PROCUREMENT POLICY


Procurement Principles


The fundamental governing principles to which all personnel engaged in Procurement on behalf of the Company must adhere to are:

  • Transparency and Openness;
  • Business Integrity;
  • Efficiency and Sustainability
  • Fairness and Non-discrimination;
  • Competition and Antitrust;
  • Accountability;
  • Diversity, Inclusion and Local Procurement Content; and
  • Labour and Human Rights as generally described within this section.


Transparency and Openness


Throughout the Procurement sourcing process, relevant information regarding the process itself and the Company’s expectations of Suppliers shall be clearly communicated as may be reasonably practicable.


Business Integrity


Procurement of Goods and Services shall be completed responsibly and with a high degree of integrity in compliance with Company policies and applicable laws, rules and regulations. This includes using Company funds, resources, assets and authority in accordance with the intended official purposes, free from:

  • Corruption including bribery, “kickbacks� favouritism, nepotism, cronyism, and clientelism;
  • Fraud and theft of resources;
  • Conflict of interest, collusion, abuse and manipulation of information;
  • Discriminatory treatment; and
  • Waste and abuse of organizational resources.


Fairness and Non-discrimination


All Suppliers shall:

  • Not be discriminated against based on race, religion, color, sex, national origin, age or disability or by giving preferential treatment to anyone over another;
  • Be considered on a merit and compliance basis for all offers, bids, quotes and proposals;
  • Have the same evaluation criteria applied to all prospective Suppliers for a particular Procurement sourcing process; and
  • Be provided a forum for complaint.


Competition and Antitrust


To ensure competitive responses, qualified Suppliers shall be invited to participate in the bidding process and will be evaluated against each other on the same criteria.


Accountability


All personnel engaged in Procurement on behalf of the Company are accountable for their actions and decisions and are responsible to ensure compliance to this Policy.


Diversity, Inclusion and Local Procurement Content


We recognize that having a diverse and inclusive workforce and supply chain aligns with our core values, makes the Company stronger and is critical to achieving current and future strategic objectives. We are committed to becoming a company that supports diversity in age, gender, ethnicity, culture, religion, disability and sexual orientation and will seek to realize this commitment. All personnel engaged in procurement on behalf of Norgeo LLC will drive supplier diversity and supply chain accountability by taking measures to ensure the participation and competitiveness of diverse and local suppliers and by encouraging the same behaviors and commitments among our suppliers.


Labor and Human Rights


The Company acknowledges and respect workers’ rights to enter into collective bargaining relationships and will not do business with Suppliers that impose excessive working hours or poor or unsafe working conditions on their employees. Norgeo LLC will not knowingly do or continue to do business with Suppliers that violate the United Nations’ Universal Declaration of Human Rights or the International Labor Organization’s Fundamental Conventions.


Risk Management


Procurement must be prepared to address risks that may cause disruptions in the Company’s supply chain, from sourcing through implementation of Goods and Services in our operations. Key risk considerations regarding the safety, reliability, quality, availability, schedule, and cost of supply must be examined and mitigated as reasonably practicable through sound Procurement processes and resultant contracts. These considerations do not remove any requirement for a risk assessment or other risk mitigation.