All employees and others who act for Norske Skog are required to conduct business in a manner which preserves and promotes Norske Skog's reputation. Our policy is to ensure a legal and ethical business standard through mandatory and minimum requirements for all employees and others who act on Norske Skog’s behalf. We expect similar conduct from our customers, suppliers and other business partners.
Transparency and Interest Conflicts:
Payments, Donations, Gifts and Hospitality
In order to ensure that Norske Skog’s interests prevail in business matters, it is crucial that employees and others acting on behalf of Norske Skog truthfully follow the principles of transparency and correct handling of interest conflicts.
- Every transaction in which Norske Skog participates, and every invoice, payment, receipt and asset must be correctly reflected in the books of Norske Skog
- Any direct or indirect offer, promise, grant, transfer or request for bribes, hereunder any illegitimate or otherwise improper gift, disposal, accept or other advantage, on behalf of an individual or Norske Skog, are unacceptable, even if it would secure business for Norske Skog
- It is prohibited to accept a gift, favour or form of entertainment if the intention of the donor could be perceived as to obtain an improper preference or advantage
- Any gift, favour or form of entertainment is prohibited if the intention is to give Norske Skog as donor an improper preference or advantage
- Conflicts between private and Norske Skog’s interests should be treated with openness, and any potential conflict should be avoided to the extent possible
Norske Skog’s leaders and employees are obliged to identify situations that may involve bribery and clearly state their disagreement with bribes. All contact with, and activities or advantages provided by, business contacts are business related even if they take place outside of working hours. Transactions, gifts, donations and hospitality, whether given or received, must not expose Norske Skog to the risk of disturbed business decisions or reputational damage. Transparency and accurate recording of all business related transactions are important to prevent and discover interest conflicts of all kinds.
“Facilitation payments” are payments made in order to expedite public officials’ services to which one is already entitled, typically faster or with less procedure than normally required. Facilitation payments normally constitute bribery, which is prohibited and will not be accepted. An exception exists where the individual involved believes that his/her own or another’s life or health may be in danger. Requests for facilitation payments should always be reported to the corporate legal department.
“Trading in influence” means improper advantages provided to someone in order to influence the performance of a third party. Trading in influence shall never take place on behalf of or to the benefit of oneself or Norske Skog, except for legally acceptable forms of lobbying. A lobbyist is an intermediary used to influence decisions both in the public and private sector. Engagement of lobbyists must always be approved at corporate level. A lobbyist working for Norske Skog must fully disclose to the person or body Norske Skog wishes to influence that he or she represents Norske Skog, and such disclosure must be agreed in the contract between the lobbyist and Norske Skog.
Charitable donations, sponsorships, gifts and hospitality should not be used as disguise for bribery.
Donations and sponsorships are monetary or practical support of a purpose or cause outside of the company or group. Any Norske Skog unit offering or accepting donations or sponsorships must ensure that the support is based on proper reasons and not used to disguise support of political parties, or particular political or controversial causes, or promote interests in conflict with those of Norske Skog in the relevant local community. Financial or similar support to political organisations must be approved by the President & CEO. Each business unit offering a monetary or practical contribution must establish formal records describing the purpose of and criteria for that contribution.
Gifts are goods, assistance, discounts or disposal given or received in connection with an employee’s role as a representative of Norske Skog. Gifts, both given and received, should be limited to a minimum in frequency and must be of symbolic value. They should always be transparent and must never be given in expectancy of any advantage or value in return.
Hospitality includes entertaining, meals, receptions, tickets to entertainment, social or sports events. Hospitality must always be adequately connected with Norske Skog’s business and should only be given or received with the aim at initiating or developing a proper relationship with proper business partners. All such hospitality must be kept to a moderate level and expensive arrangements require prior approval by a Managing Director or member of the Corporate Management.
Norske Skog has issued Corporate Standards with more detailed instructions on how to handle client hospitality and gifts, as well as rebate, service surcharge and commission payments.
If you are in doubt on how to treat hospitality, a gift or a transaction, you should contact your immediate supervisor or the corporate legal department.
Confidentiality and Inside Information
Norske Skog has financial instruments listed on a regulated market place. To promote compliance with stock exchange, trading, securities and other applicable laws and regulations, the Steering Documents set out more detailed instructions to primary insiders, employees and other representatives of Norske Skog.
All employees shall take due care when handling confidential and/or business sensitive information and ensure that such information is only disclosed or made available to those who need it. No employee shall disclose confidential information to external parties, media or others without a previous, documented decision from relevant Norske Skog decision makers.
An employee who has been exposed to inside information (herein understood as confidential information with the possible effect of noticeably influencing the price of Norske Skog or another issuer’s financial instruments) must refrain from trading in Norske Skog (or the relevant other issuer’s) financial instruments, as well as from encouraging others to do or abstain from doing so. Misuse of such information may result in criminal and civil charges being brought against the individual.
Norske Skog has the aim of protecting the securities and financial markets from illegitimate gains by inside traders, as well as securing financial markets’ trust in the value of Norske Skog and other relevant issuers’ financial instruments.
Norske Skog is a significant actor in the international market on publication paper, and it is important that we respect common regulations for our markets.
No employee or others who act on behalf of Norske Skog may make any arrangement contrary to applicable competition laws. Norske Skog’s employees shall respect Norske Skog’s internal regulations and guidelines set out in the Steering Documents. This is important to protect the functioning of Norske Skog’s markets, and thus promotes the interests of Norske Skog, as well as our customers, suppliers, agents and competitors. Breach of competition law exposes Norske Skog to immense risks of investigations, public fines and claims for damages. In some jurisdictions, it also exposes the company, as well as the directly involved individuals, to criminal sanctions including imprisonment.