Anti-corruption

The Group’s overarching goal is to develop a corporate culture characterised by good judgment and the ability to deal with difficult situations. Orkla has zero tolerance for corruption, price-fixing agreements, market sharing or other practices that hamper free competition.

Orkla’s anti-corruption manual, competition law manual, Responsible Employer and Human Rights Policy and Code of Conduct describe the Group’s standards and guidelines relating to key integrity issues. The management of each company is responsible for communicating the Orkla Code of Conduct to every employee and making all employees who may be exposed to risk aware of the requirements in the anti-corruption and competition law manuals.

In connection with the implementation of Orkla’s vision and values, a number of tools were devised in 2015 to create greater awareness of ethical issues. Selected human rights topics of particular relevance to Orkla’s operations are addressed in occupational health and safety training and certain other training programmes. Orkla routinely conducts e-learning programmes on anticorruption and competition law for management and employees considered to be exposed to risk. The companies also provide special training in these fields, and training in anti-corruption and competition law is included in several of Orkla’s central competence-building programmes for senior executives and key personnel.

Orkla requires its suppliers to have zero tolerance for corruption, based on the Orkla Supplier Code of Conduct. Suppliers are monitored on the basis of a risk assessment, and it is a long-term goal that all Orkla’s suppliers sign the Group’s Code of Conduct.

As part of the Group’s due diligence procedures in connection with acquisitions and major investments, Orkla assesses the risk of becoming involved in breaches of anti-corruption and competition law. Orkla companies must take necessary risk-mitigating action to prevent independent business partners, including customers and joint venture partners, from participating in corruption or other illegal or unethical activities in connection with their business dealings with Orkla.

Main principles
Orkla’s anti-corruption policy includes the following principles:

• Orkla tolerates neither active (attempts to bribe others) nor passive corruption (allowing oneself to be bribed).
• Any demands for ‘facilitation payments’, i.e. payment of small amounts to civil servants, for example, in order to have routine services carried out, must be rejected firmly and clearly.
• Gifts must be made openly. They must not be made in the form of cash, must have a clear, legitimate basis in local business relationships and must have a minimal cash value.
• Expenses relating to travel, meals and events paid for customers or other persons must be clearly justified by business considerations, must be reasonable and well documented and must be paid openly.
• Orkla does not tolerate acts of corruption carried out by its agents or representatives. Agents and other representatives acting on behalf of Orkla must comply with the same anti-corruption standards as Orkla.
• Orkla companies must not make financial contributions to political campaigns or the like unless specifically authorised to do so by Orkla ASA.