- BACKGROUND AND PURPOSE
Corporate social responsibility
Eika Boligkreditt AS (EBK) wishes to contribute to sustainable development for the environment, people and society, which includes accepting responsibility for ensuring that fundamental human rights and decent working conditions are respected in connection with the company’s business. To secure EBK’s corporate social responsibility and the value creation provided by the company along with the rest of the Eika Alliance, EBK will only collaborate with suppliers and business partners who meet the company’s requirements and standards. EBK aims to implement optimal and efficient procurement in terms of price, lifetime costs, quality and environmental impact. Compliance must also be ensured with national and international legislation and regulations related to human and labour rights, the environment, transparency, and combating corruption and money laundering.
Application of this policy
This policy applies to ongoing agreements with EBK and procurement of goods and services for EBK from suppliers and business partners, including internally in the Eika Alliance. That also includes agreements with investment banks/managers in EBK’s funding activities.
All procurement must accord with the principles specified in this policy. Suppliers are duty-bound to see to it that sub-suppliers also meet the requirements specified by EBK.
This policy also applies to outsourcing arrangements pursuant to EBK’s policy for outsourcing
Where procurement made via or in cooperation with Eika Gruppen (EG) is concerned, see the policy on procurement and outsourcing for Eika Gruppen AS.
- ROLES AND RESPONSIBILITIES
The relevant manager is responsible for ensuring that all procurement within their area of responsibility is implemented in accordance with this policy.
The CAO is responsible for initiating necessary revisions of this document.
- GENERAL PRINCIPLES FOR PROCUREMENT
Products or services procured must be environment-friendly and sustainable, with attention paid to the life cycle of a product related to such aspects as recycling.
EBK must ensure that contracts for procurement of goods and services are entered into on the best possible terms, and its purchases must be as cost-efficient as possible.
EBK must maintain the integrity of its procurement processes in relation to applicable regulations, and primarily make purchases on the basis of competitive tendering.
Procurement processes must meet requirements for equal treatment, predictability, transparency and verifiability.
In its procurement processes, EBK must ensure that no questions can be raised concerning conflicts of interest from the relationship between its employees and the supplier company or their personal interests. EBK has established a policy for dealing with conflicts of interest.
- REQUIREMENTS FOR SUPPLIERS
Labour rights, human rights and HSE
EBK’s suppliers must respect the UN principles on human rights, the ILO convention, and international and national legislation on pay, working hours and rights to organise.
Prohibition of child labour
The supplier must not use child labour. This concept refers to children under the age of 15 who are below the minimum age for completing compulsory education or the legal age for employment in the relevant country.
Employees under the age of 18 must not do work which could be injurious to their health or hazardous, including night shifts and overtime.
Prohibition of forced labour
The supplier must not use forced, slave or other forms of non-consenting labour. Mental and physical compulsion, slavery or human trafficking are prohibited.
Prohibition of discrimination and harassment
The supplier must not discriminate against employees or others on the basis of such aspects as gender, age, ethnicity, religion, social affiliation, disability, sexual orientation, union membership or political views.
The supplier must ensure that no employees are subject to physical, mental or verbal harassment. It must also treat everyone equitably, and strive for gender balance, diversity and inclusion in its workforce.
EBK’s suppliers must not expose employees to working conditions which could harm their life and health. The supplier must conduct health and safety assessments to identify significant risks in the company. All employees must receive training and information tailored to the risks they could be exposed to in their work.
On request, the supplier must document that HSE and safety inspections have been conducted and approved in accordance with applicable regulations.
- THE ENVIRONMENT
EBK’s suppliers must ensure that their operations accord with local environmental management regulations. Large suppliers should have an environmental policy to reduce possible negative impacts on the environment in the form of resource use, waste handling, hazardous substances, greenhouse gases and other emissions.
The supplier should conduct its business in such a way that goods and services delivered to EBK maintain a high level of environmental quality in terms of material selection, production processes, life cycle and use as a waste product.
- ETHICAL BUSINESS CONDUCT
The supplier must comply with Norwegian and international rules for storing personal and confidential information, and be GDPR compliant.
EBK does not tolerate any form of corruption, bribery, misappropriation or price-fixing. The supplier must actively oppose money laundering and undeclared (black) labour, and take the necessary precautions to avoid this. The supplier must be consciously opposed to corruption, and its employees must be able to identify corruption and know how to deal with it.
The supplier must have a process for dealing with whistleblowing which is known to employees, and which allows employees to report irregularities without fear of reprisals. The supplier must ensure that anonymity and confidentiality are maintained. The whistleblower must receive the necessary protection.
- DUE DILIGENCE AND RISK ASSESSMENT
EBK conducts due diligence in accordance with the Transparency Act. A due diligence process can be described as one where a company is able to identify, prevent, restrict and account for the way it handles the existing and potentially negative consequences of its business. Due diligence must be conducted regularly and be proportionate to the size and nature of the business, the context it operates in, and the seriousness and probability of negative consequences for fundamental human rights and decent working conditions. As part of its due diligence process, EBK identifies and assesses actual and potentially negative consequences for fundamental human rights and decent working conditions which the business has either caused or contributed to, or which are directly related to its business activities, products or services along the supplier chain or at business partners.
Pursuant to section 4 b of the Transparency Act, the scope of a risk assessment of individual suppliers or business partners depends on the type of procurement conducted. The assessment can be limited in scope providing the procurement satisfies the following criteria:
- its total value is below NOK 1 500 000
- no outsourcing or ICT procurement is involved
- this is considered acceptable, hereunder that using the relevant contractor is low-risk.
The exception could typically be applied to the procurement of operational consumables (office supplies), or to short-term or one-off procurement of services.
Where outsourcing is concerned, the procedure for acceptability assessments and outsourcing contracts is regulated in the policy on outsourcing.
- CONTRACT FOLLOW-UP
EBK will ensure that ongoing contracts are followed up to determine compliance with applicable regulations and EBK’s policy.
The company’s suppliers and business partners must note that the contract may be cancelled for serious breaches. See the self-declaration on supplier behaviour, appendix 1 to this policy.
The self-declaration or other documentation that the supplier complies with applicable regulations and EBK’s policy will be stored electronically together with the agreement with the supplier. When choosing a manager in connection with transactions, a self-declaration must be signed by the manager or corresponding documentation made available.
Suppliers and business partners must contribute to ensuring that EBK receives the information required to follow up and conduct due diligence of suppliers, such as through questionnaires
- APPROVAL OF THIS DOCUMENT
This policy was approved by the board of Eika Boligkreditt AS on 22 June 2022 and came into effect from the same date.