1 CONFLICT OF INTEREST (COI)
The employees and directors of NOREXECO are all obliged through their employment agreement/Policy for the Board of Directors to adhere to all relevant laws, rules and regulations pertinent to the company. Furthermore, as outlined in this document, all employees and directors are expected to act in good faith towards NOREXECO and where conflict of interest do arise to manage those in accordance with these principles:
● to protect NOREXECO’s interest ensuring that all decision making is impartial and objective;
● to protect the reputation of NOREXECO by maintaining ethical standards of good judgement, fairness and integrity in all its dealings;
● to ensure that employees always observe the highest standard of professional ethical conduct;
● to avoid any activity or interest that might reflect unfavourably upon a staff member’s own integrity and good name, or upon the integrity and good name of NOREXECO.
1.1 Procedure to identify COI
Each employee and director will in its line of work constantly have a vigilant focus on any potential COI associated with the business they perform and must apply judgment in the performance of our duties that is untainted by personal or financial interests. A conflict arises when:
● your own private interests, personal or financial, interfere in any way (or could be perceived as interfering in any way) with the interests of NOREXECO
● your activities might raise questions as to whether you are acting for personal gain or for the benefit of a third party, rather than in NOREXECO’s interests; or
● you or others could reasonably perceive that you owe a duty of loyalty to an entity or person whose business interests are not aligned with NOREXECO’s.
1.2 Procedure to address COI
Should any employee or director in their professional assessment consider any action to potentially produce a COI, that person shall as soon as possible inform their supervisor or the Head of Compliance. Should the supervisor or Head of Compliance consider the matter
to be of major consequence to the company, they shall as soon as possible inform the Chief Executive Officer and the Board of Directors.
1.3 Record of proceedings regarding COI
The minutes of the company’s handling of the reported COI shall include the following:
a. The name(s) of the person(s) who disclosed an actual or possible COI, the nature of the COI, any action taken to determine whether a COI was present. Furthermore, it shall include the management’s/Board of Directors’ decision as to whether the COI in fact existed.
b. The names of the persons who were present for discussions and votes relating to the situation creating the COI, whether or not any alternatives to the proposed arrangement was considered, and a record of any votes taken in connection with the proceedings.