Code of ConductThis English version of the Code of Conduct is a translation of the original Norwegian document. In the case of any discrepancy, the original Norwegian document will prevail. Approved by the Board of Directors as of 14 February 2019.
KBN shall fulfil its role and social responsibility by acting in accordance with good business practice and all relevant legislation. This Code of Conduct sets out the ethical standards that its employees must respect in their work and in their interactions with external parties and colleagues. The purpose of the Code of Conduct is to safeguard KBN’s reputation and trustworthiness, and to encourage ethical awareness as well as loyalty to KBN’s values, responsibilities and guidelines.
2. SCOPE AND RESPONSIBILITIES
The Code of Conduct applies to members of KBN’s Board of Directors, permanent and temporary employees, and other external persons who act on behalf of KBN (hereinafter collectively referred to as ‘employees’) unless a specific provision states otherwise.
All new employees shall be made aware of this Code of Conduct, and all employees shall review it regularly, in order to promote compliance with its requirements.
All KBN’s managers must ensure that performance evaluation and remuneration encourage behaviour that is in accordance with this Code of Conduct.
Violations of KBN’s Code of Conduct are unacceptable and may have consequences for the employment of the employee concerned.
3. GENERAL PRINCIPLES
KBN shall contribute to the sustainable development of society as well as to long-term value creation by adopting responsible business practices that respect human rights, the environment and societal relations.
KBN’s employees must practice high ethical standards in their work for KBN and must act at all times in accordance with all relevant legislation and with KBN’s articles of association and internal rules. Employees shall conduct themselves in a trustworthy manner and observe good business ethics.
Employees must not act in contravention of KBN’s rules and guidelines on the duty of confidentiality. The duty of confidentiality applies in all contexts, both at work and privately.
As an employer, KBN shall create a working environment for employees that is high-quality and health-promoting from a physical, mental and social perspective. As an employer, KBN does not tolerate bullying, harassment and discrimination, and it works to prevent sexual harassment. Employees shall act accordingly both internally and in their interactions with KBN’s business contacts and other external parties. Employees shall report instances of bullying, discrimination and harassment in the workplace.
4. CORRUPTION AND MONEY LAUNDERING
Corruption is illegal and includes bribery and improper trading in influence. Corruption undermines lawful business activities, leads to distortions of competition, and would destroy KBN’s public image and create risk for our customers and those we work with.
The prohibition on corruption applies both to those who give or offer unlawful advantage and to those who ask for, take or agree to any such advantage. Even the act of raising the prospect of receiving or giving unlawful advantage is illegal. This applies whether the advantage benefits KBN or other parties or businesses.
Money laundering is illegal and KBN must avoid being involved in situations or transactions related to assets that may be the proceeds of criminal acts.
KBN works to ensure corruption and money laundering have no place in its business activities.
5. RELATIONSHIPS WITH CUSTOMERS AND SUPPLIERS
KBN seeks to build and maintain good relations with existing and potential customers. A long-term and wide-ranging perspective is to be used when building relationships, with care being taken to avoid unfairly or unreasonably influencing individuals or acting such that the individuals involved feel pressured.
When discussing matters with customers, employees shall always take the customer’s needs as the starting point for the information they provide.
6. CONFLICTS OF INTEREST
A conflict of interest arises when KBN’s interests and the interests of an employee differ. Examples of matters that can give rise to conflicts of interest include close relationships, financial interests or an individual’s other positions, roles or functions.
KBN's employees must not take part in considering or deciding upon any matters:
- That are of significance to themselves or their spouse, un-married partner, children, parents or other close associates.
- That are of significance to companies, organisations or public bodies that they or a close associate own either wholly or in part, or where they or a close associate are members of the governing body or are in a position of leadership.
- When there are any other special circumstances that may make it more difficult to be confident of the employee's impartiality.
No employee may hold an appointment or employment outside of KBN unless it is self-evident that the appointment or employment is not in conflict with KBN’s interests. Employees can neither enter agreements to perform additional work nor accept appointments to the boards of other companies without written approval from the President and CEO of KBN. Board appointments related to organisations such as housing associations, nurseries and sports clubs do not require such approval. This provision does not apply to shareholder-elected board members.
Employees are themselves responsible for considering whether they have a conflict of interest in relation to any matter. If requested by someone other than the employee, or if the employee finds this necessary, the matter shall be referred to the President and CEO of KBN.
The President and CEO of KBN can only accept board appointments and can only enter into secondary employment upon approval by the Board.
At the Board level, decisions concerning conflicts of interest are taken by the Board without the party concerned taking part in the decision. Members of the Board must themselves disclose matters that might be considered as conflicts of interest.
Employees acting on behalf of KBN must avoid receiving personal benefits of any kind that could influence or be liable to influence their actions, how they prepare a case, or decisions/resolutions. This same requirement applies where KBN is the giver of gifts or benefits. The requirements of the Code of Conduct are not intended to prevent employees from giving or receiving gifts of insignificant monetary value, or moderate hospitality or entertainment for which there is a commercial justification.
No-one shall, whether directly or indirectly, demand benefits in any form from KBN’s suppliers or customers. KBN’s discount agreements can only be used when a general scheme has been set up for this purpose for KBN employees.
Travel for work that is related to KBN’s activities must be paid for by KBN unless otherwise approved by the President and CEO.
7. CONFIDENTIALITY AND INSIDE INFORMATION
Confidentiality must be maintained such that unauthorized individuals do not gain access to information that could harm KBN, its customers or the parties it works with. The duty of confidentiality must also be observed in respect of the personal data and privacy of employees, customers and collaboration partners.
It is essential to exercise caution and to think carefully with respect to whom one provides information, how it is provided and where it is provided, so that unauthorized individuals do not gain access to confidential information. Confidential information must only be shared if there is a legal requirement for it to be shared.
Misuse of inside information is illegal. Employees must be aware of the requirements regarding the duty of confidentiality and the management of inside information.
KBN’s employees are not allowed to trade in securities issued by KBN for their own account or for the account of a close associate.
Employees must follow the rules and internal guidelines in force at the time when trading in financial instruments for their own account.
8. EXTERNAL COMMUNICATION
Information provided by KBN must be reliable and correct, and must adhere to high professional and ethical standards. Unless decided otherwise, only the Chairman of the Board, the President and CEO, and the Chief Communications Officer can address the media or the public.
Employees shall exercise caution on social media and in public debates, and must act in such a way as to safeguard KBN’s reputation in a positive manner.
9. REPORTING AND WHISTLE-BLOWING
KBN wants employees to raise matters that are unacceptable so problems and challenges can be addressed in a responsible manner and lessons can be learnt.
Employees must immediately report any situations they encounter that involve questionable ethical standards or breaches of laws, rules, internal guidelines or this Code of Conduct by someone in the service of KBN. Employees can report such situations via the chain of command, the health and safety representative, the President and CEO, or the Board of Directors. Serious situations can be reported via KBN’s whistle-blower channel, which manages whistle-blowers’ reports in accordance with KBN’s whistle-blowing procedures. All situations that are reported and all whistle-blowing reports are handled with respect and are taken seriously.
10. GENERAL RULES OF CONDUCT
Employees are encouraged to inform their immediate line manager in the event of problems related to their personal finances that they are unable to resolve within a reasonable timeframe.
KBN is an alcohol-free and drug-free workplace. Employees must not be under the influence of alcohol or drugs when carrying out work for KBN. However, limited amounts of alcohol can be served when local customs and special occasions make this appropriate.
KBN’s property, premises and other resources must be used in accordance with KBN’s rules and must not be used for private purposes unless specifically agreed.
11. DELEGATED AUTHORITY
The CEO and President is authorised to establish additional rules within the framework of this Code of Conduct.
12. ENTRY INTO FORCE
This Code of Conduct replaces the previous version (dated 17 October 2014) and enters into force immediately.