NIPA Capital B.V. and subsidiaries, including all directly or indirectly controlled companies (together referred to as “NIPA”), are performing their day-to-day business following certain core values and adhere to the highest standards of integrity, professionalism and ethics. We feel an obligation to perform our business based on these key values.

 

Our core values are:

 

  • Integrity

 

  • Transparency

 

  • Creativity

 

  • Teamwork

 

  • Sustainability

 

  • Credibility

 

 

From our employees, we expect that they are familiar with our Code of Conduct and respect NIPA’s core values.

By performing our business worldwide, we would like to work together with business partners who join us in being an example in adhering to integrity, professionalism, and ethics.

 

This Code of Conduct defines the expectations we have from our business partners. We insist that our business partners acknowledge and demonstrate the same level of commitment to our core values and comply with all applicable local statuary laws, directives regulations and rules.

 

This Code of Conduct may be modified from time to time by NIPA. Any changes to this Code of Conduct will be made available to the business partners and published on our website.

1. Our expectations

 

This Code of Conduct is not intended to be an exhaustive list of rules but sets out certain key principles which NIPA expects its business partners to adhere to. This Code of Conduct should be interpreted in the context of local applicable laws and regulations.

 

Compliance with local laws and regulations

 

Each business partner needs to comply with all applicable local laws and regulations. Being compliant with laws, rules and regulations is for us an essential basic principle of responsible business conduct.

 

This contains among others:

 

  • No involvement in bribery, corruption, or any other fraudulent behavior.

  • No involvement in any unlawful activities that could lead to a certain business decision.

  • No involvement in any activities that could result in money laundering or financing of terrorism or criminal activities.

  • No behavior that could result in misusing the confidence of other people.

  • No behavior that leads to any breach of applicable competition law.

 

Integrity

 

The business partner must perform its duties and responsibilities with the highest degree of integrity.

We expect our business partner to perform its work with honesty, responsibility and transparency and refraining from any illegal activity.

 

Conflicts of interest

 

Any conflicts of interest with personal matters or other business activities, that could affect our business relation should be avoided. Should such conflicts nevertheless occur, they must be resolved in accordance with the applicable law. Conflicts must be dealt with openly and transparently. 

 

Compliance with capital markets regulations

 

The business partner is committed to comply with all applicable capital markets and securities trading regulations. The business partner will not disclose any inside information with respect to NIPA to any third party until such disclosure is approved by NIPA or released to the public. Insider information must never be used for private trading of securities or shared with third parties, including friends and family members.

NIPA’s (intellectual) property

 

The business partner will protect the intellectual property of NIPA. No material of NIPA, including confidential information and business secrets, will be shared, or forwarded to unauthorized persons within or outside the business partner, without NIPA prior approval. The business partner will return to NIPA all property, including information and documents on request. All such material will stay NIPA’s property.

 

Data protection and information and security

 

The protection of personal data in particular of NIPA’s employees, investors, customers and suppliers, is of particular importance to us.

 

Collecting and processing personal data will only be done when this is permitted by law, for e.g. upon prior valid consent of the person concerned, when the collection of personal data is required by law or when it is necessary to perform work related tasks. The business partner will safeguard and treat confidential all personal information disclosed to your company.

 

Sustainability and protection of environment and climate

 

For NIPA, sustainability, environmental and climate protection, and resource efficiency are key to corporate objectives. The business partner will do its utmost regarding sustainability and protection of environment and climate and will adhere to all applicable laws and regulations.

Health and safety

 

NIPA is committed to providing the highest standard in respect of safety and employee and/or tenant protection.

The business partner shall promote safety and health in their work environment and will comply with health, safety and environmental regulations and takes reasonable precaution measures against any accidents.

 

Human and labor rights

 

The business partner will respect internationally recognized human rights and support their observance. All forms of forced and child labor will be rejected. The right for appropriate and equal compensation is recognized for all employees. Payments shall comply with the respective national legal standards.

 

Equal Treatment and non-discrimination

A culture of equal opportunities at the workplace and mutual trust and respect is of great importance for us. We expect that our business partner promotes equal opportunities and prevent discrimination in the recruitment, promotion, training, and development of employees. The business partner acknowledge that Vivion promotes more women on senior management positions and encourage such approach.

 

Behavior in public and communications

 

We respect the right to free speech and the protection of personal rights and privacy.

NIPA is built on strong values: Reliability and honesty, credibility, and integrity. We therefore attach great importance to be open and truthful in our reporting and communications on NIPA’s business transactions to investors, employees, customers, business partners, the public and government institutions.

We expect our business partner to follow us in this approach.

 

The business partner shall ensure that internal and external reports, records, and other documents comply with the applicable legal rules and standards and are therefore complete and correct at all times and issued in good time and in accordance with system requirements.

 

2. Implementation

 

The business partner has a duty to report any known or suspected violation of this Code of Conduct, including any violation of laws, regulations and rules could harm NIPA, the business partner itself or the working relationship between NIPA and the business partner. All reporting will be handled with sensitivity and discretion. Failure to comply with this Code of Conduct or any applicable laws and regulations, could result in immediately terminating the business relationship with the business partner. In such event the facts and circumstances of each situation will be considered. 

 

We expect all business partners to adhere to this Code of Conduct. Each business partner is legally and ethically responsible for the actions of its employees.