Third-Party Code of Conduct

Principles and ethical standards

1. Introduction

Snøhetta AS, Snøhetta Oslo AS and Snøhetta Design AS (collectively referred to as "Snøhetta") are founded on humanistic values which are embodied throughout our companies from design, operations to our company culture. Social responsibility, integrity and ethical behaviour are the core building blocks of our business, and we are proud of the ethical practice we have established. Snøhetta believes that by working together with our suppliers and business partners and adhering to this Third-Party Code of Conduct (the "CoC"), we can continue to promote design as a positive force in the world throughout all of Snøhetta's operations.

This CoC defines the fundamental principles and ethical standards that make up the foundation of our companies’ value creation and applies to Snøhetta's business partners, suppliers and other entities Snøhetta has a contractual relationship with (commonly referred to as "Third Parties"). The CoC explains the minimum requirements that Snøhetta expects all Third Parties to meet to guarantee that actions are consistent with Snøhetta’s values and high ethical standards. Snøhetta expects all Third Parties to make their partners and suppliers aware of the CoC, and to ensure that also partners and suppliers comply with the CoC's requirements.

The CoC is based on the Universal Declaration of Human Rights, ILO's core conventions on fundamental principles and rights at work, the UN Sustainability Development Goals, the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. The CoC sets out minimum standards. Where other conventions and national laws and regulations relates to the same subject, the highest standard shall always prevail.

Snøhetta's CoC is owned and approved by the board of directors of Snøhetta AS, Snøhetta Oslo AS and Snøhetta Design AS. The CoC is not intended to replace the independent responsibilities and accountability Third Parties may have with regard to responsible business conduct.

2. Duty to act with integrity and in compliance with applicable rules, regulations and policies

All Third Parties commit to conduct their business operations in an ethical manner by maintaining a culture of integrity, honesty, transparency and compliance.

In addition to adherence to the CoC, all Third Parties shall comply with all applicable laws, rules, regulations and requirements in the provision of the products and/or services manufactured or provided to Snøhetta.

3 Social responsibility

3.1 Human and Labour rights 

Snøhetta is committed to and supports internationally proclaimed Human Rights and Labour Rights in accordance with the UN Guiding Principles on Business and Human Rights and the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

Snøhetta is committed to create working conditions that foster fair employment practices and where ethical conduct is recognized and valued. Snøhetta does not employ or contract child labour or any form of forced or compulsory labour. No form of discrimination is tolerated, including discrimination based on race, colour, gender, sexual orientation, age, disability, language, religion, employee representation, political or other opinions, national or social origin, property, birth or other status.

Snøhetta expects all Third Parties to be equally committed to the internationally recognized Human Rights and Labour Rights.

Third Parties shall ensure that all services, goods and other deliverables to Snøhetta shall be produced under conditions that are compatible with the requirements included in this Section 3. This includes ensuring compliance with this CoC in the Third Parties' supply chain.

For the purpose of the CoC, "Human Rights and Labour Rights" means the internationally recognized human rights and labour rights as expressed in international treaties, including but not limited to:

  • The Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights of 1966
  • The International Covenant on Civil and Political Rights of 1966
  • The ILO Conventions Nos. 29 and 105 (Forced Labour Conventions)
  • The ILO Conventions Nos. 87 and 98 (Freedom of Association, Right to Organise and Collective Bargaining)
  • The UN Convention on the Rights of the Child
  • The ILO Convention No. 138 (Minimum Age Convention)
  • The ILO Convention No. 182 (Worst Forms of Child Labour Convention)
  • The ILO Conventions Nos. 100 and 111 (Equal Remuneration and Discrimination)
  • The UN Convention on Discrimination against Women

3.2 Freedom of association

Third Parties shall ensure that all employees and workers have the right to associate or not to associate with any group as permitted by and in accordance with all applicable laws and freedom of association and collective bargaining. The Third Parties shall not interfere with or discriminate against workers choosing to take part in such free associations and collective bargaining. Where the right to freedom of association and collective bargaining is restricted under national law, suppliers will facilitate, not hinder, alternative means of independent and free association and bargaining.

3.3 Underage labour

Third Parties shall ensure that no underage labour has been used in the production or distribution of goods and services to Snøhetta. A child is any person under the minimum employment age according to the laws of the country where the product (or parts of) or services are sourced from, or in the absence of law under the minimum age for completed mandatory education.

3.4 Forced labour

Third Parties will not use or tolerate in their supply chain any form of slavery, servitude, indentured, bonded, involuntary, military or compulsory labour or any form of human trafficking.

All work must be conducted voluntarily and without threat of any penalty or sanctions.

No employee government issued identification, passports or work permits shall be retained by Third Parties as a condition of employment.

Workers’ rights to leave their workplace after their shift or to terminate their employment after reasonable notice and receive owed salary must be recognized by the supplier. This also applies to local or migrant employees.

3.5 Regular employment

Third Parties shall ensure that all of its employees and the workers in its supply chain, are entitled to a contract of employment that shall be written in a language they understand.

Obligations to employees under international conventions and national social security laws, and regulations arising from the regular employment relationship, shall not be avoided through the use of short-term contracting (such as contract labour, casual labour or day labour), sub suppliers or other labour relationships.

3.6 Working hours, wages and benefits

Third Parties shall ensure that working hours per week shall not exceed national legal standards. Workers shall always receive overtime pay, minimum in accordance with national legal standards.

Wages and benefits of the Third Parties' employees and/or workers, must meet legal minimums and industry standards without unauthorized deductions.

3.7 Health, safety and employee security

Snøhetta is committed to protecting all employees’ health and safety and strives to create and maintain safe, healthy and sustainable working conditions. Third Parties must provide safe and clean conditions for workers at sites of working and residential facilities. All workers shall have access to clean water.

Clear procedures or routines and sufficient training must be in place to ensure regulated occupational health, safety and wellbeing standards are adhered to.

3.8 Non-discrimination

Snøhetta expects that all Third Parties treat everyone with courtesy and respect, regardless of race, gender, national or social origin, disability, sexual orientation, religious belief etc. An inclusive and diverse work environment with equal opportunities for all workers is encouraged.

All employees must be treated fairly and not be discriminated in any form of employment.

Third Parties must not discriminate against any employee based on age, gender, sexual orientation, race, ethnicity, disability, religion, political affiliation, union membership, national origin, marital or pregnancy status or any other relevant grounds during any hiring or other employment practices.

Third Parties must commit to a workforce free of any harassment or threat of harassment. Any forms or threats of harassment, whether physical, mental, sexual or verbal, must be prohibited and not tolerated.

3.9 Safeguards to ensure respect for Human Rights and Labour Rights

Third Parties shall take effective measures to ensure that its performance under its contractual relationship with Snøhetta, respects Human Rights and Labour Rights consistent with the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

To this effect, Third Parties shall take all reasonable steps to avoid, or otherwise appropriately address or remedy, including through the establishment of appropriate grievance mechanisms, adverse impacts on Human Rights and Labour Rights which it or any of its affiliates, or any officer, director, agent, representative or employee of the Third Parties or such affiliates may cause or contribute to.

The Third Parties shall identify the risk of Human Rights and Labour Rights' violation in its own supply chain and shall on a risk-based approach actively seek to safeguard Human Rights and Labour Rights in the supply chain. The Third Parties shall use best efforts to include contractual clauses that set out the same requirements and obligations as this CoC in agreements with its suppliers.

The Third Parties shall promptly, and in writing, reply to any questions from Snøhetta related to its compliance with the obligations set out in this Section 3.

Third Parties agree to notify Snøhetta promptly in writing upon discovery of any instance where it fails to comply with this Section 3. In such event, the Third Parties shall promptly take adequate mitigating measures to minimize any adverse effect on Snøhetta and any potential breaches of Human Rights and Labour Rights.

4. Environment

4.1 Environmental responsibility

Snøhetta is committed to minimize the environmental impact of our operations and our designs. Snøhetta adheres to relevant local and internationally recognized standards and strives to minimize our environmental impact and continuously improve our environmental performance.

Third Parties shall be committed to operate in an environmentally responsible and efficient manner and comply with national and international laws and resolutions for the protection of the environment. Third Parties are committed to contribute to reduce the use of finite resources, including energy, water and raw materials, reduce harmful emissions to the environment, including waste, CO2 emissions and other air emissions and discharges to water.

4.2 Environmental management system

Third Parties shall have established an environmental management system which as a minimum shall consist of the following elements:

  • A system for the company’s environmental objective and environmental policy
  • Strategy for competence in the environmental field
  • Procedures for performing the contract in an environmentally sound manner

Third Parties may present the company’s quality or environmental management system according to ISO 14000, EMAS or other equivalent third party verified systems.

5. Ethical Business Conduct

5.1 Anti-Corruption

Snøhetta has zero tolerance for all forms of corruption. Third Parties shall comply with all laws concerning bribery, corruption, fraud and any other prohibited business practices.

No agent, affiliate, employee or other person acting on behalf of the Third Parties shall, directly or indirectly make or accept any contribution, bribe, rebate, payoff, influence payment, kickback or other payment to or from any person, private or public, regardless of form, whether in money, property or services (i) to obtain or provide favourable treatment in securing business, (ii) to pay or receive payment for favourable treatment for business secured, (iii) to obtain or provide special concessions or for special concessions already obtained or provided or (iv) for any other illegal or improper purpose.

Third Parties shall have implemented systems for internal control and organise its operations in a manner that prevents and discovers economic misconduct, including corruption, theft, embezzlement, fraud, breach of financial trust, favouritism and nepotism.

5.2 Gifts and business courtesies

Snøhetta will not accept gifts or other remuneration if there is reason to believe its purpose is to influence business decisions

Third Parties shall not, directly or indirectly, receive or offer gifts, including to Snøhetta employees or persons representing Snøhetta or anyone closely related to these, unless the gift is of insignificant value. Money shall under no circumstances be accepted or offered as a gift.

Business courtesies, such as social events, meals or entertainments may be accepted or offered if there is a legitimate business purpose involved, and the cost is kept within reasonable limits. Travel expenses for the individual representing the Third Parties shall be paid by the Third Parties. Business courtesies, expenses or gifts shall not be offered or received in situations of contract bidding, negotiations, or award.

5.3 Anti-Money laundering

Snøhetta has zero tolerance for all forms of money laundering. We will only conduct business with partners involved in legitimate business activities with funds derived from legitimate and traceable sources.

Third Parties shall take all reasonable steps to prevent and detect any illegal form of payments and prevent financial transactions, including transactions with Snøhetta, from being used by others to launder money.

5.4 Conflict of interest

A conflict of interest occurs when an individual's personal relationships or interests could influence, or could be perceived to influence, the individual's decision making when acting for the Third Parties.

Third Parties shall ensure that neither the company nor its directors and employees have any external positions or engagements that could represent a conflict of interest in relation to the Third Parties' work for Snøhetta.

5.5 Competition

Snøhetta supports fair and open competition in all markets. Third Parties shall refrain from any unfair competition under applicable anti-trust and competition laws and regulations and shall not enter into any anti-competitive agreements and, alone or in cooperation with other entities or individuals, such as illegal cooperation on pricing, illegal market sharing or any other behaviour that is in breach of applicable competition laws.

6. Sanctions and export control

Third Parties shall adhere to national and international foreign trade control laws pertaining to business transactions with countries, companies and persons (sanctions), and the transfer of goods and services, software or technology between countries (export controls). Third Parties shall require the same conduct for its suppliers and business partners.

Third Parties shall not import, export, re-export or transfer, directly or indirectly, any goods, services or technology contrary to the export control restrictions which is or may be imposed by any country or organisation, including Norway, the United Nations and the European Union, nor shall Third Parties undertake or fail to perform any act which would cause a breach of such controls or restrictions. Third Parties shall ensure that appropriate measures for marking and handling such goods, services and technology are established and maintained.

7 Intellectual property and data protection

7.1 Intellectual property

Third Parties shall respect Snøhetta’s intellectual property and take all reasonable steps to safeguard Snøhetta's intellectual property from unauthorized access, sharing and illegitimate use. Intellectual property must not be made available to external parties without prior authorization and a signed confidentiality agreement from such parties.

7.2 Confidentiality

Snøhetta respects and safeguards information that is of a sensitive nature or classified as confidential by Snøhetta or external parties.

Any confidential information disclosed to Third Parties or obtained through the relationship with Snøhetta shall be handled in accordance with all applicable laws and regulations protecting confidentiality, including the regulations of a relevant contractual relationship with Snøhetta. Third Parties shall protect all confidential information against unauthorised use, disclosure, loss, damage or destruction.

The duty of confidentiality also applies after the conclusion of a contractual relationship with Snøhetta for as long as the information is confidential.

7.3 Personal data and privacy

All processing of personal data shall be subject to the care and awareness required according to laws and regulations. Third Parties' processing of personal data obtained from Snøhetta through the relationship with Snøhetta shall be limited to what is needed for operational purposes, efficient customer care, relevant commercial activities, and proper administration of human resources.

8. Ensuring compliance with the code of conduct

8.1 Control measures to ensure compliance

Third Parties must be able to demonstrate compliance with the CoC. This includes documented evidence and a right for Snøhetta, or a third party appointed by Snøhetta, to conduct audits or other action it considers appropriate to investigate compliance, e.g. facility inspections, reviews of Third Parties’ records or business practices, and conduction of employee interviews.

In case of a breach of the CoC, failure to promptly inform Snøhetta of a known or suspected breach, or a failure to cooperate in audits and other investigative measures, Snøhetta may suspend or terminate their contractual relationship with the Third Party for cause and without compensation to the Third Party.

8.2 Reporting concerns

Third Parties are invited to report any area of concern to Snøhetta. If Third Parties identify severe adverse impacts that they either cause, contribute to or are linked to, they must immediately inform Snøhetta and propose a plan to remedy the impact.

Third Parties must ensure whistle-blower confidentiality and sufficient protection to safeguard that there is no retaliation against employees or partners who participate in such programs in good faith or otherwise speaks up about non-compliance of this CoC.

8.3 Contact information and questions

Any reporting concerns or other questions that Snøhetta's Third Parties may have regarding the CoC shall be addressed to