All Hydro employees have a responsibility to speak up about any wrongdoing. The right, and in some cases, the duty to report applies to all employees, as well as insourced personnel. As reflected in our Code of Conduct and Hydro Governance Documents, employees have a duty to report on:

• Threats to safety or security
• Hazardous working conditions
• Harassment and discrimination
• Data privacy breaches

Hydro encourages employees to ask questions, seek guidance, raise concerns and report suspected concerns. Examples of Alerts include, but are not limited, to:

• Any type of fraud, corruption, or financial irregularities 
• Conflicts of interest 
• Compliance issues
• Human rights issues
• Workplace or community health or safety issues
• Discrimination or harassment
• Quality issues
• Business partner misconduct
• Information security breaches

Normally, employees should be raised with your local manager/supervisor. If for some reason you cannot report concerns to your manager/supervisor, you may always raise concerns to someone else in management or an employee representative, including functions such as:

• HR
• Legal
• Compliance
• HSE
• Sustainability
• GIA&I

If your concern is an Alert, you can also report using Hydro’s AlertLine. The AlertLine is always open for both employees and external parties and supports anonymous reporting.

For certain types of issues, such as those related to Competition law, HSE, Data Privacy or Cyber incidents, Hydro has specific reporting channels and/or requisite procedures for investigating incidents or breaches. Seek guidance from the respective functions responsible:

• Threats to health, safety or environment: HSE Reporting Tool / IMS / Synergi
• Data Privacy breaches: Local member of Hydro's Data Privacy Network / Intranet
• Competition Law: Legal / Compliance
• Cyber Security Incidents: IT Service Portal
• Social responsibility issues at Alunorte: SA8000
• External grievances about Hydro's operations in Brazil: Canal Direto

Hydro does not tolerate retaliation against anyone who speaks up in good faith to ask a question, raises a concern, reports a suspected violation or participates in an internal company investigation.

Hydro also has a zero-tolerance principle for intentionally reporting false Alerts. 

Yes, Hydro encourages external stakeholders to report any concerns about wrongdoing linked to Hydro's operations and activities. Please report your concern through the AlertLine, including as much detail as possible to enable Hydro to adequately follow-up your concern. Examples of Alerts can be, but are not limited, to:

• Any type of fraud, corruption, or financial irregularities 
• Conflicts of interest 
• Compliance issues
• Human rights issues
• Workplace or community health or safety issues
• Discrimination or harassment
• Quality issues
• Business partner misconduct
• Information security breaches

If you are an external partner of Hydro in Brazil and wish to report a concern relating to any community or business relationship with Hydro in Brazil, you may use the Canal Direto. This channel was specifically designed for external grievances regarding Hydro in Brazil.

If you have a concern regarding social responsibility issues at Alunorte, you may use SA8000 channel.  

All concerns reported to the AlertLine will be handled by a member of Hydro’s Group Internal Audit & Investigation (GIA&I). GIA&I is independent of Hydro's line organization, and will handle your concern in confidence, with objectivity.

GIA&I will review your concern and if the concern is an Alert, it will be handled according to internal procedures (available on the Intranet). If your concern is not an Alert, GIA&I will ensure it is forwarded and referred to the correct function for follow-up.

You can expect the following when submitting an Alert through the AlertLine:

• Receipt of the Alert is confirmed within seven days. 
• All reports are taken seriously.
• Hydro has zero tolerance for retaliation against anyone who speaks up in good faith, and zero tolerance for intentionally reporting false Alerts.
• Requests regarding anonymity are respected to the extent possible.
• The Alert and the identity of the Reporter are kept confidential to the extent possible.
• Feedback or status on the Investigation or follow-up is provided within three months.

Hydro's AlertLine supports anonymous reporting. We encourage anonymous reporters to provide as much detail as possible when submitting an Alert, and ask that anonymous reporters retain the report key and other credentials received when making the Alert. This enables a member of Group Internal Audit & Investigation (GIA&I) to provide feedback and ask questions to the anonymous reporter in the AlertLine, which is a secure reporting system.

Depending on the content of the report, there may be limitations on how we can follow-up and investigate anonymous reports.

GIA&I will protect identities of reporters to the extent possible throughout the process. If a reporter identifies themselves, GIA&I will always seek to protect the integrity of all persons involved, including protecting a Reporter's identity. In some instances, GIA&I may be required to disclose a Reporter's identity, such as during legal procedures. If any such instance should occur, GIA&I will seek to inform the reporter.

Information sought and shared during an internal investigation is on a need-to-know basis. GIA&I will not share information regarding an investigation beyond this.

The AlertLine is operated in accordance with the Norwegian Working Environment Act and European data protection principles. This generally entails an obligation to inform individuals of allegations raised against them. To the extent possible, information shared with individuals who are reported against will not disclose a Reporter's identity.

When an Alert is reported through the AlertLine, feedback on Alerts will be provided through the AlertLine. Reporters can access their report using the report key and credentials provided when submitting the Alert.

Feedback or a status update will be provided within three months of submitting an Alert.

Due to confidentiality purposes, full details of the investigation and/or outcome of an Alert may not be shared.  

If your Alert pertains to criminal activity, involved individuals will have a duty to report the issue to the authorities. If so, you may be required to speak with the authorities, and your identity could be compelled to be disclosed.

Contact your local sales representative or local plant management – see https://www.hydro.com/en-NO/about-hydro/hydro-worldwide/

See https://aluminium-stewardship.org/about-asi/asi-members/norsk-hydro/

See https://www.hydro.com/en-NO/about-hydro/corporate-governance/policies-and-tools/

See https://www.hydro.com/en-NO/privacy/

See https://www.hydro.com/en-NO/careers/

See https://www.hydro.com/en-NO/about-hydro/sponsorships/