1.Introduction and purpose

This document reflects Nuuk City Development A/S’s (”NCD”) Code of Conduct (”COC”).

The COC applies to all of NCD’s companies, employees, internal functions and business activities and to full-time, part-time as well as temporary staff. The COC also applies to NCD’s management and board of directors.

The development of NCD is, i.a., based on the confidence of our customers, employees, business partners and the external environment in general. A precondition for this confidence is the respect for the COC described in this document. The purpose is to define commonality of standards and rules for our conduct as support of NCD’s values and that must be followed and acted on by NCD’s employees with respect to our customers, suppliers etc.

The employees of NCD must follow and observe the guidelines and be vigilant with respect to matters that concern themselves, their contracts, departments and the persons for whom they are responsible. The COC must be handed out to the employee at the commencement of their employment. Non-compliance may have consequences in relation to employment law.

2.Laws, directives and other regulations

NCD’s employees must follow any laws, directives and policies applicable from time to time.

NCD must follow the principles of the UN Global Compact initiative concerning human rights, labour standards, environment and anti-corruption.

3.Forced labour and child labour

NCD will not accept forced labour and child labour as defined in the applicable ILO conventions, and to the extent that national legislation provides higher requirements, such requirements are respected.

4.Discrimination

NCD engages employees based on qualifications and will treat everybody on equal terms irrespective of ethnic or national origin, race, gender, religion, sexual orientation and age.

In addition, it is important that all employees treat all individuals they encounter in their employment with dignity and respect.

5.  Pay and conditions of employment

NCD and its sub-suppliers will comply with the minimum wage limits under the law, other employee benefits, working hours and conditions of employment in general.

6.  Conflicts of interest

All employees must comply with this COC in order to promote a healthy, professional conduct in all situations. In addition, the employees must avoid situations that may lead to conflicts of interests and thereby refrain from having interests in and benefitting personally from business opportunities with which the employee becomes familiar in connection with their work.

7.  Confidentiality

Confidential information, including material, contracts etc. received from customers, suppliers and business partners etc. must be treated in confidence. Consequently, employees must not disclose confidential information that they hold by virtue of their position in or affiliation with NCD.

8.  Quality

Quality is of strategic importance to NCD and assurance of quality is therefore a natural part of all contractual obligations.

The employees must participate in the ongoing improvement of systems and procedures that support the quality management.

9.  Working environment

All employees are under an obligation to do their utmost to participate in maintaining a healthy and safe working environment, including to observe external and internal policies in this area.

10.Business conduct and competitive power

NCD’s business conduct and competitive power is based on ethical and legal business principles.

NCD will not participate in any form of unfair trading or illegal cartels.

NCD will neither directly nor indirectly receive any bribe or use other illegal methods. Furthermore, NCD will neither offer nor give any form of present or other form of payment that can be seen as bribery.

11.Suppliers and business partners

NCD will treat all customers, suppliers and business partners honestly and fairly. The choice of these is, i.a., based on the suitability, quality, price and terms of delivery of the products or the services.

NCD will only enter into contracts with suppliers and business partners that comply with laws and other regulations as well as human rights in the countries in which they are represented.

12.Requirements to key customers, suppliers and business partners

All suppliers and business partners in a direct contractual relationship with NCD that are involved in the performance of building activities must comply with collective agreements, minimum pay etc., be affiliated with an employers’ organisation covered by a collective agreement or be otherwise affiliated with a collective agreement for the relevant field and be legally registered in connection with work performed in Greenland. All companies that employ foreign labour in Greenland, either itself or through sub-contractors, sub-suppliers, employment services companies and similar, must perform an adequate control to ensure that all work is performed legitimately.

The COC applies to key collaborative relations which means that such collaborative relations must respect guidelines corresponding to NCD’s guidelines. NCD may choose to terminate cooperation if customers, suppliers and business partners do not observe NCD’s COC.