Code of Conduct and Ethical Principles

provides clear instructions about what our staff can and can't do, and also sets the expectations on what external stakeholders can expect from us in terms of how we conduct our business.

Introduction

Several stakeholders in Smartoptics’ success have expectations on how we behave as a business and how our employees behave when representing the company. This includes our owners, employees, customers and our suppliers. This is our Code Of Conduct and is important because it provides clear instructions about what we can and can’t do, and also sets the expectations on what external stakeholders can expect from us in terms of how we conduct our business. The Code of Conduct shall be applied throughout the company´s operations, including in the management, development, production, supply, sales and support of Smartoptics’ solutions, products, and services worldwide.

The Code Of Conduct is a starting point for our journey to become a recognized  role model for companies in our business and of our size. Taking Corporate Social Responsibility seriously shouldn’t be a luxury that only large companies can afford.

Guiding principles

Smartoptics Code of Conduct is based on the UN Global Compact framework and specifically its ten guiding principles. Smartoptics has not negotiated a Collective Bargain Agreement with any union, however employees at the two main sites enjoy benefits very similar to what is normally included in such agreements. 

Human Rights

1:   Businesses should support and respect the protection of internationally proclaimed human rights; and

2:  make sure that they are not complicit in human rights abuses.

Labour

3:  Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

4:  the elimination of all forms of forced and compulsory labour;

5:  the effective abolition of child labour; and

6:  the elimination of discrimination in respect of employment and occupation.

Environment

7:  Businesses should support a precautionary approach to environmental challenges;

8:  undertake initiatives to promote greater environmental responsibility; and

9:  encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

10:  Businesses should work against corruption in all its forms, including extortion and bribery.

Labor standards

Smartoptics offers a fair and equal opportunity working environment. Working hours, wages and benefits are all according to Environment acts or better.

Child Labor Avoidance

No person shall be employed who is below the minimum legal age for employment.

Elimination of Discrimination 

All employees shall be treated with respect and dignity. All kinds of discrimination based on partiality or prejudice is prohibited, such as discrimination based on race, color, gender, sexual orientation, gender identity, marital status,  pregnancy, parental status, religion, political opinion, nationality, ethnic background, social origin, social status, indigenous status, disability, age, union membership or employee representation and any other characteristic protected by local law, as applicable. Employees with the same qualifications, experience and performance shall receive equal pay for equal work with respect to those performing the same jobs under similar working conditions.

Physical or verbal abuse, bullying or other unlawful harassment and any threats or other forms of intimidation shall be prohibited.

Fair Employment Conditions 

Employees shall understand their employment conditions. All employees must be provided with a written document that outlines the basic terms and conditions of employment in a language understandable to them. Pay and terms shall be fair and reasonable, and comply at a minimum with applicable laws or industry standards, whichever is  higher. Working hours shall comply with applicable laws.  Vacation is regulated by respective local vacation acts.

Fair, Safe and Healthy Working Conditions

The health and safety of our employees will be prioritized. We will have HSE-rounds with the dedicated safety representative. HSE-rounds include emergency plans, control of fire equipment, work environment – both physical and psychosomatic – etc. to ensure a healthy and safe work environment. Necessary steps will be taken accordingly to findings during HSR-rounds.

We shall provide support to employees to maintain a balance between work and personal life.

Management system

Smartoptics is ISO 9001:2015 certified and the management system is continuously updated to ensure that we follow laws, regulations and risk management.

Environment

We shall develop, produce, and offer products and services with excellent sustainability performance and contribute to the sustainable development of society. Our ambition is to develop procedures and tools that allow us to track, measure and incentivize ourselves to continuously improve our environmental footprint.

Our products are RoHS compliant and CE Certified. We are actively developing our products with target to comply with REACH.

For all waste, we have a contract with a recycle and disposal company to comply the WEEE-regulation from the European Commission.

Ethics

Smartoptics has a zero-tolerance policy towards any form of corruption and financial irregularity, for example bribery, kickbacks, facilitation payments, fraud, embezzlement, and money laundering.

Bribes and Kickbacks

No employee of Smartoptics may demand, accept, offer to give to any representative of a business partner or third party, any kind of Bribe, kickback or any other unlawful or unethical benefit.

Gifts and Entertainment

Gifts and entertainment given or offered to a third party in the course of employment shall be modest and appropriate and business related, comply with applicable laws and conform to the recipients organization’s policies or rules and be fully disclosed and transparent. Cash or cash equivalents may
never offered, accepted or requested.

Public Officials

Stricter rules apply when we interact with government entities and their employees or representatives. Normally nothing of value should be promised, offered, or provided to a public official, either directly or indirectly.

Money Laundering

Money laundering and the funding of terrorist and criminal activities is strictly prohibited. It is therefore vital that employees are familiar with, and comply with all applicable laws related to such matters.

Conflict minerals

Smartoptics do not produce products containing minerals from Congo or other conflict areas.

Reporting compliance concerns

Employees or business partners may report suspected violations of laws or this Code of Conduct document to the CEO of Smartoptics.

A whistle blower function is available. Einar Caspersen (attorney at law, Schjødt Oslo and member of the board of directors at Smartoptics) may be contacted for this purpose.