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NMS is dedicated to strong corporate governance, rooted in honesty, leadership, responsibility, fairness, and transparency. Our Board of Directors, Management, Officers and Staff embody these values, fostering a culture where ethical conduct and effective leadership drive our success. This commitment enhances our relationships with clients and stakeholders, positioning us as a leader in delivering smart and reliable technical solutions and reinforcing our reputation for excellence and integrity in the industry.
Ambition
Positive dissatisfaction: Happy, but not satisfied. A little better day by day, project by project.
Cooperation
We all depend on each other in the Norconsult family. Personal relationships (but not private).
Transparency
To learn, we must share: No secrets, proactive participation and commitment across.
Trust
Motivation = the trust from leaders, colleagues, clients, and society.
Care
Take care of others and ourselves, our right and duty to speak up, care for the environment and society.
Accountability
Take responsibility. Don’t look for excuses when targets are not met.
Honest
We live by our Code of Ethics and act honestly in all matters to the benefit of society, our clients and ourselves.
Competent
We all take responsibility for the development of our own competence, and we constantly strive to enhance our knowledge and skills to deliver the best professional quality.
Inclusive
We create results through positive inter-action among people and approach everyone with respect and openness. By sharing knowledge and experiences we can solve tasks as one team.
Engaged
In Norconsult, we are proactive. Through our joint engagement and our ability toinnovate and develop, we are at the forefront. We are a driving force for sustainability with creative solutions.
All our behaviour shall be able to withstand public scrutiny. We do the media test by asking ourselves and our colleagues as well:
«Is it OK if this is going to make headlines?». The answer should always be a sound and clear YES.
INTRODUCTION
In addition to our strong technical prowess, integrity has always been a key ingredient to what Norconsult Management Services, Phils., Inc. (NMSPH). As a business we say, “We make a decent profit decently”. We believe that there are many clients out there who want to work with companies like who operate under the principles of integrity, honesty and ethical behavior. It is therefore important for all of us who work in NMSPH to understand that these principles are not mere buzz that we use in our corporate documents and credentials. These are words that describe the way we work and live as a company and as citizens of this country.
I therefore implore that we all take the time and effort to understand and imbibe our Code of Ethics it a pivotal part of our company culture. As we reflect these in our lives, we reflect the very nature what God has intended us to be: a people of conscience, scruples and morality.
–RODOLFO T. AZANZA, JR.
President & Chairman of the Board
SCOPE and RESPONSIBILITY
This code shall apply to all employees, regardless of the position and employment status. This also includes all members of the Boards of Directors and shareholders. Affiliated companies and NMSPH’s business partners are expected to be committed to ethics and integrity compliance in the conduct of their business operations and will be monitored accordingly.
The Code of Ethics is a governing document, and part of NMSPH’s management system. It defines the ethical standards upon which we shall act.
This Code of Ethics does not provide detailed guidance on any specific situation or give instructions on how to comply with local legal requirements in the many different countries in which NMSPH operates. It provides a framework of conduct to be followed when representing NMSPH, and as such influences how to think about what we should and should not do. Managers on all levels at NMSPH are responsible for familiarizing their employees with the Code of Ethics and implementing and ensuring compliance with it.
Employees shall comply with all applicable laws and regulations. If there are differences between such laws and regulations and the standards set out in this Code of Ethics, the most stringent standard shall be applied.
In situations of doubt or if this Code does not provide explicit guidance, consult with your immediate superior. Enquiries about the Code of Ethics, how it should be interpreted and applied can be directed to your immediate superior, applicable staff functions or HR.
1 SOCIETY AND ENVIRONMENT
1.1 Social Responsibility
NMSPH and our employees must be aware of their responsibility for the impact the company’s decisions and activities have on society and the environment and which is exercised by displaying transparent and ethical behavior that contributes to sustainable development in society, takes into account expectations from stakeholders, is in accordance with applicable law and compatible with international behavioral norms and is integrated throughout the organization and is practiced in the organization’s various relations.
Sustainable development is a question of looking after the external environment and human health and building good communities using economic and cost-effective solutions. NMSPH will contribute to development that meets the needs of the current generation, without compromising the needs of future generations.
1.2 Environment
NMSPH is a key player in the regional and the national communities in which the group is represented.
Our activities may pose challenges to the environment through our consultancy, and in our business
operations.
In this context, the environment includes topics such as the natural resources, emissions of greenhouse gases, substances hazardous to health and the environment and general reduction of resource use. NMSPH’s activities shall not contribute to damaging the resource and income base, especially not for indigenous people and other marginalized population groups, for example by contributing to seizure or through irresponsible use of land and other natural resources.
All employees are responsible for ensuring that the environmental impact of our activities is minimized.
Environmental impact shall be assessed in our assignments, and employees are responsible for recommending sustainable solutions.
NMSPH is committed to exercising care and responsibility for the environment.
1.3 Human rights
All people are equal and entitled to be recognized and treated with respect and dignity. NMSPH supports and respects the promotion of internationally proclaimed human rights, such as the United Nations’ Universal Declaration of Human Rights. At NMSPH, all relationships and business practices are to be founded on basic human rights and a recognition and acceptance of diversity. Inclusive and honest are among NMSPH’s core values. All employees shall respect the personal dignity, privacy, and rights of all those with whom they interact.
If employees suspect or are aware of conduct in breach of NMSPH’s standards regarding human rights, they shall notify their immediate superior, in accordance with the routine for reporting concerns.
NMSPH shall be a safe workplace with an inclusive working environment. NMSPH upholds freedom of association and recognizes the right to collective bargaining in accordance with national laws and regulations. NMSPH supports the elimination of all forms of child, forced and compulsory labor. NMSPH does not tolerate any form of harassment, discrimination, or intimidation.
Employees of NMSPH shall never contribute to, perform, or experience negative discrimination based on any status, mental or sexual harassment, language or physical contact that is coercive, threatening, abusive or exploitative. If employees suspect or are aware of conduct in breach of NMSPH’s standards regarding working conditions, they shall notify their immediate superior in accordance with the routine for reporting concerns.
1.5 Health, safety and employee security
NMSPH will conduct its business with the highest regard for the health, safety and security of all employees. NMSPH is committed to maintaining a working environment that is safety-conscious and a workforce that is properly equipped, trained, aware of, and compliant with safety and health requirements and guidelines.
With a continuous focus on identifying risks, potential accidents, and non-conformances, and investigating their causes, hazards shall be identified, mitigated and monitored to prevent accidents, occupational illnesses and deliberate threatening or violent actions in or resulting from NMSPH’s business operations.
All employees are responsible for ensuring that occupational risks relating to assignments and tasks are identified, evaluated, and documented. Relevant measures and controls to reduce occupational risk shall be identified, implemented and documented in a verifiable manner. It is the duty of each and every employee to notify their immediate superior of any concerns that may threaten the health, safety and the security of employees.
2 OUR RELATIONSHIP
2.1 Clients
Our clients place trust in our competence and consultancy to support their value creation and success. NMSPH’s business mission is to stand out as the first choice in the consultancy sector. However, no client is more important than the ethics, integrity, and reputation of NMSPH. Employees of NMSPH are responsible for providing quality services that reflect our professional and interdisciplinary competence and are appropriate and tailored to the specific issues and needs of our clients.
Employees of NMSPH shall meet and treat clients in a consistent way, working together to achieve the best solutions and acting as ambassadors for our core values: Competence, Honesty, Inclusiveness and Proactiveness.
2.2 Partners and suppliers
Suppliers comprise both individuals and companies that have their own organization and routines and
are engaged by NMSPH to further enhance our ability to provide products and services to our clients.NMSPH expects its suppliers to be committed to ethics, and to comply with other integrity requirements established in the terms and conditions of contracts with NMSPH. This is particularly important because NMSPH may be associated with and held liable for the conduct of its suppliers. Suppliers shall be treated fairly and equally by NMSPH. In competition for contracts with NMSPH, all suppliers shall be confident that the selection process is predictable, equitable, transparent and verifiable.
Employees of NMSPH are responsible for ensuring that established guidelines and procedures are followed in the selection of partners and suppliers. If employees suspect or are aware of supplier conduct in breach of NMSPH’s Code of Ethics, they shall notify their immediate superior, in accordance with the routine for reporting concerns.
2.3 Use of intermediaries
Intermediaries comprise agents, sales representatives and other parties who act as links to third parties
in NMSPH’s business activities. Corruption can sometimes occur when companies use intermediaries to obtain public and private sector business or influence public or private sector actions on their behalf. NMSPH and its employees may be accountable if an illegal payment is made by an intermediary on behalf of NMSPH. It is preferred that intermediaries are not engaged. In some situations, however, it may be deemed necessary. In these instances, NMSPH will only engage intermediaries who apply the same standards of business conduct as NMSPH, whether in interaction with private sector clients, or government officials.
Employees of NMSPH shall obtain written approval from the Board of Directors in NMSPH for use of an intermediary.
Furthermore, all requirements established in the NMSPH Group Procedure for use of Intermediaries shall be satisfied and employees of NMSPH shall document this. Employees shall consult with their immediate superior or HR if they are in any doubt or if conduct in breach of NMSPH’s standards is suspected.
2.4 Fair competition and anti-trust legislation
Political and religious contributions are contributions of anything of value to support a political or
religious goal.
Contributions to industry associations or fees for memberships of organizations that serve business interests are not political contributions. NMSPH does not take political positions or associate itself with any religions or specific political movements. NMSPH does not make contributions to political parties, individual politicians or organizations directly affiliated with religions or political parties.
The political sympathies, religious affiliations and membership in groups, teams or associations of employees of NMSPH are irrelevant to the company. Employees of NMSPH are free to participate in religious and political activities on their own behalf without reference to NMSPH or their employment with NMSPH. Employees of NMSPH are expected to act impartially in their work and conduct on behalf of NMSPH. Furthermore, employees of NMSPH are expected to demonstrate loyalty to the company and not to damage NMSPH’s reputation, whether in private or at work.
3 INTEGRITY AND CONFLICTS OF INTEREST
3.1 Corruption and bribery
Corruption is the willingness to act dishonestly, and the abuse of entrusted power in return for money or personal gain. Corruption is a threat to business and to society as a whole, and NMSPH exercises zero tolerance towards all types of corruption.
Employees of NMSPH shall never accept or offer a bribe, kickback or facilitation payment. Knowing, or having reason to know about prohibited payments, are also considered violations of the Code of Ethics if these are not immediately reported to your immediate superior and the NMSPH Group HR. A bribe is an offer, a promise or any undue pecuniary or other advantage given, whether directly or through intermediaries, attempting to influence a decision to obtain or retain business or other improper advantage. A kickback is a form of negotiated bribery in which a commission, or a portion of the improper advantage, is paid to the party receiving the bribe in return for services rendered. Both a bribe and a kickback can take the form of non-monetary payments of anything of value, such as purchases at inflated prices and unreasonable entertainment. A facilitation payment is a small payment made to lower-level government or private sector employees, as a personal benefit to them, to secure or speed up the performance of a routine action which it is their duty to perform regardless of the payment. Facilitation payments are a form of corruption and are strictly prohibited.
Employees of NMSPH shall notify their immediate superior immediately if a payment is made that could be misinterpreted as a facilitation payment to ensure that such payments are properly documented and posted to the correct accounts. If a payment is demanded from you in order to avert an immediate threat to the life or health of any person, such payments are not prohibited, but must immediately be reported to your immediate superior and NMSPH HR.
3.2 Money laundering and fraud
Money laundering is a process whereby the identity and origin of illegally obtained money, such as bribes, are concealed or disguised. Fraud is the use of deception, trickery and breach of confidence to gain some unfair or dishonest advantage. NMSPH exercises zero tolerance towards all forms of money laundering and fraud.
Employees of NMSPH shall act and conduct business activities in compliance with relevant laws and regulations and using funds from legitimate sources. If employees suspect or are aware of conduct in breach of NMSPH’s standards regarding money laundering and fraud, they shall notify their immediate superior or Group HR, in accordance with the routine for reporting concerns.
3.3 Conflicts of interest
A conflict of interest exists when a party has professional obligations or personal or financial interests that could influence the objective exercise of her/his duties. Service to or from NMSPH shall never be subordinate to personal gain or advantage for any employee of NMSPH.
NMSPH employees shall not attempt to gain unfair advantages for NMSPH, themselves, friends or relatives. It is not permitted to take part in or attempt to influence decisions if this could lead to a conflict of interest, or if this could be interpreted as a conflict of interest. Employees of NMSPH who realize that a potential and unacceptable conflict of interest may arise, shall notify their immediate superior, in accordance with the routine for reporting concerns.
3.4 Gifts and benefits
Gifts and benefits include services, financial benefits or other privileges, and material things of value that are given, offered, solicited or received. The distinction between acceptable gifts, benefits, courtesies and corruption can be difficult to draw. NMSPH is committed to making business decisions objectively and solely on the basis of factors supporting fair competition. All gifts, benefits and courtesies offered or received with an obligation to provide any benefit or improper advantage in return, are prohibited at NMSPH.
Employees of NMSPH shall not offer or accept any cash, cash equivalents, or expensive and excessive gifts and courtesies. Employees of NMSPH are permitted to receive modest gifts but are urged to reflect upon whether receiving an offered gift will withstand public scrutiny. Employees of NMSPH shall consult with and notify their immediate superior or Group HR immediately if they are in any doubt or if conduct in breach of NMSPH’s standards is suspected.
3.5 Nepotism and Cronyism
Nepotism is favoritism shown to family members without regard to merit or qualification. Cronyism is the same shown to close friends. NMSPH is firmly opposed to nepotism and cronyism.
Employees of NMSPH shall not let personal relations affect decision-making processes, such as recruitment processes, and shall be responsible for evaluating their own independence in such processes.
Employees of NMSPH shall consult with and notify their immediate superior or HR if they are in any doubt or if conduct in breach of NMSPH’s standards is suspected.
3.6 External engagements
External engagements include positions, tasks, commissions, and memberships with or in other companies, entities, associations or organizations. Engagements in external positions by employees may be in conflict with or impair NMSPH. Any external engagements taken on by NMSPH employees must never become a hindrance to their ability to carry out duties and functions as NMSPH employees or undermine trust in NMSPH.
Employees of NMSPH shall not engage in activities that adversely affect or are in competition with NMSPH. It is the duty of each and every employee of NMSPH to inform their immediate superior of existing or potential external engagements that may have an impact on their work ability and capacity.
When external engagements have an impact on an employee’s work ability and capacity, prior written
approval shall be obtained from the employee’s immediate superior.
3.7 Confidentiality
Confidentiality is a set of rules or a commitment that limits access to or places restrictions on use or dissemination of certain types of information. At NMSPH, confidentiality requirements shall be regulated in employment contracts and in assignment contracts. NMSPH shall never disclose information received, produced or processed when this relates, for example, to intellectual property rights, technical- or business-sensitive or personal information, and there is a contractual obligation or other legitimate interest in avoiding the spread of information.
NMSPH shall protect all information in a professional manner, and as specified in contractual agreements.
Employees of NMSPH shall maintain professional secrecy regarding all information received, produced or processed in the course of their work. This includes being careful when discussing, transmitting or storing information under conditions or circumstances where information can be disclosed to unauthorized persons. Professional secrecy shall be respected after the period of employment in NMSPH is terminated.
3.8 Public information, communication and media
Public information comprises information disclosed to employees, stakeholders and the public. Media includes mass communication channels such as newspapers, periodicals, television, radio and social media.
All internal and external information from NMSPH shall be verifiable and correct and be based on high professional and ethical standards. When it is in NMSPH’s interest, NMSPH may participate in public debate. Only employees who are expressly authorized to do so may communicate with the media.
All employees of NMSPH engaged in producing or publishing public information are responsible for ensuring that the information is verifiable and correct.
Employees of NMSPH who discover or suspect inaccurate or false information shall notify their immediate superior, according to the routine for reporting concerns.
4 OUR ASSETS
4.1 Internal controls and authorities
Internal controls, including the authority to commit and represent NMSPH, are instruments that shall ensure that risks are minimized in business operations and processes, and ensure that these are run effectively. At NMSPH, decisions shall be made at the correct level in accordance with the applicable stipulated authorization.
An employee may only commit NMSPH if he/she is specifically authorized to do so and must always comply with the framework of authorization. Internal controls are a management responsibility, but each and every employee is responsible for following established procedures and guidelines. Employees of NMSPH shall consult with their immediate superior if they are in any doubt about their conduct.
4.2 Assets and intellectual property
All that is owned and controlled by NMSPH and which is held to create positive economic value are the properties and assets of NMSPH. Intellectual property comprises all professional creations conceived by employees of NMSPH, past and present.
Competent is one of NMSPH’s core values, and our main competitive advantage lies in our ability to apply our professional and interdisciplinary expertise to our client’s specific needs. NMSPH shall safeguard this ability by restricting unauthorized access to and use of time, financial assets, facilities, materials and intellectual property.
NMSPH respects the employee’s right to privacy. The business processes personal data to the extent necessary to carry out our obligations. NMSPH will always ensure proper and legal processing of personal data and will only use such information for expressly stated and legitimate purposes. Furthermore, employees and business partners undertake to keep confidential all businesssensitive and confidential information they are given access to through their work with or for NMSPH.
Authorized personnel can monitor and inspect equipment for safety, maintenance, cost management and regulatory compliance. Video surveillance (CCTV) can only be used for security reasons and on lawful basis. The person concerned must be informed about the basis for processing data. Employees shall protect the assets and intellectual property of NMSPH against loss, damage and abuse. In particular, information, IT systems and Internet services shall be utilized in the best interests of NMSPH, and not for personal purposes. This includes utilization of social media during working hours. Employees of NMSPH shall not violate the intellectual property of others.
4.3 Accounting and financial reporting
Accounting and financial reporting comprises the production of information that is reliable, transparent, consistent and timely about the economic resources under NMSPH’s control, and the financial activities of NMSPH. NMSPH’s accounting processes and annual financial reports shall be in accordance with the Finance and Integrated Reporting Policy, and relevant laws and regulations.
Employees of NMSPH shall follow the Finance and Integrated Reporting Policy when carrying out financial transactions, accounting and reporting processes, and register transactions with proper documentation to ensure that these are fully and correctly recorded.
5 IMPLEMENTATION AND MONITORING
5.1 Integrity due diligence
Integrity due diligence comprises research into the background, reputation, qualifications and conduct of a party with regard to laws, regulations and NMSPH’s ethical standards.
NMSPH shall perform integrity due diligence to ensure that the Group is not at risk of exposure to unwanted costs, reputational loss or criminal liability.
NMSPH shall avoid dealing with clients, contractors, suppliers and other business partners known to be, or reasonably suspected of, engaging in misconduct, except in cases where appropriate mitigating actions are put in place.
Employees of NMSPH shall perform and document integrity due diligence on joint venture members, major sub-suppliers, intermediaries and companies considered for acquisition in accordance with the NMSPH Procedure for Integrity Due Diligence. NMSPH employees who are in any doubt about whether integrity due diligence should be performed should consult with their immediate superior or HR.
5.2 Dilemma training
Dilemma training is a means of active training intended to increase awareness and reduce doubt about what is the ethically responsible course of action in situations that may compromise integrity. NMSPH shall promote openness, dialogue and cooperation to safeguard ethical conduct in all parts of the Group.
Employees of NMSPH shall periodically participate in and complete mandatory training initiatives. Employees are urged to actively and regularly consult with and discuss integrity dilemmas with their colleagues, immediate superior or HR.
5.3 Integrity reporting (whistleblowing)
Employees of NMSPH shall report concerns and infringements of laws, regulations or the Code of Ethics to their immediate superior. Failure to report concerns and infringements constitutes conduct in breach of the Code of Ethics. If reporting to the immediate superior is not possible or appropriate, the case shall be reported directly to the Internal Audit Department. Sanctions shall not be applied to employees who report concerns and infringements in good faith. Employees of NMSPH may voice concerns in privacy and confidence pending discrete and comprehensive follow-up.
5.4 Sanctions
NMSPH exercises zero tolerance towards compliance violations. Those who infringe laws, regulations or the Code of Ethics will be subject to consequences that reflect the violation. Disciplinary action may be taken in accordance with relevant legislation. Serious violations may lead to termination of employment. In the event of a violation, disciplinary and preventive measures will be implemented as deemed appropriate.
In the event that an employee is found guilty of a violation of anti- corruption and bribery laws, NMSPH will not pay or reimburse employees for fines or legal fees incurred in defending such charges.
Programs and Compliances
NMS acknowledges the value of continuous workplace learning including both internal and external training opportunities, along with other developmental initiatives. This approach is designed to ensure that all employees possess the essential skills for their current roles and are well-prepared for future advancement.
To assess these needs, NMS will perform a Training Needs Analysis (TNA) alongside the annual performance review. Any identified training and development requirements will be addressed through either in-house programs or external training opportunities for the participants.
Health and Wellbeing
All regular employees and project-based employees with 6 months of continuous service to the company are required to undergo an annual physical examination, using the HMO provided by the company.
NMS guarantees commitment with the programs of the government on the following: