Code of Conduct

Working Environment

• Nera Networks is committed to providing a work environment that is positive and professional.
• Employees shall behave with respect and integrity towards anyone they encounter in their work.
• Any behaviour that can be perceived as degrading, discriminating or threatening will not be tolerated.

Human Worth

• Nera Networks supports the international human rights as outlined by the United Nations declaration and conventions.
• Employees shall not in any way cause or contribute to the violation or circumvention of human rights.

Loyalty, Impartiality and Conflict of Interests

• Nera Networks respects the individual employee's right to a private life and private interests, but demands openness and loyalty to the Group and the Group's interests.
• Employees shall not take actions nor have interests that make it difficult to perform your work objectively or effectively.
• Service to Nera Networks should never be subordinated for personal gain and advantage.
• Conflicts of interest should, wherever possible, be avoided.

Confidentiality

• Employees has a duty of confidentiality by law and written agreement.
• Confidentiality shall be maintained for all corporate and other matters that could provide third parties unauthorized access to confidential information.

Intellectual Property

• Intellectual property such as know-how, technology, design, methodology, concepts, ideas and drawings are protected and in the interest of the Nera Networks Group.
• Intellectual property rights of others shall be respected and violation of such avoided.

Property and Assets

• Nera Networks' property and assets, e.g. buildings and equipment, shall be managed and safeguarded in an appropriate manner.
• Employees shall observe the Group's security requirements concerning access to and use of the group's facilities.

Nature and Physical Environment
Nera Networks shall encourage environmental protection, by minimizing environmental damage and by developing, promoting and utilizing environmentally friendly technology.

Information that may Affect the Stock Price
As a subsidiary of a publicly listed company, Nera Networks is subject to strict rules concerning the handling of non-public information that may affect the market price of Eltek shares and other financial instruments issued by Eltek ASA.

• Employees are responsible to prevent access to non-public information by unauthorized persons.
• Employees that have stock-price sensitive information is prohibited to trade in the financial instrument before the information has been made public or ceases to be sensitive.

Media Communication
Communication with the media, the public and the financial markets shall be done only by authorized personnel and in accordance with established guidelines and routines and satisfy the regulations and practice applicable to publicly listed companies.

Expertise and Authority
All decisions shall be made at the appropriate level in accordance with the applicable regulations concerning authority.

Relations with Customers, Suppliers, Competitors and Public Authorities

• Customers shall be met with insight, respect and understanding.
• Customer's personal information shall be protected in accordance with the relevant laws on protection of personal data.
• Suppliers shall be treated impartially and justly.
• Suppliers in competition for contracts with the Group shall at all times be able to trust the Group's selection processes.
• Competitors shall be met in an honest and professional manner.
• Public authorities shall be met in an appropriate and open manner.

Competition

• Employees shall under no circumstances be part of any breach of general or special competition regulations, such as illegal cooperation on pricing, illegal market sharing or any other behaviour that is in breach of relevant competition laws.
• Nera Networks is firmly opposed to all forms of corruption.
• Employees are not allowed to offer or accept illegal or inappropriate monetary gifts or other remuneration in order to achieve business or personal advantages.

Gifts and Business Courtesies
Employees must exercise caution in relation to offering or accepting gifts and business courtesies. It is not allowed to accept gifts or other remuneration if there is reason to believe that its purpose is to influence business decisions.

Money Laundering
Nera Networks is firmly opposed to all forms of money laundering and shall take steps to prevent its financial transactions from being used by others to launder money.
See also the “Anti-Corruption policy”.

Relations to Employees’ Private Interests and Actions

• Employees of Nera Networks are not allowed to be employed or work as a contractor for another company without prior written permission from Nera Networks.
• Engagements in external duties and positions are positive, but their scope or type must not affect your working relationship with Nera Networks or come into conflict with Nera Networks’ business interests.
• Employees who take part in political activities will be granted leave from their work in accordance with the law and any agreements.
• Employees must ensure that the technology made available by the Company is used in a manner consistent with the Company’s practices and policies.

Reporting and Accountability

• All suspicions of infringements of Nera Networks’ policies and procedures or ethical guidelines, must be reported immediately.
• Failure to report infringements is itself a breach of this Code.
• Nera Networks will not implement sanctions in any form against any employee who informs individuals in positions of responsibility or the Audit Committee about possible infringements of Nera Networks’ policies and procedures, ethical guidelines, applicable laws or other blameworthy circumstances in Nera Networks’ business. These individuals shall take all actions they consider appropriate to investigate any violations reported.
  
  If a violation has occurred, Nera Networks will take such disciplinary or preventive action, as it deems appropriate.