Compliance and Reporting Mechanism

Responsibilities of the company and employees' compliance with the Code of Conduct is a requirement throughout NCC - from the Executive Management Team via managers at all levels to the individual employee.

Within their specific area of responsibility, all managers have an obligation to ensure that employees and business partners are given information about the contents of the Code of Conduct and our requirement for compliance with this. NCC managers must set a good example at all times.

Reporting mechanism – NCC Compass

This Code of Conduct has been adopted by NCC AB's Board of Directors, and the company monitors compliance with the Code on an ongoing basis as a natural part of its operations. To help employees to comply with the code, NCC has created NCC Compass – a program that provides guidance on issues concerning gifts, business entertainment, conflicts of interest and competition law.

Together, the Code of Conduct and NCC Compass point us in the right direction. If any employee is uncertain how to act, specially trained employees – known as navigators – are available throughout the Group for consultation. Employees are obliged to report any breaches of the Code of Conduct of which they become aware.

Tell Me is a reporting mechanism that enables NCC employees to bring possible breaches of the Code of Conduct or applicable laws to the attention of senior management. This facility is also available to other stakeholders such as suppliers and other business partners via NCC's external website. All reports are taken seriously and investigated. All reports are treated in confidence, and NCC will not tolerate any form of retaliation against employees for making 'good faith' reports of violations of the Code of Conduct or relevant laws.

NCC employees found to be in breach of the Code of Conduct will be subject to disciplinary measures. NCC will take action against business partners found to be in contravention of our guidelines, and the relationship will be terminated in the event of repeated or serious breaches.

Examples:

  • You as an employee have to report if you see violation of national law or breaches of NCC Code of Conduct.
  • We do want external stakeholders to report if and when they see violation of national law breaches of NCC Code of Conduct.
  • You do not have to tolerate investigation or retaliations that jeopardize your employment at NCC because you have raised the subject that we have to follow NCC Code of Conduct, NCC policies or if you have reported an incident.

Compliance resources 

Gunar Bäckström, NCC Group Compliance Officer 
gunnar.backstrom@ncc.se

Kaj Juhlin, NCC Group Security Officer 
kaj.Juhlin@ncc.se

Christina Lindbäck, NCC Corporate Sustainability Senior Vice President christina.lindback@ncc.se 

Håkan Broman, NCC Board of Directors (and audit Committee) hakan.broman@ncc.se