Statement of Business Ethics and Anti Corroption Policy

Company name: Nesskip Ltd.
Registration no.: 440474-0399
Address: Austurströnd 1
170 Seltjarnarnes
Iceland

The Statement

Nesskip is committed to the promotion of high standard ethical conduct in its business activities. We ensure that our employees are fully informed of the rules, regulations and compliance issues that apply to the work we undertake on behalf of any local or international clients.
All employees and Directors and anyone else working on behalf of Nesskip are required to comply with our ethical policies and procedures. We endeavour to collaborate with companies and organisations who share our commitment to ethical values and principles.

Nesskip will aim to ensure that all statements, communications and representations made to existing and prospective clients in project proposals, bid preparations and daily operations are accurate and truthful to the best of our knowledge. We will ensure that contracts and/or other form of agreements are implemented according to the agreed specifications, requirements and clauses. Nesskip will not take part in any business if any connection of bribes will be part of it or try to influence improperly decisions about awards of projects or jobs, nor will Nesskip condone such behavior in others. Nesskip will avoid any conflict of interest and will inform its clients and suppliers in beforehand of any potential conflict or interest that could arise during the implementation of contracts and/or general business activity.

Nesskip will only undertake assignments in our areas of expertise, where we can, to the best of our knowledge and ability, deliver efficient, effective and quality services to our clients. We will act with loyalty to our clients and respect the confidentiality or proprietary information we may acquire from partners and clients during the course of our normal business activities.

Nesskip will maintain accurate and complete company records related to all its business activities. All transactions between Nesskip and outside organisations and individuals will be accurately entered in our books in accordance with internationally accepted accounting practices and principles.

NESSKIP WILL NOT TAKE PART IN ANY ACTIVITIES THAT COULD DAMAGE ITS REPUTATION OR THAT OF CLIENTS ORGANISATIONS.

The Policy

In order to comply with the provision of international Acts related to the subject matter, Nesskip prohibits all employees, Directors and anyone else working on behalf of Nesskip from:

  • Offering, giving, soliciting or accepting any bribe, whether in cash or other inducement, to or from any person or company, in order to gain any commercial, contractual or regulatory advantage for Nesskip or anyone connected to Nesskip in a way which is unethical or in order to gain any personal advantage or otherwise. Any such payment or inducement may result in immediate dismissal for those involved in their payment or receipt.

This policy statement does not prohibit the following practices providing they are customary in a particular market, or are proportionate and are properly recorded:

  • Normal and appropriate hospitality, given or received.
  • The giving of an appropriate gift at a festival, ceremony or at another special time.

Nesskip recognises that market practice varies across countries and what is normal and acceptable in one place may not be in another. Nesskip also appreciates that to refuse a gift in certain circumstances and/or countries would cause offence to our clients or partners. Special care must be taken in accepting or giving any gift and/or entertainment from or to a public official and these are not permitted if by any way would create a real or perceived conflict of interest.

Nesskip will keep financial records and have appropriate internal controls in place which will provide evidence of the business reason for making any payments to third parties.

The prevention, detection and reporting of bribery and corruption is the responsibility of all employees and Directors and anyone else working on behalf of Nesskip. Any suspicion of bribery can be reported confidentially to the Chairman, Managing Director or Financial Manager of Nesskip. If anyone is in doubt as to whether a potential act constitutes bribery and/or corruption, the matter should be referred to one of the named in this paragraph.

The Directors are responsible for carrying out regular risk assessments through audits and for implementing and monitoring this policy. This policy has been discussed and introduced to all Nesskip employees and Directors, it is available to them in both written and electronic format and is accessible to all through the company’s website www.nesskip.is

Seltjarnarnes, September 2012

Oyving Gjerde
Chairman

Garðar Jóhannsson
Managing Director