Anti-Corruption Policy

1. Purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that Nordisk Sikkerhet AS’s business is conducted in a socially responsible manner.

2. Policy statement 
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. 

Nordisk Sikkerhet AS’s policy is to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and to implementing and enforcing effective systems to counter bribery. 

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the Kingdom of Norway, including Straffeloven § 276 a-c. and “The [Norwegian] Ministry of Foreign Affairs’ zero-tolerance policy on corruption”, in respect of our conduct both at home and abroad. 

Bribery and corruption are punishable for individuals by up to 10 years imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from receiving government grants, tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously. 

3. Scope 
3.1 Who is covered by the policy? 
In this policy, third party means any individual or organization one comes into contact with during the course of work for Nordisk Sikkerhet AS, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties. 

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). 

This policy covers: 
•    Bribes; 
•    Gifts and hospitality; 
•    Facilitation payments; 
•    Political contributions; 
•    Charitable contributions. 

3.2 Bribes 
Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world. 

3.3 Gifts and hospitality
Employees must not offer or give any gift or hospitality: 
•    which could be regarded as illegal or improper, or which violates the recipient’s policies; or 
•    to any public employee or government officials or representatives, or politicians or political parties; or 
•    which exceeds NOK 100 in value for each individual gift or NOK 500 in value for each hospitality event (not to exceed a total value of NOK 1000 in any financial year), unless approved in writing by the employee’s manager. 

Employees may not accept any gift or hospitality from our business partners if: 
•    it exceeds NOK 100 in value for each individual gift or NOK 500 in value for each hospitality event (not to exceed a total of NOK 1000 in any financial year), unless approved in     writing by the employee’s manager; or 
•    it is in cash; or 
•    there is any suggestion that a return favor will be expected or implied. 

Where a manager’s approval is required above, if the manager is below Director level then approval must be sought from an appropriate Director. 

If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity. 

We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered. 

Within these parameters, local management may define specific guidelines and policies to reflect local professional and industry standards. Where this policy requires written approval to be given, the Company Director shall put in place a process to maintain a register of all such approvals. 

3.4 Facilitation payments and kickbacks 
Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low-level officials to obtain a level of service, which one would normally be entitled to. 

Our strict policy is that facilitation payments must not be paid. 

3.5 Political Contributions
We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage. 

3.6 Charitable contributions 
Charitable support and donations are acceptable (and indeed are encouraged), whether of in-kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Company Director. All charitable contributions should be publicly disclosed. 

4. Employees’ responsibilities 
All Nordisk Sikkerhet AS’s employees must ensure that they read, understand and comply with this policy. 

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. 

Employees must notify the Company Director as soon as possible if they believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future. 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy. 

5. Record-keeping 
Nordisk Sikkerhet AS must keep financial records and have appropriate internal controls in place, which will evidence the business reason for making payments to third parties. 

Employees must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review. 

Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with expenses policy and specifically record the reason for the expenditure. 

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments. 

6. How to raise a concern 
Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If employees are unsure whether a particular act constitutes bribery or corruption, or if employees have any other queries or concerns, these should be raised with the Company Director. 

7. What to do if one is a victim of bribery or corruption 
It is important that employees tell the Company Director as soon as possible if employees are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that the employee is a victim of another form of unlawful activity. 

8. Protection 
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. 

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If an employee believes that s/he has suffered any such treatment, the employee should inform the Company Director immediately.
9. Training and communication 
Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis. 

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter. 

10. Who is responsible for the policy? 
The Company Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. 

The Company Director has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. 

11. Monitoring and review 
The Company Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. 

Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. 

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. 

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Company Director. 

This policy does not form part of any employee's contract of employment and it may be amended at any time.