Code of Conduct

Our Code at a Glance Our Code guides how we work For every Northstar employee, across our offices and frontline locations. This fictional gallery example shows how a Code of Conduct can help people make sound, respectful choices. The authoritative Code, local requirements, and acknowledgment are in Policy Hub. The essentials A few practical principles to keep in view. Treat people with respect Make work interactions professional, fair, and free from harassment or intimidation. Do not dismiss or target someone because of who they are. Raise conduct that makes work unsafe or disrespectful. Protect fair decisions Notice when a personal relationship, financial interest, or outside role could affect—or appear to affect—a work decision. Pause and disclose a possible conflict before the decision. Ask for guidance when the connection is unclear. Check before accepting A gift or invitation may be subject to rules that depend on location, role, and business context. Check the applicable Policy Hub policy before responding. Pause when an offer is tied to a pending decision. Go to the topic you need These pages explain common situations and practical next steps. Respect at Work Everyday respect, examples, and reporting options. Conflicts of Interest Recognize a possible conflict and prepare to disclose it. Gifts & Hospitality Pause, check the relevant rules, and seek guidance. Ethical Dilemmas Work through fictional examples and discussion questions. How to Raise a Concern See the app route and general expectations after reporting. Authoritative Code and acknowledgment Need to raise a concern? Speak Up is Northstar’s named app for raising a concern. Open it through your organization’s approved app access; this site does not submit a report. Confirm Speak Up availability, access methods, and urgent-response wording for each relevant location before publishing. Use Speak Up and follow the options available to you there. For immediate danger or urgent safety needs, use the established local emergency or safety response route. Respect at Work Respect is part of the work Every employee should be able to work without harassment, intimidation, or degrading treatment. In this fictional Northstar example, respectful conduct means treating colleagues with dignity, listening without personal attacks, and keeping disagreement focused on the work. Harassment and other disrespectful conduct are not acceptable. The applicable published policy and local reporting routes determine the formal definitions and process. If something feels unsafe or you are unsure whether it crosses a policy line, do not wait for certainty before seeking help. Use an available reporting option or Speak Up, according to your local process. Notice the behavior, not just the intent These examples are illustrative, not a complete policy definition. A person’s stated intent does not by itself settle the impact or whether conduct breaches an applicable policy. Respectful disagreement A colleague challenges a proposal by explaining the work concern and inviting a response. Address the decision or evidence, not a person’s identity. Give colleagues room to speak and respond. Conduct to raise A colleague repeatedly makes personal remarks after being asked to stop, or uses threats, slurs, or humiliating comments. Do not excuse repeated conduct as a joke. Raise the concern through an available route. If you experience or witness a concern Use an appropriate route; do not put yourself at risk. Address immediate safety If anyone is in immediate danger, move to a safer place if possible and use the established local emergency or safety response route. Note what you observed When appropriate, write down the date, location, people involved, what happened, and any witnesses. Share only information relevant to the concern. Raise it through an available route Use Speak Up or another reporting route confirmed for your location and situation. The applicable policy describes the formal process. Choose a reporting route Speak Up is the named app for raising a concern. Confirm its access methods and any local alternatives before publishing this page. For the authoritative Respect at Work policy and acknowledgment where required, use Policy Hub. Open Speak Up through your organization’s approved app access. This page explains the topic; it does not receive or submit reports. Read the published policy Conflicts of Interest Recognize a possible conflict early A personal connection may matter when it could affect—or appear to affect—a work decision. A personal relationship, financial interest, or outside role can create a possible conflict if it overlaps with a decision you influence. A possible conflict is not a finding of wrongdoing. Raise it before the decision through the approved confidential route described by the applicable policy. This page helps you recognize a situation and prepare. It does not submit, approve, or decide a disclosure. The applicable policy and designated reviewer’s route govern real disclosures. Compare the situation with your work These fictional examples are prompts for checking the applicable policy, not final determinations. A relative’s business is in play A close relative owns or works for a company being considered for a contract, hire, or purchase you can influence. Identify whether you evaluate, recommend, or approve the decision. Raise the possible conflict before the decision. An outside role overlaps A board seat, side business, consulting engagement, or investment touches the same customers, suppliers, or decisions as your job. Note which work decisions the role could touch. Disclose the role even if you have not acted on it. No apparent work connection A hobby, community volunteer role, or investment in an unrelated field may have no connection to your work decisions. Check the applicable policy for any category it requires you to disclose. Ask the designated reviewer if the connection is unclear. Prepare to raise a possible conflict Identify the connection Describe the relationship, financial interest, or outside role and the people or organizations involved. Name the work decision Explain whether you evaluate, recommend, approve, or otherwise influence the related decision, and when that decision is expected. Use the approved route before acting Follow the applicable policy’s confidential disclosure route and ask its designated reviewer for guidance. Do not rely on this page to decide whether a conflict exists. Find the disclosure policy and route Gifts & Hospitality Pause before you accept Check the approved Gifts and Hospitality policy for your location, role, and business context before responding. Pause and seek the policy’s designated guidance if an offer is connected to a work decision, unusually timed, involves a public official or regulated activity, or you cannot tell which rule applies. This fictional example sets no monetary limits, grants no approval, and creates no entitlement. The applicable published policy determines what is permitted and what must be recorded. Compare the situation, then check the local rule Illustrative examples only; the applicable approved policy determines what is permitted and what must be recorded. A supplier offers a branded notebook at an open industry event; no related business decision is pending. Check the applicable local policy; disclose or record the offer if it requires it. Do not assume a modest-looking item is automatically permitted. A supplier invites you to dinner while a renewal involving that supplier is being evaluated. Pause and ask the policy’s designated approver before responding. The pending decision and timing make this different from an ordinary event. An invitation involves a public official or regulated activity. Pause and consult the applicable specialist route before responding. Do not rely on this general guide to determine the rule. Before you respond Pause Do not accept or promise anything while you are unsure which rule applies. Check the applicable policy Use Policy Hub to find the published Gifts and Hospitality policy for your location, role, and business context. Ask before acting when needed If the offer is tied to a decision or the policy does not clearly resolve the situation, contact the designated guidance route named in that policy. Use the authoritative policy Ethical Dilemmas: Scenarios Discuss the dilemma before deciding A fictional practice scenario for employees and team discussions. At fictional Northstar Works, a project lead is preparing a supplier renewal recommendation when the supplier offers complimentary seats at a professional conference. Use the scenario to identify competing considerations and questions to check before acting. It is a learning example, not company policy, legal advice, or a decision about a real matter. For a live situation, use the applicable policy and approved advice routes. What is pulling in different directions? Both perspectives raise questions; neither settles the decision. Separate the stated facts from assumptions. Possible work benefit The conference could provide relevant professional learning and a chance to discuss project needs with the supplier. The lead may believe the offer would not change their recommendation. What legitimate work purpose might the offer serve? What alternatives could meet that purpose without accepting the offer? Timing and fair process The offer arrives while the lead is preparing a renewal recommendation. Even without intended influence, acceptance could raise questions about impartiality and confidence in the process. Who could reasonably question the recommendation or process? What approved guidance is needed before any response? Questions to discuss Use these prompts to practice careful reasoning, not to reach an unsupported approval. What facts are known, and what is still unknown? Known: a supplier made an offer while a renewal recommendation is being prepared. Unknown: the applicable local rules, the offer’s conditions, who else is involved, and whether an approved exception or review process applies. Could the offer affect—or appear to affect—the decision? Consider timing, the lead’s role, the supplier relationship, and how the process could appear to colleagues or other suppliers. Do not assume the lead’s stated intent resolves those questions. What should the lead do next? Pause, check the applicable Gifts and Hospitality policy, and ask its designated guidance route before responding. If a personal interest or relationship is also involved, check the conflict-of-interest policy. Review the related topics Use the relevant page to prepare for checking the authoritative policy. Gifts & Hospitality Pause and check the applicable rules for an offer. Conflicts of Interest Recognize a personal interest that may overlap with a work decision. How to Raise a Concern You can raise a concern Use Speak Up or another reporting route confirmed for your location and situation. In this fictional Northstar gallery example, employees are encouraged to raise good-faith concerns about conduct. Before publishing, Northstar must confirm its non-retaliation commitment, applicable policy wording, and reporting options for every relevant location and workforce group. Share what you know; you do not need to investigate or prove a concern yourself. This site does not receive reports. Use Speak Up through your organization’s approved app access or follow another route specified in the applicable policy. Choose an available route Confirm actual access methods and local alternatives before this example is published. Speak Up Use the Speak Up app to raise a concern using the options available to you there. Open it through your organization’s approved app access. Check the app’s instructions for available reporting options. Other approved route If Speak Up is unavailable or not appropriate for your situation, use a route named in the applicable policy or local process. Check Policy Hub for the authoritative policy. Use the designated route for your location and concern. What may help when you report Describe what happened Share what you observed or were told, when and where it happened, who may be involved, and any relevant records or witnesses, if known. Share what you know Be clear about what you saw directly and what you learned from someone else. Do not investigate, confront people, or collect information you are not authorized to access. Follow the route’s instructions Use the reporting channel’s directions for any follow-up. What happens next depends on the concern and the applicable process; do not assume a particular timeline or outcome. What to expect What happens after I raise a concern? The receiving team or designated role follows the applicable process. Next steps depend on the concern and the information available. Confirm Northstar’s actual process, any follow-up arrangements, and expected communication before publishing. Is a report confidential? Do not promise absolute confidentiality. Who can access information and what may need to be shared depend on the reporting channel, applicable policy, and circumstances. Confirm approved confidentiality wording for Speak Up and other routes. What if there is an immediate safety risk? Use the established local emergency or safety response route for immediate danger. Confirm local instructions before publishing; this page does not replace emergency procedures. Can I raise a concern about retaliation? Use Speak Up or the applicable approved route and state what happened and when, if known. Northstar’s non-retaliation commitment and the process for concerns about retaliation must be confirmed in the published policy. Ready to raise a concern? Open Speak Up through your organization’s approved app access and follow its instructions. This page is guidance only and does not submit a report. Before publication, confirm Speak Up access, available options, confidentiality wording, non-retaliation language, local alternatives, and the post-report process. Use the route available to you and share what you know. Check Policy Hub for the applicable policy and confirmed local reporting guidance.