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Code of Conduct



Morrow’s vision is to be the preferred partner for solutions in the battery industry through living our values. Being a responsible societal actor is of key importance towards this vision. As a tool in this respect, Morrow has prepared this Code of Conduct and Ethical guidelines that employees, consultants, partners and board of directors are required to comply with.

1 Compliance with laws and regulations

We will comply with applicable laws and regulations. We will align our conduct with the Ten Principles of the UN Global Compact and the UN Declaration of Human Rights, and with other international laws and codes of conduct where such are applicable.

2 Minimizing negative environmental impacts

We will work to minimise negative impacts on the environment, taking into consideration the full life cycle of our products. We will continuously strive to improve energy efficiency and minimize harmful discharge, emissions, and waste production by means of recycling, re-using or substituting materials. We will also comply with relevant international and national environmental legislation and discharge permits.

3 Compliance in metal and material sourcing

We strive to only source minerals and materials that have been mined and traded in such a way that they have not contributed to human rights abuses, caused environmental damage or provided funding for conflicts. This means that we are determined to comply with regulatory and customer requirements as well as key international guidelines regarding the prohibition and restriction of substances, including hazardous substances and minerals from conflict prone areas. We shall ensure that materials provided to Morrow are following requirements covered under the scope of all relevant regulations at the time of delivery and also report if additional relevant knowledge regarding the material emerges upon delivery.

4 Respect of human rights and good working environment

We will adhere to international human rights law and treat our colleagues, consultants, and externals equally and fairly. We will not accept use of violence, retaliation, harassment, or discrimination and support a good working environment for all.

5 Report illegal or unethical behaviour

We will support a culture where concerns related to illegal or unethical conduct are reported and addressed either through manager in line or to the whistleblowing channels. Whistleblowing may be reported to General Counsel, who will treat the information strictly confidential and may offer anonymity to the person raising a concern or reporting. A whistleblowing situation related to top management should be reported directly to the Chair of the Board.

6 Make sound decisions and seek advice if in doubt

We recognise that employees are entitled to take decisions according to a set Authority Matrix. We will ensure decisions also are made according to set procedures and in a professional manner. We will seek advice through colleague or manager if in doubt, and document the work related hereto.

7 Adhering to financial compliance and international sanctions

To obtain or retain business or other advantages in the conduct of business, we will not offer, promise, or give any undue advantages to anyone. This applies regardless of whether the advantage is offered directly or through an intermediary. We will also in our work follow international legislation on bribery and corruption, such as the US Foreign Corrupt Practices Act and the UK Bribery Act. In addition, we will comply with sanctions as issued by UN, EU, and similar regulatory bodies.


8 Showing due care if offering gifts, hospitality, or refund of expenses

As Morrow employees and related parties, we should not give or accept any gifts or favour of monetary value from suppliers or third parties, except for promotional items of minimal value, normally bearing a company logo.

Hospitality such as social events, meals or entertainment may be accepted, provided there is a clear business reason for doing so. The costs related to such hospitality must be kept within reasonable limits. Travel, accommodation, and other expenses for the individual representing Morrow, will as a main rule be paid by Morrow, unless participation is agreed to being a service in return from Morrow under a contractual relationship.

Gifts, hospitality, expenses, or other favours shall not be offered or received in connection with contract bidding, evaluation, or award. CFO or General Counsel may advise on the matter.

9 Securing conduct in the interest of Morrow

We will not take part in or seek to influence any decision in circumstances that can give rise to an actual or perceived conflict of interest for Morrow. Such circumstances may be a business interest or a personal interest in the subject matter – economically or otherwise – directly or through someone closely related.

If we become aware of potential conflict of interest, we will notify and seek advice with direct manager without undue delay.

10 Doing business the right way

We will promote that other employees, customers, partners, agents and intermediary adopt the principles set forth in this Code of Conduct. We will also promote the implementation of the principles for supporting policies and guidelines such as Authority Matrix, Supplier Code of Conduct, Procurement Policy, Employee Handbook, and Sales Governance.


Declaration of responsibility
This document does not give customers, suppliers, competitors, shareholders or other people or entities any rights.

Updated: August 2022

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