will always respect and have a proactive approach towards our customers’ rules for gifts, trips, event participation and expense settlements.
• In our major events, we will always have a professional program which in time and content is significant and proportionate to the total event.
• Normal business amenities like lunches, entertainment, executive briefings can be offered to customers provided the expenses involved are kept at a reasonable level
• Customer representatives pay their part of travel and accomodation expenses related to our events.
• Customer representative’s spouses may be invited on the condition that travel and accomodation is paid for by the customer representative.

Customer gifts and trips paid by customers or subcontractors
• Group employees are not permitted to receive from customers / partners / subcontractors or debtors any gifts or other financial benefits that might endanger decision-making based upon sound economic principles
• As a general rule, the giving and receiving of gifts and trips is not permitted when dealing with customers or vendors where a contract is under negotiation, though not yet signed
• Receiving a gift from above-mentioned interest groups is permitted, if not otherwise contrary to law or generally approved practice, for example, in the following situations:
–Customary business gifts and business lunches
–Birthday presents etc
–General rewards and awards for merits
–Normal discounts on the customer’s products
• A customary business gift can be considered as an element of the relationship between Lindorff and the interest group. The giving or receiving of such a gift is not related to any individual decision or action concerning the interest group. Consequently, a customary gift cannot be considered as a personal reward
• Lindorff employees should also take a reserved attitude towards trips offered by these interest groups. Participation in such trips is subject to the immediate superior’s prior approval
• The above-mentioned principles shall also be followed where applicable, when offering gifts and trips to customers or other individuals outside of the Group

Secrecy obligation
• Customers have entrusted confidential information to Lindorff. The processing of this information is regulated by law and by bank secrecy (assignments from credit institutions). Using and processing the details entrusted to Lindorff is only allowed in the context of the business activities that the customer has asked Lindorff to undertake on their behalf
• The above statement is also applicable for confidential information relating to Lindorff’s partners and other interest groups with which it has business dealings
• Examples of confidential information include:
–Secret information (extremely limited target group): business development plans, merger & acquisition material etc.
–Confidential information (limited target group): personal register details, operation plans, monthly reports, auditing reports, brochures before publication, general instructions, work instructions, notices etc.
• Lindorff employees are party to information, the use of which might result in financial profit or cause losses to the customer. Therefore, issues regarding bank secrecy or other business secrets should not be discussed with other Lindorff employees, except when necessary for carrying out required tasks
• As far as issues other than bank or business secrecy are concerned, careful consideration should be exercised when discussing business matters with parties from outside Lindorff. When discussing the business of customers, we should only disclose facts that we are certain of
• Bank and business secrecy must not without reason prevent the free flow of information within Lindorff

Fair employment practices
• Lindorff aims to create a working environment in which employees can fulfil their potential
• Lindorff is committed to equality of opportunity in all its employment practices. No employee will receive less favourable treatment due to their gender, nationality, disability, membership or non-membership of a trade union, marital status, religion or sexual orientation

Discussions of issues concerning oneself and one’s immediate circle
• During the period of employment, a Lindorff employee may not participate in the preparation and handling of, or decision-making upon, collections or other business activities undertaken by the Group, concerning themselves or their immediate circle:
• People considered to belong to the immediate circle include, for example:
–Husband or wife or a co-habitant person
–Persons living in the same household
–Parents, children or siblings
–An association in which a Lindorff employee or a person in their immediate circle is acting as a member of administration or management, or a significant proportion of which is owned by a Lindorff employee or a person in their immediate circle
–Considerable investments or loans are considered equal with ownership
• It is particularly emphasised that Lindorff employees must not:
–Handle an assignment concerning themselves or a person in their immediate circle or participate in the decision-making relating to the assignment
–Participate in handling assignments given to Lindorff by themselves or their immediate circle
–Commit themselves or their immediate circle on behalf of the employer or sign such commitments
–A Lindorff employee may of course give assignments to Lindorff and act as a customer through normal agreements and transaction processes

Other conflicting interests
• Lindorff employees, each of them belonging to the same above-mentioned immediate circle, should as a general rule not work in the same unit / department and never in a superior-subordinate relationship
• Family connections, significant holdings, investments or other interest relations may result in conflicting interests. In most cases, it is a question of decisions or measures that produce personal, financial benefits. In such cases it is absolutely necessary to refrain from participating in decision-making on a case. If necessary, the case must be submitted to the immediate superior for a decision

Secondary Occupations and Positions of Trust
• A Lindorff employee is expected to work for Lindorff at full capacity. Secondary occupations and positions of trust must not be an obstacle to executing the employees duties at work
• Written permission from the employees superior must be acquired for secondary occupations and positions of trust
• The following general requirements are established regarding permissible secondary occupations and positions of trust:
–Operations competing with Lindorff may not be connected to the secondary occupation, nor may it be in conflict with Lindorff’s operations
–A Lindorff employee may not carry out the secondary occupation during their working hours or on Lindorff’s premises
–A Lindorff employee carrying out a secondary occupation may not utilise Lindorff’s personnel, customers or property
–Decisions deviating from these requirements can only be made by the Group Management Team. Should the employee concerned be a member of the Group Management Team, the Board of Directors shall make the decision.

Utilising inside information
• From time to time a Lindorff employee may posses inside information that could influence the value of securities issued by another company. Inside information refers to information that has not been published, nor has it otherwise been made available in the market, and which is likely to have a material effect upon the value of the said security
• Inside information may include a merger/division of a company or other significant corporate actions e.g. a significant outsourcing deal or a purchase offer relating to portfolio acquisition
• The information shall be confidential until published or otherwise made available in the market. It is expressly prohibited for employees to make use of inside information to gain economic benefit for themselves or for any other person
• The prohibition against abuse of inside information shall apply to all persons who possess inside information regardless of how and where the information has been received from

Valuables handled in the debt collection process
• Lindorff employees must under no circumstances retain valuables handled in the debt collection process. Furthermore this means that Lindorff employees under no circumstances can acquire:
–Any item repossessed by Lindorff street collection
–Any item sold under enforced auction where Lindorff has been involved in the collection process

Documentation of decisions and filing of documents
• All decisions made by Lindorff and which affect the relationship between the company and the customer or the subcontractor must be duly documented
• Documentation must be filed in a safe place so that the decisions, relevant information and all factors pertaining to the decision-making process as well as the names of the persons who made the decisions can be found easily
• The obligation concerning documentation and filing is also valid for the differing authorisations and assignments given to Lindorff. The contents and purpose of the authorisation or assignment must be shown within the authorisation and assignment. The possible time limits of the assignments must be noted and adhered to. The authorisations and assignments shall be given to a company belonging to Lindorff, not to an individual employee

Environmental principles
• Lindorff supports and endorses environmental protection and principles of sustainable development. Sound environmental principles make business sense since there is a positive interaction between economic growth and environmental protection
• Environmental matters are integrated into our normal daily business. Our environmental principles provide guidance on how we shall manage environmental issues within our services
• Lindorff complies with relevant environmental regulations and issues in the countries in which we operate
• Lindorff expends a lot of effort in improving its environmental performance by reducing the negative environmental consequences of its services and increasing staff awareness of recycling office equipment (IT), furniture and waste in order to reduce the use of natural resources
• Lindorff avoids unnecessary travel and promotes the use of video and telephone conferences
• Lindorff promotes the usage of intranet and on-line services in order to save costs, reduce unnecessary processes and to reduce the environmental impact of its services by lowering the paper consumption etc.
• When purchasing products or services, Lindorff places emphasis upon the high environmental quality of products/services being considered.