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Code of conduct

Overarching commitment to a safe and respectful work environment


SIA Nordic Homes (“NH”) is committed to providing a safe, respectful working environment for all individuals with whom we interact. The following Code of Conduct is based on the underlying philosophy that we respect every individual’s right to dignity, privacy, integrity and safety as well as their right to equal and fair treatment in the work environment.


Classification of individuals inside and outside the organization who are covered by the Code


This Code of Conduct applies to and protects the following individuals in the workplace: existing and prospective employees and contractors of NH; employees and contractors in existing and prospective portfolio companies; existing and prospective investors in NH; existing and prospective vendors and service providers to NH.


Where the Code is enforced


This Code of Conduct is enforced where NH work is performed or discussed, including offices, conferences, forums, meetings and social events.


Definitions and examples of unacceptable behavior


Discrimination: All individuals are treated equally in NH and we do not tolerate discrimination based on age, gender, race, religion, sexual orientation, political beliefs, citizenship, marital status, family status, disability or any additional ground protected by law. This commitment applies to all interactions with individuals doing business with NH, including recruitment, investment, divesture, promotion, training, transfer, discipline, termination, compensation, benefits and participation in all activities, events and programs sponsored by NH.


Workplace Harassment: Workplace harassment is defined as unwelcome conduct or comments, either directly against an individual in the workplace or made in a general manner that contributes to an environment that is hostile or lacking respect or dignity. Examples of workplace harassment include:

  • insulting, intimidating, demeaning, annoying, embarrassing or otherwise offensive behavior;

  • inappropriate or unwelcome focus or comments on a person’s physical characteristics or appearance;

  • bullying and cyberbullying;

  • isolation and shunning, gossip, rumors, negative blogging, insults, name-calling;

  • slamming doors, throwing objects and physical contact and;

  • any other harassment that affects an individual’s dignity or psychological or physical integrity


Sexual Harassment: Sexual harassment is defined as engaging in unwelcome sexual solicitation, conversation or advances against an individual or made in a general manner and any resulting grant or denial of benefits to an individual as a result of the response to the solicitation, conversation or advance. Examples of sexual harassment include:

  • unwelcome sexual advances;

  • requests for sexual favors;

  • verbal or physical conduct of a sexual nature including sexual jokes, graphic spoken commentary about a person’s body, derogatory or degrading remarks, leering, whistling, unwanted physical contact, or assault;

  • inquiries or comments about an individual’s sex life; and

  • displaying sexually offensive material


Workplace Violence: Workplace violence is defined as the attempted or actual exercise of physical force against an individual in the workplace that could cause discomfort, pain or injury. The definition also includes threats to exercise physical force and domestic violence that occurs in the workplace. Examples of workplace violence include:

  • Hitting, punching, slapping, poking or other means of unwanted physical contact or assault

  • Challenging an individual to fight

  • Engaging in unwelcome horseplay

  • Bringing weapons into the workplace

  • Threatening an individual verbally or in writing

  • Stalking or intimidating


Mechanisms for reporting infractions


NH is committed to an efficient and safe process for reporting infractions. We support the following:

  • The right of individuals to report incidents without fear of negative consequences or retribution including protection from retaliatory actions

  • The timely reporting of all incidents, without a set statute of limitations. In the case of violence, individuals should call police and/or first responders immediately.

  • The right of a victim to confront their harasser (where comfortable) without the threat of retribution and make clear behavior is not to be tolerated

  • A clear line of reporting incidents directly to a manager, or if the manager is source of the problem, to a Compliance officer, Edgars Līvmanis,, of NCH Riga branch, located at “Mezaparka Offices” Kelnes Street 1, Riga, LV-1014, Latvia or to Chairman of the Board of SIA Nordic homes, Kaspars Šenvalds,

  • An alternative official or investigator if there is deemed to be any conflict of interest with the Compliance officer of NCH Riga of Chairman of the Board of NH.

Expectations for disciplinary action on substantiated claims


A range of disciplinary actions for substantiated claims can include mandatory training, demotion, suspension, and termination. The disciplinary action will be determined by the management of Nordic Homes.


Expectations for confidentiality


The investigation of each complaint will be handled in as confidential a manner as possible. While the investigation is ongoing, the alleged victim, the accused, and any witnesses should not discuss the complaint, incident or the investigation with other individuals not involved in the matter. Investigators will not give out identifying information about persons involved unless such disclosure is necessary to conduct a full and fair investigation, take corrective action, or otherwise required by law. All records of the investigation, if any, will be kept confidential.

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