Code of Conduct

1 About KMG

Karl M. Gulbrandsen was one of the first toolmakers to get educated at Elektrisk Bureau A/S. Karl M. Gulbrandsen Stansefabrikk A/S was established on June 19th 1917, and the production started in Fredensborgveien in Oslo. In 1933, the factory moved to larger premises in Møllergaten 34. When Karl M. retired, his son Trygve Gulbrandsen took over and ran the factory till 1973. Before the war, Elektrisk Bureau and Televerket were KMG’s primary costumers. After the war, this title went to Kongsberg Våpenfabrikk, Radionette, Tandberg Radiofabrikk, Philips Fabrikker, and Televerket. In 1973, Frank Nyland took over the factory, which at that time had about 30 employees. He had then worked at the factory since January 2nd, 1961. The factory’s primary work has always been punching of components and semi-finished products. In 1981, the factory moved all its production to Sagdalen, Skjærvaveien 8, 1466 Strømmen. The premises were expanded in 1985, and then again in 1987, to a total of 1,000m2. On September 1st 1994 KMG was bought by the brother Bjørn, Tom, and André Heramb. Bjørn and André had both completed their apprenticeship in tool making at KMG, and had attended NKI-Ingeniørhøgskolen for four years. In 1997-1998, a new hall and administrative space was built. Further expansion was done in 2008, and the factory now measures a total of 2,850m2. Karl M. Gulbrandsen Stansefabrikk A/S is one of Norway’s oldest and leading companies within its field. KMG also delivers products and services to Europe and Asia.

Today’s Business
KMG has 21 employees as of 2021, and large portions of the production are now automated. KMG has a regular network of 24 small and large external suppliers, who are our close partners regarding delivery, product development, and production. The annual turnover is at approximately 60 million Norwegian Nok. KMG is primarily a leading supplier of mass produced parts and CNC-punching/bending. Tool making and maintenance is also an important part of the company. This combination of services gives KMG a clear advantage compared to many other businesses in the same field.

As merely a subcontractor, however, KMG is vulnerable when larger companies move out of Norway, and go offshore in countries with lower production and labor costs. In the long term, these costs will probably get more equal, especially as Eastern European countries more fully integrate into the EU. It is therefore vital that the competence and knowledge that exist at companies like KMG stays in the country.

Objective
KMG’s overarching objective is to be a prominent supplier of mass produced punched parts, whilst being perceived as a professional supplier of quality products.
A direct consequence of this ambitious objective is that our customers receive goods of proper quality at the right time and at the right price. To make this possible, KMG always has to satisfy the customer desired requirements for their products. The customer is in focus.
This entails a close monitoring of all products by the use of quality surveillance and sample testing. One of KMG’s objectives is to ensure that all products and services that are being prepared by the company is of satisfactory quality, in accordance with the customer’s requirements, and that it is delivered to the customer the right way and at the right time.

2 Purpose and applicability

The purpose with this document is to stipulate the requirements of personal behavior and business practices. KMG has “OTTT” as its profile. We strive to live up to the following principles every day through our daily work:

Reputation (“Omdømme”)
Trust (“Tillit”)
Security (“Trygghet”)
Credibility (“Troverdighet”)

To develop a culture of sustainability based on our vision and our core principles, we expect transparency, honesty, and integrity – both internally at KMG and in contact with all of our customers. KMG ethical guidelines apply to board members, managers, chairmen, employees, contractors, and anyone else who are acting on behalf of KMG. We expect that every individual shall act as a role model by maintaining or improving KMG’s reputation. It is the organizations responsibility to ensure that employees are aware of and fulfill KMG’s ethical guidelines.
All employers shall have read and followed the ethical guidelines, and commit themselves to the principles as set out in this document. KMG shall comply with all applicable laws and regulations and act in an ethically and socially responsible manner. If there is a difference between such laws, regulations, and standards as outline in this code, KMG shall use the highest standards in accordance with current international, national, and local laws. In situations where employees represent KMG’s holdings in other partnerships, regardless of whether KMG is in a position of control or not, the ethical principles as put forward in this document shall be followed. KMG’s representatives shall also ask for and bring forward ethical guidelines that are fully compatible with KMG’s own guidelines in these partnerships.

3 Relationships within KMG

KMG’s owners, board members, managers, and employees shall protect and actively promote business related goals and interests within the company. The organization shall conduct its business by protect the interests of its employees, as well as maintaining their health, environment, and risk. The organization expects employees to exercise the highest level of professional integrity.

Visions and values
Our visions and values tell us who we want to be, what we want to achieve, and how we are going to achieve it. Everything we do is interconnected, and everything is going to contribute to achieving those goals. In order for everyone at the company to work towards the same goals and in the same direction, we developed a Quality and environment improvement plan with our overarching goals. “Our customers shall perceive KMG as their first choice – as an independent international punching specialist – that delivers effective construction, tool and production solutions to our customers all over the world – through engaged, enthusiastic, and customer-oriented employees.”

Our vision:
We want to improve the customer’s value chain
We create value together
We contribute to sustainable growth
We keep our promises
We recognize the costumer’s needs
We build long-lasting costumer relationships
We are credible and deliver quality

Our values:
We are heading in the same direction
We demonstrate compassion and respect
We collaborate across departments
We show curiosity towards others’ ideas
We show interest towards others expertise
We talk with, not about each other
We inspire one another

First choice
When you choose to work with us, we want you to feel like you are in good hands. We help you with choosing the best product, both in terms of quality and price; we help you find the best and most economical solution to use the product; and we ensure that your order is delivered at the right time. Our quality systems and employees ensure that you don’t have to worry about the construction, tools, and manufacturing solutions. We can also teach your employees how to use the product when necessary. To work with KMG means that the products work optimally, orders are delivered on time, and that you will receive worry-free construction, tool, and production solutions.

Engaged, enthusiastic, costumer-oriented employees
All of our employees continue to work to offer you our best products and our best service. We continuously educate and train our employees in order for them to have first-hand knowledge about technological and product-related development.

Technological company
KMG has for many years worked to hold a selection of modern and high-tech machinery, while continuously training its employees. KMG is actively engaged in the training and recruitment of youth to our field, and therefore wishes to be perceived as a technological company people wish to work at.

The certificates text
Development and production services of stamping tools and machines for the industry. Technological innovation and production of stamped and machined products and services. Selection of materials considering a life cycle perspective of products.

Processes
The figure below shows the overall processes that are performed in the company today. The core processes address the entire life cycle of products and services produced by the company. The process overview belongs to Karl M. Gulbrandsen Stansefabrikk A / S.

Quality policy ISO 9001
KMG’s quality policy shall be an integrated part of the company’s strategy, and shall therefore have top priority in all areas of activity. Quality shall be an integrated part of KMG’s business culture.

KMG’s management will actively communicate and follow up on the company’s policy and goals for quality. The company always complies with the current rules and regulations. This is being controlled and verified annually through safety inspections and revisions. KMG’s focus on quality can be traced all the way back to 1917. It is not possible to work with mass production for this many years without having a system to prevent quality from not reaching a set standard. In the last few years, however, KMG has taken a great leap to a new way to think about quality. Ten internal auditors are educated at the company, and they are recruited from all levels within the organization. The auditors have meetings in an audit forum where completed audits are discussed and new areas of improvement are revealed. The company aims at discovering potential weaknesses before rather than after the fact. The upper management commits itself to our three management systems of quality, environment, and working environment, which scope is determined and incorporated into our system.

Environmental policy ISO 14001
KMG is continuously working to reduce its environmental impact, and to increase its sustainability in all parts of the value chain by preventing and reducing resource use, emissions, and waste. KMG tries to comply with the balance between a sustainable environment, society, and economy. We attempt to steer or influence the way products and services are shaped, produced, distributed, and used, by using the lifecycle perspective which can prevent the environmental impact from being relocated to other stages of the products life. We also work to find more environmental substitutions where possible.

KMG wishes to receive financial and operational benefits through implementation of sustainable alternatives that strengthen the organizations market position. KMG uses REACH candidate list, RoHS directorate and Conflict minerals platform (Dodd-Frank Consumer Protection Act) with reference to the products and services we manufacture and deliver, as well as requesting all our external suppliers to obtain material and origin certificates to the extent that we consider it necessary. KMG will communicate environmental information to relevant customers.

To succeed in our work, we have implemented the following environmental policy:

KMG shall continuously strive to be better in dealings with the environment through:

First cleaning our side of the street
Fostering awareness for sustainability in our own organization
Making our external suppliers and customers environmental partners
Satisfy environmental requirements put forward by the government

Working environment policy ISO 45001
KMG expects every person who is acting as a representative of the organization to treat everyone with politeness and respect. KMG shall be a stimulating workplace with an inclusive work environment. Every individual shall refrain from any behavior that can have an unfavorable effect on the work environment and KMG. The organization strives to be a workplace where diversity is appreciated, and where employees have the opportunity to develop their own skills and talents. The organization prohibits the discrimination of employees based on age, gender, sex, sexual orientation, disability, race, nationality, political opinions, religion, and ethnic background, and any other basis for discrimination is prohibited. The organization does not tolerate harassment or degrading treatment in any form target towards any one of its employees. KMG is not engaged in, and does not tolerate, child labor. KMG is affiliated with Fellesordningen for AFP. When a company is affiliated with Fellesordningen, all employees are principally covered, whether they are organized with a labor union or not. This also applies to our seasonal workers, substitutes, and students/apprentices.

Strategy and marketing
KMG shall be a leading technological company in the field of punching and metalwork. KMG seeks to satisfy all requests for punched products, both nationally and internationally, by offering products of high value. KMG aims at offering products of high quality and thereby develop a profitable, effective, and binding relationship with both the supply and marketing side. The board will seek to maintain the group’s good earnings performance in coming years. The board, working together with the management, wishes to continue developing and customizing the company’s business system according to national and international requirements.
The board highlights the need for strategic forward-looking models for the company’s activities. This can include purchases, mergers, or other similar implements. The board works actively to secure financial and structural relationships for the company’s long term economic goals. By utilizing this market plan, we want to accumulate experience that will help us through new rounds of betting, which again will help us build a market plan which is better suited for the market we serve. No matter how good our market planning is, there will always be forces outside our control that determine how the market will look at any moment in time. But by planning to adjust, we get closer to success every time we bet. The market exists; we just have to make the market aware of our existence!

The company’s interest
All employees are required to promote legitimate interests in the company when an opportunity arises. Employees cannot take on personal opportunities that are discovered through the use of the company’s property, machinery, information, or position. Employees shall not perform actions nor have personal interests that makes it difficult for them to achieve their worker objective, and conflict of interest should be avoided as far as possible. The employee must not get involved in a relationship that can give rise to conflict with KMG’s interest. Conflict of interest can involve employees, contracted persons, external suppliers, competitors, or other closely related partners who are somehow connected to KMG. All business with closely related partner shall act according to the board’s adopted principles regarding such enterprises. In the case of a conflict of interest, the employee shall evaluate the case and report to his or her closes superior regarding the conflict.

Property and assets
KMG’s property and assets must be protected in an expedient way. The company’s assets shall only be used for legal purposes and only by legitimate employees or their deputies. This applies to normal assets, like for instance cars, machinery, equipment and assets like intellectual property and confidential information. All employees have a responsibility to protect the company from theft and loss, and possible theft, waste, or misuse of the company’s asset shall be reported by employees.
Employee’s use of IT-systems and internet in particular shall for the company’s needs and not personal interest. Information produced and saved on KMG’s IT-systems is considered to be the company’s property, and employees should maintain electronic files and archives in a clean and orderly way. Private use is only allowed to a limited extent, and information that can be considered illegal or unsuited shall under no circumstance be processed or downloaded.

Sensitive information and confidentiality
Employees have a duty of confidentiality, both by law and per written agreement. Each employee is responsible for keeping secret all aspects that can give an outsider unwarranted access to confidential information. The duty of confidentiality also applies after the conclusion of work and contract relations with KMG, and for as long as the information is considered to be sensitive or confidential.

4 Relationship with the customer

We wish to be the costumer’s intuitive first choice. If our customers are going to be happy, we need to have an inward-looking focus. All our relations, internal as well as external, shall be able to trust what we say. Our employees are our representatives, something we also wish that our customer and external suppliers will be. We draw and develop products and services in collaboration with the costumer, after specific requirements for sustainable solutions that meet the products purpose, use, and potential national and international environmental requirements. We empathize with relevant needs and expectations, and understand which of these become compliance obligations. All employees must strive to be honest, ethical, and fair with the company’s costumers, external suppliers, competitors, neighbors, the municipality and the authorities. KMG will seek short and long-term collaboration with the most important customers and external suppliers to remain informed and involved early on in important decision-making processes. Understanding and compliance between KMG’s goals and the customer’s expectations and needs are sought through improved communication. The objective is to better the planning and optimize the cost and service level.

Corruption and bribes
KMG disassociates itself from all forms of corruption, and will work actively to ensure that it does not occur in the company. Employees shall not offer illegal or inappropriate gifts, money, or other payment to gain business-related or personal benefits. Furthermore, employees shall not use middle men to achieve similar benefits that can be interpreted as corruption.
All payment must be in accordance with the company’s accounting and financial procedure for approval and registration of payments, and must be sent to the correct management level to be evaluated according to the company’s procedures and authority matrix.

Gifts, entertainment, and sponsorships
Employees are required to exercise caution and good judgment with regards to giving or accepting gifts and courtesies. Employees shall not, either directly or indirectly, accept gifts or other allowances if there is a reason to believe that its purpose is to influence decisions. Employees shall never ask for gifts or services for personal gain from any of KMG’s customers. Hospitality such as social events, meals, or entertainment can be accepted by an employee if it serves a clear purpose, and granted that the price for such hospitalities stay within a reasonable limit.

Relations with external suppliers
Employees at KMG shall treat external suppliers, including contracted consultants and advisors, impartially and fairly. Long-term cooperation with suppliers results in development, logistics, and material selection which again privileges the customer expectations and comply with the quality requirement. External suppliers are expected to follow ethical standards that comply with KMG’s standards.

External environment
KMG will act responsibly with ambition to reduce direct and indirect negative impacts on the external environment. KMG will follow relevant international and local laws and standards that aim at minimizing environmental impact. KMG displays high morale in regards to our societal responsibility.

5 Implementation and follow-up

Implementation
Managers are responsible for communicating the requirements of the ethical guidelines, and all employees must ensure that they are familiar with and accept these, as well as assuring that their work tasks are fulfilled in accordance with the requirements.

Monitoring
The organization is responsible for both promoting and supervising that the ethical guidelines are adhered to within its area of responsibility. Breaches of the ethical guidelines will not be tolerated, and can lead to internal disciplinary actions, termination, or prosecution.

Handling of breaches
If employees come across cases of breaches of KMG’s ethical guidelines, they have to report it immediately. Employees can report their concerns to their immediate supervisor, to the advisor, or to a board representative. If the employee is, for any reason, uncomfortable with this, they can report the case to their safety representative. They employee can then choose to remain anonymous.
The employee always has the right to alert supervisory authorities or other public authorities. Examples of such authorities include Arbeidstilsynet, Økokrim, Konkurransetilsynet, Datatilsynet, Helsetilsynet, or Statens forurensingstilsyn. Such suspicions or complaints can be reported confidentially and – if you find it necessary – anonymously, and will always be acceptable and legal.