Responsible and Independent Advisory Services on Mineral Resources in Greenland

 

NEMCo advises companies, investors, decision-makers, organisations and other stakeholders on the mineral resource sector in Greenland.

 

Our advisory services are based on practical experience, professional integrity and an in-depth understanding of the commercial, political, social and regulatory conditions that shape mineral resource projects in Greenland.

 

The mineral resource sector presents significant opportunities, but also important responsibilities. Projects may affect local communities, the environment, industry, infrastructure, employment, political decision-making and Greenland’s long-term development. We therefore work according to clear ethical principles regarding independence, confidentiality, transparency and responsible advisory practice.

 

This Code of Conduct describes the principles by which we work.

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1. Professional Integrity

We provide advisory services based on experience, verifiable information, relevant analysis and professional judgement.

We clearly distinguish between facts, assessments and recommendations. Where there are uncertainties, assumptions or limitations in an analysis, we make these clear.

We do not contribute to presenting circumstances as more certain, simple or positive than there is basis for.

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2. Independence

Our advisory services must be professionally independent and credible.

We do not allow financial, political or personal interests to influence our advice in a way that compromises our integrity. Our long-term credibility is more important than short-term commercial interests.

We reserve the right to decline assignments that cannot be carried out in an independent, responsible or ethically sound manner.

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3. Confidentiality

We treat clients’ information as confidential.

Confidential information is not shared with third parties without consent, unless there is a clear legal obligation to do so. This includes, among other things, commercial plans, project strategies, investor dialogues, political assessments, internal analyses, licence matters and non-public knowledge about companies or projects.

We do not use confidential information from former employers, clients, partners or management roles in advisory work for others.

General experience and industry insight may form part of our advisory services, but confidential information remains confidential.

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4. Conflicts of Interest

Conflicts of interest are handled openly and consistently.

Before accepting an assignment, we assess whether actual or potential conflicts of interest may exist. This applies particularly in matters where several stakeholders may have opposing interests in the same project, licence, political process or commercial negotiation.

As a general rule, we do not advise two parties with directly conflicting interests in the same specific matter.

Nor do we advise a client if the assignment requires the use of confidential knowledge from a former or current client.

We assess new assignments according to a green, yellow and red model for conflicts of interest and assignment acceptance.

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🟢 Green assignments may be accepted following ordinary client acceptance.

🟡 Yellow assignments require a specific conflict assessment, clear limitation of scope and any necessary mitigating measures.

🔴 Red assignments are declined if they involve a direct conflict of interest, use of confidential knowledge, hidden lobbying, greenwashing or a risk of compromising our independence and credibility.

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5. Transparency Regarding Our Role

We are clear about the role we have in any given assignment.

In some contexts, we act as a strategic adviser to a client. In other contexts, we may contribute independent analysis, presentations or general industry insight. Our role must be clear to the client and to relevant stakeholders.

We do not engage in hidden lobbying, concealed advocacy or communication where the sender, purpose or party interest is deliberately obscured.

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6. Advisory Services to Political Actors

We may advise political actors, decision-makers and organisations on the mineral resource sector, but this type of advisory work requires particular care.

When advising political actors, we distinguish between professional analysis, policy options and specific recommendations.

We do not use confidential information from corporate clients in political advisory work. We do not advise political actors and companies on the same specific project if this may create doubt about our independence or confidentiality.

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7. Advisory Services to Companies and Investors

When advising companies, investors or project developers, we work to provide a realistic picture of opportunities, risks and expectations in Greenland.

We may advise on, among other things:

• strategic market understanding

• stakeholder mapping

• political and social risks

• authority and decision-making processes

• local anchoring

• ESG and social licence

• communication and stakeholder dialogue

• project maturation at management and board level

We do not guarantee licences, approvals, political support, authority outcomes, local acceptance, financing or investor interest.

Our role is to advise on process, context, risks and possible courses of action — not to promise specific outcomes.

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8. Responsibility Towards Greenland

We provide advice with respect for Greenland’s society, nature, culture, language, local decision-making processes and long-term development interests.

Mineral resource projects should be assessed in a broader societal context and not solely on the basis of technical or financial parameters.

We emphasise that responsible project development requires:

• genuine dialogue with affected stakeholders

• respect for local communities

• understanding of local industries and living conditions

• transparent communication

• realistic expectations

• local value creation where possible

• proper handling of environmental and social risks

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9. ESG and Social Licence

We do not contribute to greenwashing or misleading ESG communication.

If material environmental, social, governance-related or societal risks have not been sufficiently assessed, we make this clear.

We help clients understand how ESG, local acceptance and social licence can be decisive for a mineral resource project’s ability to develop responsibly and credibly.

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10. Anti-Corruption and Improper Influence

We do not accept bribery, hidden payments, facilitation payments, improper gifts or other benefits that may influence — or be perceived as an attempt to influence — decisions, recommendations or relationships.

We exercise particular caution in relationships with politicians, civil servants, authority representatives and public employees.

All contact and advisory work must be able to withstand public scrutiny.

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11. Clear Scope of Advisory Services

We are clear about what we advise on, and what we do not advise on.

We provide strategic, commercial, political, societal and ESG-related advisory services within our areas of competence.

We do not provide independent legal, tax, technical geological, environmental technical, geotechnical, securities law or investment advice, unless this is done in cooperation with relevant qualified specialists.

When an assignment requires specialist knowledge outside our areas of competence, we recommend involving lawyers, auditors, geologists, environmental specialists, financial advisers or other relevant experts.

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12. Use of Our Name and Analyses

Clients may not use NEMCo, our name, reports, analyses, presentations or advisory input in public communication, investor material, press releases or third-party dialogue without prior agreement.

This applies particularly where our name or work may be perceived as a general endorsement of a project, licence, ESG position, investment case or political viewpoint.

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13. Data Protection and Use of Digital Tools

We handle client data responsibly and use appropriate digital tools for document management, communication and analysis.

Confidential information is handled with care and is only shared with persons who have a legitimate need for access.

When using digital analysis tools, including artificial intelligence, we always quality-assure the content before it is used in advisory work, reports or presentations.

Confidential client information is not used in external digital tools unless the client has accepted this and the tool is considered suitable for the purpose.

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14. Partners and Subcontractors

We may cooperate with external specialists when an assignment requires supplementary professional expertise.

Partners and subcontractors must respect confidentiality, disclose relevant conflicts of interest and work according to professional and ethically sound standards.

When external specialists are involved in an assignment, their role and responsibility are made clear to the client.

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15. Quality and Responsibility

We strive for high quality in all deliverables.

Analyses, reports, briefings and recommendations must be clear, relevant and useful to the client. Material assumptions, risks and limitations must be stated.

If we discover a material error in material or advice delivered to a client, we inform the client and correct the error professionally.

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16. Assignments We Do Not Accept

We do not accept assignments where the purpose is to:

• gain access to confidential information from former clients or roles

• influence political or authority decisions in a hidden or improper manner

• present misleading analyses, consultation responses or communication

• downplay material environmental, social, political or commercial risks

• present party interests as independent analysis

• advise two sides in the same specific conflict

• contribute to greenwashing

• promise specific authority, political or commercial outcomes

• circumvent legislation, authority processes or good business practice

If an assignment cannot be carried out in accordance with this Code of Conduct, we decline it.

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17. Our Commitment

Our advisory services are intended to create a better basis for decision-making — not to hide complexity.

We work to help clients understand the opportunities, risks and responsibilities in Greenland’s mineral resource sector and make decisions on a more informed basis.

Our ambition is to be a credible, independent and responsible adviser in a field where trust, experience and integrity are essential.