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Code of Conduct



Code of Conduct

Nabucco Gas Pipeline International GmbH (“NIC”)

1 Introduction

NIC and its national subsidiaries (hereinafter referred to as “NIC”) are responsible for the development, construction and operation of the Nabucco Pipeline.

NIC has an Integrated Management System which is consistent with ISO standards.

This document summarises the basic principles governing all of NIC's actions and outlines how NIC aims to achieve its operational and economic goals. It defines rules of behaviour and underlying management policies to which NIC is committed in order to create a solid basis of trust for all its stakeholders through sound business ethics, and respect for environmental and community issues.

As a forward-looking company, NIC sets a high value on an active dialogue with employees, regional communities, governments, customers, shareholders, investors, interest-groups, the media, non-governmental organizations and the general public as a whole.

2 Scope of Application and Principles

NIC itself as well as NIC's employees, both permanent and temporary, contractors, subcontractors and all persons acting in NIC's name are committed to the principles outlined in this document. NIC’s managers bear special responsibility in this respect.

Moreover, NIC encourages all suppliers and customers to adopt these principles.

NIC will comply with all laws and regulations of the countries in which it operates as well as Nabucco Company Standards.

This Code of Conduct covers all areas of Corporate Responsibility: employee relations, human rights, health and safety, the environment, social issues, security as well as corporate governance.

Underlying basis for the core values set out in this document are the 10 principles of the United Nations Global Compact initiative:

  • Businesses should support and respect the protection of internationally proclaimed human rights and
  • make sure that they are not complicit in human rights abuses.
  • Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining, as well as,
  • the elimination of all forms of forced and compulsory labour,
  • the effective abolition of child labour, and
  • the elimination of discrimination in respect of employment and occupation.
  • Businesses should support a precautionary approach to environmental challenges,
  • undertake initiatives to promote greater environmental responsibility, and
  • encourage the development and diffusion of environmentally friendly technologies.
  • Businesses should work against corruption in all its forms, including extortion and bribery.

3 Society and employees

Responsible business practices towards society and employees are critical for sustaining the success of the Nabucco project.

NIC acts as a responsible Corporate Citizen towards the community on an international, national as well as regional level. As part of this commitment, NIC seeks to build and maintain a constructive dialogue with all groups holding a stake in the business activities of the Nabucco project. NIC will maintain a comments and complaints procedure according to internationally recognized best practice.

NIC respects cultural heritage issues along the Nabucco pipeline route and will address them appropriately.

NIC's employees and job applicants will not be discriminated against on grounds of age, race, faith or religion, skin colour, nationality, ethnic origin, political or other beliefs, sex, sexual orientation, disabilities or family status (Equal Opportunities Policy).

NIC is committed to selecting and recruiting employees who are best suited to the current and future requirements of the job and to supporting the progress of the Nabucco project. NIC expects all members of staff to take responsibility for the impact of their own behaviour and, in particular, to comply with all relevant laws and regulations.

Training and education of NIC’s employees are seen as an investment in the project.

The personal interests of NIC's employees and the interests of NIC are to remain strictly separated. A conflict of interest occurs when there might be a perception of personal and NIC's interests colliding (e.g. nepotism).

NIC will apply high occupational health and safety standards and emphasises the importance of health and safety for its staff. Every employee shall return home as healthy as coming to work,

4 Environment, health, safety

Initially, NIC will perform a full-scale environmental and social impact assessment according to EU directives, national standards and International Financial Institutions’ standards.

It is NIC's fundamental policy to fully comply with all applicable environmental, occupational health and safety laws and regulations in the countries where NIC operates. To achieve this, NIC will apply robust environmental and safety technologies and will promote environmental awareness to control and mitigate effects on the environment.

Hazards, effects and impact management will be at the core of NIC's Integrated Management System that is consistent with ISO 9001, ISO 14001 and ISO 18001.

5 Corporate Governance

NIC is committed to irreproachable integrity in all its business relations and does not tolerate bribery, money-laundering or corrupt business practices in any form.

NIC's business activities are guided by the commitment to provide efficient and transparent solutions to meet the needs of its customers.

Recognising that its shareholders are the prerequisite for the success of the Nabucco project, NIC's conduct towards its shareholders is governed by transparency and responsibility.

NIC's communication will be fair, accurate, comprehensible and as timely as possible.

With regard to politics, NIC is committed to neutrality and does not make any donations to political parties or to organisations and foundations which are closely associated with political parties. NIC will not employ or undertake consultancy agreements with individuals whose main occupation involves holding a public office or parliamentary seat.

In recognition of the commitment towards its stakeholders and their requirements, NIC welcomes constructive criticism and discussion with interest groups that are prepared to engage in an open and serious dialogue.

NIC will nominate a Compliance Officer who will introduce procedures that will allow it to monitor the adherence to the principles of this Code of Conduct (e.g. annual sign-off by senior management or a registrar for breaches). External and internal audits will be carried out on a regular basis.