Code of Conduct

Naviair's Code of Conduct applies to all companies providing products and/or services to Naviair. It includes suppliers (and subcontractors) and the Company's consultants, collectively referred to as "Suppliers" below. Naviair's Suppliers are responsible for ensuring that their employees and the employees of their subcontractors who are involved in the supply of services to Naviair have read, understood and agree to abide by the principles of this Code of Conduct.

The supplier shall have an established process for monitoring compliance with Naviair's Code of Conduct and shall be responsible for following up on subcontractors' compliance.

This Code of Conduct is an essential part of the contractual relationship between Naviair and the supplier and breach thereof may result in termination of the collaboration with the supplier.


The Code of Conduct describes the minimum standards suppliers must meet, even when they are stricter than local legislation.

All Naviair suppliers are required to respect and comply with the laws and regulations of the countries in which they do business.

Suppliers must also comply with the principles of the UN Global Compact, the UN Universal Declaration of Human Rights, the OECD Anti-Bribery Convention and the ILO Conventions in force at any time, which Denmark has ratified, including:

- Forced labour (ILO Conventions Nos 29 and 105)
- No discrimination in employment (ILO Conventions 100 and 111)
- Minimum age for admission to employment and prohibition and immediate action for the elimination of the worst forms of child labour (ILO Conventions Nos 138 and 182)
- Safe and healthy working environment (ILO Convention No. 155); and
- Freedom of association and the right to collective bargaining (ILO Conventions Nos 87, 98 and 135) within the framework of existing legislation.

The supplier undertakes to refrain from all forms of corruption as defined in principle 10 of the UN Global Compact.

Corruption means active corruption as defined in Article 3 of the Convention on the fight against corruption involving officials of the European Communities or officials of Member States of the European Union and Article 2(1) of Council Framework Decision 2003/568/JHA of 22 July 2003 on combating corruption in the private sector (Official Journal 2003 L 192, p. 54). Bribery shall be as defined by the national law of the Member State or the country of origin of the Supplier or of the country where the Supplier is established.

The supplier undertakes to refrain from bribing or accepting bribery or otherwise unduly influencing public officials, courts and/or private parties.

Suppliers must never use gifts, benefits or other forms of unauthorised compensation in their dealings with customers, suppliers, authorities or other decision-makers to obtain or retain business.

MONEY LAUNDERING Suppliers must never participate in, promote or otherwise support activities based on money laundering.

Suppliers must always comply with applicable competition law. Suppliers shall not exchange information or enter into agreements with competitors, customers or suppliers in a way that risks obstructing, restricting or distorting competition in the market.

The supplier shall contribute to the protection of nature and the environment so that the development of society can take place on a sustainable basis, respecting human living conditions and the conservation of wildlife. This is specifically intended to ensure that the Supplier, when providing services to Naviair, seeks in good faith:

- To prevent and control pollution of air, water, soil and subsoil, as well as vibration and noise disturbances.
- To avoid materials and methods that pose risks to the environment when other available and suitable alternatives exist.
- To apply hygienically justified processes of importance for the environment and for humans.
- To reduce the use and waste of raw materials and other resources, and to promote the use of cleaner technologies.
- To promote recycling and reduce problems associated with waste disposal. Emphasis shall be placed on what is achievable through the use of best available technologies, including less polluting raw materials, processes and equipment and the best available pollution abatement measures.

The Supplier thus undertakes to contribute to the protection of nature and the environment, as defined in principles 7, 8 and 9 of the UN Global Compact, in the performance of the Framework Contract.

The Supplier shall ensure that employees of the Supplier and any subcontractors who assist in the performance of an agreement with Naviair are guaranteed wages (including special benefits), working hours and other working conditions which are not less favourable than those applicable to work of the same kind under a collective agreement concluded by the most representative social partners in Denmark in the relevant trade area and which applies throughout the Danish territory. "Contributing to the performance of an agreement with Naviair" means work performed in Denmark for the purpose of performing an agreement between Naviair and the Supplier.

The supplier and any subcontractors must ensure that the employees are informed of the conditions arising from the employment clause.

Suppliers must respect the right of workers to organise in unions of their choice and to bargain collectively.

No employee shall be subjected to discrimination or harassment on the grounds of age, sex, religion, sexual orientation, disability, political opinion or ethnic origin.

During working hours, the Supplier's employees involved in the delivery to Naviair shall refrain from the use of alcohol or intoxicating substances.

The supplier must work consciously and systematically to create a good working environment, both physically and psycho-socially. This is to achieve a safe and healthy workplace. Employees must receive appropriate health, safety and training information, including - but not limited to - arrangements for the safe evacuation of buildings and the correct handling and labelling of chemicals and machinery.

Suppliers are expected to pay particular attention to safeguarding confidential information received from Naviair and that this is not disclosed to unauthorised parties.

In cases where the Supplier's employees come into contact with confidential information (about Naviair or Naviair's customers), this information must be protected and must not be disclosed to unauthorised parties. Supplier's employees shall not access, copy, reproduce or otherwise process any other information beyond what is required to provide agreed services to Naviair.

The Supplier is obliged to accept random audits of compliance with this Code of Conduct.

For identified non-compliance with the Code of Conduct, the supplier shall submit a corrective action plan to be approved by Naviair. In this context, Naviair may decide to apply enhanced surveillance for a period of time. Repeated or serious breaches of the Code of Conduct principles shall be considered as a material breach of the contractual relationship, which may lead to termination of the collaboration with the supplier.

If the Supplier becomes aware of any breach of the obligations under Naviair's Code of Conduct, or if legal action is taken against the Supplier for such breach in relation to the obligations, the Supplier shall immediately, on its own initiative, notify Naviair.

All suppliers are also encouraged to report suspected violations of applicable laws and regulations or non-compliance with the Code of Conduct. This should be reported to Naviair's contact person for the agreement to which the supplier is party, or via Naviair Whistleblower Scheme on Naviair website. Reports can be submitted anonymously. All reports are investigated. Naviair does not accept any form of discrimination or other negative consequences for suppliers/individuals who have reported suspected non-compliance in good faith.

All suppliers can, at any time, contact their contact person at Naviair if they have any doubts or questions about the above.