Communication on Progress
Global Compact
Stockholm, 22 November, 2011

Confirming our commitment
The NCC approach is based on our values; Honesty, Respect, Trust, Focus, Simplicity and Responsibility.
NCC Group is a signatory to the UN Global Compact since January 20, 2010. This is the first Communication on Progress Report issued by NCC. Through this report NCC expresses our continued support for and our commitment to the UN Global Compact’s ten principles with respect to human rights, labor, environment, and anti-corruption.
We honor the principles of transparency on NCC’s overall sustainability performance and support of the Global Compact ten principles, and regularly disclose information to our stakeholders.
The areas covered by Global Compact’s ten principles are also covered by NCC’s Code of Conduct, which guides NCC’s business operations. It is necessary that NCC act in a responsible way in order to gain trust from our stakeholders.
An important part of our efforts is to continue our support of the ten Global Compact principles in the NCC organization, which we do through the implementation of our Code of Conduct.
Transparency
NCC believes that we need to be transparent about our commitment, ambitions and performance. In 2011 NCC issued a sustainability report for 2010. The report is developed in accordance with the GRI Guidelines for voluntary reporting on sustainability information, G3 and application level C. The sustainability report is part of NCC’s Annual report 2010 (pages 30-37) and the complete GRI table is presented on our website (http://www.ncc.se/en/About-NCC/The-environment/GRI-index/).
The NCC sustainability report 2010 highlights our most material sustainability issues and how they are managed within the Group. Sustainability and responsibility are viewed from two perspectives within the NCC group; the risk management perspective and the opportunity perspective.
We welcome you to take part of our sustainability report in order to learn more about the NCC values, our Code of Conduct, our approach, and our most important issues and how these are managed as well as the NCC sustainability performance in 2010.
The NCC Annual Report 2010 is presented on our website (http://www.ncc.se/Global/About_NCC/ir/arsredovisning/NCC_AR10_eng.pdf)

Peter Wågström
President and CEO
NCC AB

NCC supports and respects international conventions concerning human rights. The NCC approach is based on our values; Honesty, Respect, Trust, Focus, Simplicity and Responsibility, in which human rights are included. The areas covered by Global Compact’s ten principles are also covered by NCC’s Code of Conduct, which guides NCC’s business operations. In 2003, we adopted our first Code of Conduct, which regularly is being updated according to needs. The latest update was done in 2011. It is necessary that NCC act in a responsible way in order to gain trust from our stakeholders.

Every manager has an obligation, within his or her area of responsibility, to ensure that employees are informed of the contents of NCC’s Code of Conduct and the need for compliance with it. Managers within NCC must always set a good example. Each employee is encouraged to report any disrespectful behaviour (“whistle-blower”).

To monitor the adherence with our policies and objectives regarding e.g. human rights, we conduct an annual study, the Human Capital Index survey (HKI). Employees from all countries and business areas participate and anonymously answer questions regarding values, daily work, immediate manager, working climate discrimination, health- and safety issues and personal development. Results are accumulated for the whole company, as well as for business areas and specific departments. The results are presented and used as a tool for further dialogue and development of our company.

NCC supports and respects international conventions concerning human rights, which includes compliance with labour laws in the respective country where we operate. NCC does not accept any form of mental or physical punishment, threat of punishment, discrimination in employment opportunities or work, bullying at the workplace, or sexual or other harassment, forced labour or other types of involuntary work. NCC values a healthy balance between work and leisure and works actively to ensure that the employees achieve this. The operations and the projects in which NCC is involved shall be characterized by a safe, healthy and hygienic work environment. Our health and safety work includes a zero vision when it comes to work-related accidents.
Obligations toward employees pursuant to national laws and agreements on social security must be respected and followed. Pay and other benefits shall at least fulfil national laws, applicable collective and/or local agreements and the generally accepted standard for the industry.
Child labour is not permitted. Employees must have turned at least 15 years of age or have reached the age for completing compulsory schooling, if that is higher than 15 years.
Employees’ rights to organize themselves in optional employee organizations and to negotiate collectively must be respected. Employee representatives must be given the opportunity to perform their duties.

Every manager has an obligation, within his or her area of responsibility, to ensure that employees are informed of the contents of NCC’s Code of Conduct and the need for compliance with it. Managers within NCC must always set a good example. Each employee is encouraged to report any disrespectful behaviour (“whistle-blower”).
As a member of the Business Social Compliance Initiative (BSCI), NCC supports this quality assurance organisation in the work with conducting social audits to build ethical supply chains. For significant international suppliers, NCC demands they have passed the BSCI audit.

To monitor the adherence with our policies and objectives regarding e.g. human rights, we conduct an annual study, the Human Capital Index survey (HKI). Employees from all countries and business areas participate and anonymously answer questions regarding values, daily work, immediate manager, working climate discrimination, health- and safety issues and personal development. Results are accumulated for the whole company, as well as for business areas and specific departments. The results are presented and used as a tool for further dialogue and development of our company. All managers with a group large enough to guarantee the individuals anonymity will receive the results from the survey.
NCC measures the gender-distribution on all our markets, and within the recruitment policy, equality and diversity policy, as well as in HR´s business plan NCC encourages a high diversity of gender, ethnicity and age.
Through BSCI´s supplier audits we safeguard that our suppliers follow our code of conduct in regard to the principles that are relevant in a case to case basis.

In all of its operations, NCC strives continuously to reduce climate impact, focusing primarily on the energy and transport areas, and to conform to or surpass the requirements of national or international regulations or agreements concerning the reduction of emissions and discharges to air, land and water.
In all of its operations, NCC must reduce its use of harmful substances, ensure that the handling of waste is performed in a safe and environmentally compatible manner, and contribute to increase recycling.

Through NCC´s Management system there is a clear process with precautionary approach to environmental challenges. Each project makes risk analysis prior to project start where environmental risks are analysed and actions and measures are taken to avoid impact.
NCC measures our Carbon footprint and reports our sustainability efforts in accordance with the guidelines of the Global Reporting Initiative (GRI) at Level C. (http://www.ncc.se/sv/OM-NCC/Miljo-och-energi/gri-index/)
NCC has a strong focus on research and development, with a separate Research and Development department as well as cooperation with different universities and institutes. Examples of NCC projects that promote environmentally friendly technologies are low energy buildings and Green Asphalt with low carbon dioxide emissions.

The environmental performance is monitored and evaluated through a carbon footprint measurement, through the GRI-index reporting as well as both internal and external audits.

NCC does not permit any form of pricing collaboration, cartel building or abuse of its market dominance, and supports in all phases of its operations correct and unrestricted competition in regard to bids, tenders, procurement and purchasing.
Employees are not permitted to work or participate indirectly in business activities for an organization that competes/engages in business with NCC. Employees are not permitted to engage in activities that could lead to conflicts of interest, or to exploit relations with business partners for personal gain. This includes providing or accepting personal gifts or services of a value exceeding a specified level, or participating in expenses-paid activities beyond normal business requirements. It also includes requesting or providing any form of promise connected to the acceptance of gifts. All managers are to participate in training against corruption.
While NCC does not subscribe to any party-political position, employees are encouraged to take an active interest in social issues provided they adhere to normal rules regarding partiality.

Over 3000 managers have been educated in the contents of our Code of Conduct in general and business ethics in particular. NCC employees are obligated to inform their immediate superior of any business activity that the employee conducts outside the NCC Group. Each employee is encouraged to report any disrespectful behaviour (“whistle-blower”).

In addition to the routines implemented, as set out above, all business areas are obligate to annually conduct a compliance check in relation to our Code of Conduct.