Code of Conduct

This 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 17 Oktober 2014.


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 and elected officers 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 and responsibilities.


Unless otherwise specified by the individual provisions, the Code of Conduct applies to elected officers of KBN and to its permanent and temporary employees.

The Code of Conduct applies to persons who provide services to KBN but who are not employees or elected officers insofar as is relevant and when stipulated in any agreement covering the services provided. Agreements of this type must always be entered into with service providers if as part of providing the services they are physically present at KBN’s offices or are granted access to the agency’s systems.


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, ethical conduct and societal relations.

KBN’s elected officers and 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 the agency’s articles of association and internal rules. Elected officers and employees must abide by the principle of openness in all business activities while also ensuring that all legal requirements in respect of duty of confidentiality and other rules on confidentiality are satisfied.


KBN has a zero-tolerance policy towards all forms of bullying, harassment and discrimination, and expects employees to act accordingly internally and in their interactions with the agency’s business contacts and other external parties.


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 where they 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.

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.

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 relationships that might be considered as conflicts of interest.


No-one 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.

The President and CEO of KBN can only accept board appointments and can only enter into secondary employment upon approval by the Board. Employees can neither enter into agreements to perform salaried 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.


Confidentiality must be maintained such that unauthorized individuals do not gain access to information that could harm KBN, the agency’s customers or the parties it works with. The duty of confidentiality must also be observed in respect of elected officers’ and employees’ personal data and privacy.

It is essential to exercise caution and to think carefully about 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.


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.


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.

Those attending customer events organised by KBN must pay their own travel and accommodation expenses. Agreements with organisations with which KBN is working must define both parties’ responsibilities.

When advising customers and discussing matters with them, the agency’s employees must strive to give ethically and professionally sound advice and information in order to prevent the customer’s representatives from being misled into taking decisions that are not in line with the customer’s own interests and requirements.


Misuse of inside information is illegal. Employees and elected officers must be aware of the requirements regarding the duty of confidentiality and the management of inside information that are set out in the Securities Trading Act. Breaches of the provisions concerning inside information can lead to the individual concerned being held criminally liable.


Money laundering is illegal and KBN must avoid receiving, or in any way being involved in a situation or transaction related to assets that may be the proceeds of criminal acts. Appropriate measures to identify and evaluate the integrity of our business counterparties shall be established, and shall be applied using a risk-based approach.


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. KBN has zero-tolerance of corruption, and will work to ensure that it has no place in the agency’s business activities. 

The ban on bribery and improper trading in influence 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.


Employees must immediately report any situations they encounter that involve questionable ethical standards or breaches of laws, rules or this Code of Conduct by someone in the service of the agency. Employees can report such situations either to their line manager or to their line manager’s superior. On receiving such information, a line manager’s superior must consult his own line manager or the CEO and President.


If employees for any reason do not feel comfortable reporting an unacceptable situation through KBN’s formal chain of command, they can use the agency’s whistleblower channel, the health and safety representative, the CEO and President or the Board, which has a duty in accordance with the Norwegian Working Environment Act to consider whistleblowers’ reports. Whistleblowers can choose to remain anonymous.


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.

Situations that could lead to conflicts between KBN’s interests and personal interests must be avoided.

The requirements of the Code of Conduct are not intended to prevent employees from receiving gifts of insignificant monetary value (up to NOK 500) such as flowers etc. Gifts worth more than NOK 500 must be approved by the CEO and President and are the property of KBN. Gifts and other benefits worth more than NOK 300 must be reported. This applies regardless of whether the gifts or benefits are for KBN or the employee personally, or whether KBN is itself the giver of the gift or benefit.

The requirements of the Code of Conduct are similarly not intended to prevent employees from receiving or giving benefits of moderate hospitality and entertainment as part of regular cooperation and information exchange.

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 employees.

Travel for work or work-related purposes must be paid for by KBN unless otherwise approved by the CEO and President.

The agency’s property, premises and other resources must be used in accordance with the agency’s rules and must not be used for private purposes unless specifically agreed. Private use that is insignificant in scope is nonetheless permitted.


Rules regarding personal trading in financial instruments are set out in the Securities Trading Act, Chapter 8. Employees are themselves responsible for keeping up-to-date with all applicable legislation and regulations, as well as internal rules, on this matter. This includes whether they are required to report any trading, which financial instruments can be traded, excluded counterparties, and how long they must hold any instrument before selling it. KBN shall ensure that its internal rules are readily available and updated. Those who are required to report any trading may be held criminally liable if they are in breach of the provisions regarding employees’ personal trading.

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.


KBN 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


All new employees shall be made aware of this Code of Conduct, and all existing employees shall be reminded of the Code of Conduct annually, 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 may have consequences for the employment of the employee or elected officer concerned.


The CEO and President is authorised to establish additional rules within the framework of this Code of Conduct.


This Code of Conduct replaces the previous version (dated 12.10.2011) and enters into force immediately.