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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
This document does not give customers, suppliers, competitors, shareholders or other people or entities any rights.
Updated: August 2022
Morrow is on a mission to safeguard our planet and our way of life for future generations. Every day we devote ourselves to delivering the most sustainable battery cells in the world. We take pride in noting that our batteries will ensure that large volumes of greenhouse gas emissions can be avoided by enabling customers to move away from fossil fuel. Morrow’s Environmental Policy offers guidance in our work and communicates our commitment.
Morrow utilises 100% renewable electricity. We are working towards zero emissions in our battery cell manufacturing (scope 1 and 2) and we will continuously strive to improve energy efficiency in our production.
Morrow’s scientist and engineers are developing commercially viable battery chemistries that eliminate the use of cobalt and reduce the use of nickel – thereby further bringing down greenhouse gas emissions in Morrow’s supply chain (scope 3). Moving forward, we want to further lessen emissions by enabling the use of new raw materials. We will also complement these gains by encouraging the processing of active battery materials closer to Morrow’s facilities and use of renewable energy. We will build long-term and comprehensive relations with all key suppliers so that we can collectively work towards more renewable energy and zero-emissions in the supply chain (scope 3).
Morrow is set to be an industry leader in low levels of production scrap and the re-use of production scrap. We are developing batteries that can be easily reused and recycled and, in collaboration with leading recyclers, we aim to establish on-site units for recycling batteries and battery material.
Morrow recognises that the mining of battery minerals and the refining of these carry risks of causing local environmental damage, including water contamination and biodiversity loss. We require suppliers to demonstrate excellent environmental management practices, including, where appropriate, certified systems for environmental management, such as the ISO14000 Environmental Management standard.
Morrow seeks to develop partnerships that can deliver zero-emission transport of battery cells to customers through use of electric trucks, zero-emission shipping and electric rail.
Morrow integrates environmental concerns when developing our new research and production facilities. Our construction work and buildings will be certified through the globally recognised BREEAM green building certification system, or equivalent. We want to minimize waste, enable reuse and resource sharing, recycle correctly and, if possible and reasonable, favour products made from recycled materials. We take every measure to avoid harmful discharges and emissions.
Morrow is on a mission to safeguard our planet and our way of life for future generations. Every day we devote ourselves to delivering the most sustainable battery cells in the world. We know that in order to do so we need to deliver outstanding business performance as well as excel in environmental and social stewardship, including vigorously working for upholding human rights and decent work practices across the battery value chain. This human rights and decent work policy offers guidance in our work and communicates our commitment.
Morrow’s employees will adhere to international human rights law and treat our colleagues, consultants, and externals equally and fairly. We will not accept the use of violence, retaliation, harassment, or discrimination and we support a good working environment for all. Morrow opposes all forms of human trafficking, forced labour and illicit forms of child labour in our operations and in our supply chain. We also commit ourselves to respecting the human rights of people in communities impacted by our activities including, but not limited to, the right to property, livelihood and the use of land and natural resources, security, health, and the right to water and sanitation.
Respecting human rights and upholding decent work practices form central parts of Morrow’s Code of Conduct and all employees at Morrow are requested to familiarize themselves and sign this code as they enter the Morrow workforce.
Morrow’s Supplier Code of Conduct stresses the importance of decent work and respect for human rights. All suppliers are requested to assess and sign this code when entering collaboration with Morrow.
Morrow has a robust due diligence procedure where we assess likely social and environmental risks in our own operations as well as in our supply chain. We take measures to mitigate against these through screening, documentation requests and dialogue. The need to uphold human rights forms a key part of this work. Our procedures include supplier site audits by Morrow staff or third-party agencies. Any breaches observed will trigger action from our side. Morrow’s top management and board supervises the due diligence process and insights from our due diligence work features at regular intervals on the board agenda.
Morrow supports a culture where concerns related to illegal or unethical conduct are reported and addressed either through manager in line or through whistleblowing channels. Similarly, as advised in the UN Guiding Principles on Business and Human Rights, any human rights grievances held externally by individuals or communities impacted by Morrow’s activities, including in our supply chain, may be put forward to Morrow’s General Counsel who will inform the Chair of the Board. Morrow will, in dialogue with stakeholders, explore ways of appropriately remedying any human rights breaches should they occur.
Morrow is ready to share information openly regarding human rights and decent work upon request from interested parties as per the Norwegian Transparency Act. Our suppliers pledge, when they sign our Supplier Code of Conduct, to assist with providing necessary information if prompted as per the Norwegian Transparency Act. Morrow reports, as of 2023, publicly on issues related to human rights and decent work on an annual basis as required in the Norwegian Transparency Act.
Beyond our reporting we also strive to engage and collaborate with stakeholders to learn more about potential human rights and decent work challenges that may appear in battery value chains. This includes dialogue with NGOs, trade unions, informal local associations, scholars, media and local authorities.
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 Supplier and Subcontractor Declaration which all potential suppliers and subcontractors are requested to comply with.
As a supplier or subcontractor to Morrow 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.
As a supplier or subcontractor to Morrow we will work to minimise negative impacts on the environment, taking into consideration the full life cycle of our products. We will work continuous to improve energy efficiency and minimize harmful discharge, emissions and waste production by means of recycling, re-using or substituting materials. We will comply with national environmental legislation and discharge permits.
As a supplier to Morrow, we are determined to comply with regulatory and customer requirements regarding the prohibition and restriction of substances, including hazardous substances and conflict materials. Therefore, we shall ensure that the goods/materials provided to Morrow are in compliance with requirements covered under the scope of all relevant regulations at the time of delivery. In particular, we will:
- Document to Morrow the origin of all materials and substances contained in our supply
- Report to Morrow any conflict materials as defined in applicable law
We will also inform Morrow accordingly if our knowledge to products or material is updated or corrected after delivery.
As a supplier to Morrow we recognise that the European Union is Morrow’s key market, and that the recently proposed EU battery regulation focus on key sustainability issues such as a batteries CO2 footprint, traceability of key materials used, and recycled content used in its production. We aim to support Morrow actively in meeting these and other relevant future regulatory requirements. We recognise that there is an increased focus on ensuring acceptable standards and practices are used in the mining of battery materials. As a supplier to Morrow we will seek to improve transparency and the sustainability of mining over time. We will evaluate the implementation of developing standards such as Initiative for Responsible Mining Assurance (IRMA) or equivalent standards, where relevant within our supply chain.
As a supplier or subcontractor to Morrow we will adhere to international human rights law and treat our employees and hired labour equally and fairly. We will not accept use of violence, retaliation, harassment or discrimination based on political view, age, gender, religion or other human right.
As a supplier or subcontractor to Morrow we will comply with local law and agreements regarding working hours. As a supplier or subcontractor to Morrow we will ensure that wages paid to employees and hired labour are considered fair and in compliance with local law and agreements.
As a supplier or subcontractor to Morrow we will neither engage or employ people against their own free will, nor will personnel be required to lodge “deposits” or identity papers upon commencing employment. As a supplier or subcontractor to Morrow we will not engage or employ people through any form of forced labour as defined by international labour standards including not employing children below the age of 15 for light work and 18 for hazardous tasks.
As a supplier or subcontractor to Morrow we recognise that our employees are entitled to be union members and to be represented in collective bargaining agreements. In countries where these rights are restricted, we will provide our employees with opportunities to influence their work
situation.
As a supplier or subcontractor to Morrow we will not, in order to obtain or retain business or other advantages in the conduct of business, offer, promise or give any undue advantages to a public official or a third party to make the official act or refrain from acting in relation to the performance of her/his official duties or to Morrow employees/representatives. This applies regardless of whether the advantage is offered directly or through an intermediary.
As a supplier or subcontractor to Morrow we will also follow international legislation on bribery and corruption, such as the US Foreign Corrupt Practices Act and the UK Bribery Act. We will also comply with sanctions as issued by UN, EU and similar regulatory bodies.
As a supplier or subcontractor to Morrow, we are aware that Morrow does not accept any gifts or hospitality from its suppliers, and we will therefore not offer gifts and other favours to Morrow, Morrow’s employees, representatives, owners, partners or anyone closely related, except for promotional items of minimal value, normally bearing a company logo.
Hospitality such as social events, meals or entertainment may be offered, provided there is a clear business reason. The costs related to such hospitality must be kept within reasonable limits. Travel, accommodation, and other expenses for the individual representing Morrow, will as amain rule be paid by Morrow, unless participation is agreed to being a service in return from Morrow under the contractual relationship. Gifts, hospitality, expenses, or other favours shall not be offered or received in connection with contract bidding, evaluation, or award.
As a supplier or subcontractor to Morrow we, and our employees, 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. 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 Morrow without undue delay.
As a supplier or subcontractor to Morrow we will promote that potential business partners, agents and intermediaries adopt the principles set forth in this Supplier and Subcontractor Declaration. We will also promote the implementation of the principles set forth in this Supplier Declaration towards own suppliers.
By signing this document, we confirm that we fulfil the requirements in the Supplier and Subcontractor Declaration. We agree that Morrow may audit our practices in the aforementioned areas to make sure we comply with the requirements. We are aware that where a deviation cannot be improved the business relations may be terminated. The Authorised signature below is from a representative with authority to act on behalf of our company.
