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 a manager or anonymously via the independent external whistleblowing channel available at MorrowBatteries - Home (integrityline.com). Whistleblowing may also 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.
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. This mineral policy offers guidance in our work and communicates our commitment.
Morrow strives 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, labour rights abuses, caused environmental damage or provided funding for conflicts.
Morrow is 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 report if additional relevant knowledge regarding the material emerges upon delivery. We expect the highest standards on the environment as well as human rights and decent work to be upheld across the supply chain.
All of Morrow’s suppliers need to exercise due diligence and uphold a system of control and transparency over their supply chain, including and especially companies in the mining and mining related sectors, which traditionally have been supply chains particularly prone to social and environmental risk. This includes expectations to establishing a chain of custody and upholding a traceability system that allows for the identification of upstream actors and provides an understanding of which mining sites materials emerge from and where they are further processed before reaching Morrow’s production site.
Mining companies that form part of Morrow’s supply chain must operate according to the highest social and environmental standards and mining operators must be able to document this though the Initiative for Responsible Mining Assurance (IRMA) certification or similar national or international standards. Alternatively, an ability to comprehensively document high levels of social and environmental standards through auditing procedures may, in exceptional cases, also be acceptable.
Conflict-affected and high-risk areas typically have the presence of armed conflict, widespread violence or there are other risks of harm to people. Armed conflict may, as defined by the OECD, take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may consist of wars of liberation, or insurgencies and civil wars. High- risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence. These areas are often characterised by widespread human rights abuses and violations of national or international law.
Morrow seeks to identify and eliminate minerals from conflict affected and high-risk areas in our supply chain. Morrow maintains a focus on the formally labelled conflict minerals tin, tantalum, tungsten and gold (3TGs), but is also highly mindful of other minerals, such as cobalt, that may stem from conflict-affected areas.
Morrow expects suppliers to provide the company with detailed information if there is a risk that minerals may stem from conflict-affected and high-risk areas. The OECD conflict reporting template offers useful guidance on relevant information, alongside the information requirements listed in Morrow’s Supplier contract.
Morrow takes note that particular regions in otherwise stable countries may, to some degree, be high-risk areas. This includes mining and refining regions such as the Xinjiang province in China or the disputed Western Sahara territory that formally is part of Morocco. Upholding a system of control and transparency over minerals that may stem from these types of areas is particularly important and we expect conflict-affected and high-risk areas in otherwise stable countries to be flagged in suppliers’ dialogue with Morrow.
Morrow is gravely concerned by the high biodiversity loss rates that may be attributed to some land-based mining practices, including nickel mining. Current standards and practices may not be sufficient to guard against negative local environmental impact, including biodiversity loss. Morrow seeks to collaborate and work with partners that aim to further enhance the way mining projects are implemented and explore ways to further strengthen conservation and restoration practices in this sector.
Morrow wants to see a just global burden sharing as net-zero industries expands and more minerals are required. Mining practices need to be expanded across the globe, and not only in countries that traditionally have formed part of the global south. More ambitious environmental approaches are called for in a range of mining locations, including in the Nordic region, in Europe and globally.
Morrow has currently no plans to source minerals from deep-sea mining and will not engage in this sector unless it can be proven that deep-sea mining can be conducted sustainably. Morrow’s position is a precautionary one: More knowledge is needed on the potential negative impact that deep-sea mining may have on marine biodiversity and ecosystems. Morrow also notes that as of yet there is an absence of well-established and proven impact-avoidance and mitigation techniques and this further bars Morrow from engaging in the sector.
This policy should be consulted in conjunction with Morrow’s Environmental policy, Morrow’s Human rights and decent work policy as well as Morrow’s Supplier and subcontractor declaration.
