Business Ethics and Integrity

Business ethics and integrity
Jotun wants to be perceived as a serious, dependable and long-term business partner. We therefore:

• have high standards in business ethics and integrity
• give priority to the interests of both customers and Jotun over personal gain and benefit; e.g. we do not mix Jotun’s business with any own business or those belonging to relatives or close friends
• do not solicit or accept any benefits other than customary gifts and entertainment
• meet customers with respect
• treat suppliers impartially and fairly
• meet and refer to competitors in a professional manner
• offer high quality products and services as well as in all parts of business processes
• have employees who act as Jotun ambassadors and who strive to maintain Jotun’s reputation when engaged in both business and non-business activities
• respect the culture of those countries in which we operate

Community

• Jotun is a responsible and dependable company, and therefore meet public authorities and Non Governmental Organisations in an appropriate and open manner
• Jotun does not make contributions to political candidates or political parties

Fair trade and free competition

• Jotun believes in fair trade and free competition which will facilitate a just distribution of goods and services
• Jotun aims for transparency and works actively against corruption and bribery

Employees
Jotun believes in the dignity of each employee and in taking employees’ interests seriously. We therefore:

• respect the UN Human Rights Declaration and ILO standard
• provide high health and safety standards in our working environments at all sites and facilities and take appropriate steps to prevent accidents and injuries
• encourage constructive discussions without jeopardising the position of an individual
• engage in negotiations in good faith if conflicts arise
• facilitate communication with all employees to address areas of concern
• respect the right of personnel to form and join trade unions of their choice
• avoid discriminatory practices with regards to gender, age, race and religion

Business operations
Jotun holds a high ethical standard in its daily business operations. Furthermore, Jotun wants transparency in operations. We therefore:

• respect laws and regulations of those countries in which we operate
• ensure that transactions are correctly registered and supported by proper documentation in accordance with local and international accounting principles
• do not reveal to any third party confidential information, including but not limited to technology, operating procedures, pricing, financial information, business and strategy plans, supplier and customer lists and customer information
• adhere to and comply with Jotun standards and policies, e.g. with respect to Health, Safety and Environment, Corporate rules for protection of personal data, Finance, Communication, Human Resources, Chemicals, Site Security, Crisis Management, e-mail and internet policy.

Corruption and bribery are threats to economic development, global poverty and our integrity and we owe it to our customers, the local communities, our shareholders and our employees, to maintain high ethical standards.

At Jotun we believe that openness, discussion and training is the best way of creating the right attitudes. In addition to rules and guidelines for behaviour, Jotun therefore puts great emphasis on practical training. Only when our employees have discussed things openly and trained in how to act when facing a dilemma, can the right and sound business decision can be made.

Jotun works actively against corruption!

Definition of whistle blowing  
Whistle blowing is the act of calling attention to intolerable circumstances relating to Jotun’s activities, by notifying someone who can do something about it.

There are many questions related to this topic:
How should you — both as manager and as a colleague — deal with irregularities that occur within the organisation? How and in what way should one report these irregularities? To whom should one report? What should be done if nothing changes? A culture of responsible attitudes and actions 
At Jotun, all employees are invited to contribute to an open discussion about responsible attitudes and actions in a constructive and non-bureaucratic way.

Fostering a culture in which people dare to raise difficult subjects does not come about all by itself. It requires both brave employees and skilled managers to enhance such a culture.

Blowing the whistle in Jotun
A lot of conflicts arise when you discover serious circumstances. Your own interests — including your future with Jotun — must be maintained, along with concern for the future reputation of the organisation. 

At the same time, you have a professional responsibility to your superior. 

It is Jotun’s responsibility to ensure that whistle-blowers are well taken care of internally, meaning that the person must not be punished, directly or indirectly. 

On the other hand, anyone blowing the whistle without a proper reason or to harm a person or the organisation will be subject to disciplinary procedures. You don’t need proof of your suspicions, but all concern must be made in good faith.    

It is preferable to file your report in writing. That is the best way of documenting a whistle-blower situation. 

It is important to have proper facts and to be as certain as possible about the fundamental facts of the case.  
 
What to report  
Severe incidents, breaches or suspected breaches of:

• Jotun’s Business Principles or laws and regulations
• Corruption, including bribes and kick backs
• Human and labour rights violations
• Discrimination or harassment
• Threats to life or health
• Fraud, theft and/or embezzlement
• False financial reporting
• Conflicts of interest
• Violations of competition laws
• Violations of environmental regulations
• Breaches of confidentiality

Want to raise a complaint? On a day-to-day basis, you should seek guidance from and direct anti-corruption inquiries to your immediate superior. You may also contact the legal department, Group Controlling department or Legal and Compliance department of Jotun A/S if you have any questions about this manual or anti-corruption law on  + 47 33 45 70 00 . 

If you decide to raise a complaint, this should also be reported through the proper channels, i.e. line manager. If this is inappropriate or inadequate due to the nature of the complaint, information may be given to HR or General Manager/Managing Director. You may also use Jotun’s whistle blowing procedures and report openly or anonymously by copying the below URL to your browser to access the whistleblowing channel: 

https://report.whistleb.com/jotun 

The communication channel can be reached on any device, including smart phones. The channel allows anonymous messaging and dialogue between the whistleblower and the receiver.

Jotun makes an effort to run our business in a way that respects human rights and labour standards. Our commitment is based on:  
Universal Declaration of Human Rights, International Covenant on Civil and Political Rights (ICCPR) and International Covenant on Economic, Social and Cultural  UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work (ILO Convention) and the UN Global Compact principles.   
Our Human Rights policy applies to all Jotun companies regardless of the individual state's abilities and/or willingness to fulfil their own human rights obligations. Jotun expects that our personnel, business partners and others stakeholders who are directly linked to our operations, products or services, have equally respect for fundamental human rights.   

Besides having a clear policy on compliance with human rights anchored at the Board of Directors, Jotun has processes to avoid that adverse human rights impact takes place. 

Through Jotun's internal reporting system, each Jotun company reports twice per year to the local Board of Directors and the line management Business Review team, that mitigation and remediation processes are in place in case of adverse human rights impact. Besides all companies do a self-assessment yearly on human rights compliance.  

Jotun has taken active steps to prevent adverse human rights impacts linked to our suppliers. Through our structured supplier audit system, suppliers are audited on a list of indicators, hereunder human rights compliance.   

If adverse human rights impact should occur in a Jotun company, the incident will initially be dealt with along the business line. Any adverse impact may also be reported through Jotun's centrally administrated whistle blowing channel. Appropriate administrative or legal steps will be taken depending on the circumstances. 

Jotun’s Human Rights commitment is reviewed by external expertise.