Relations with middlemen and business partners

What you need to know

The use of middlemen is normal and desirable in many circumstances. However, Telenor could be held liable for corrupt or fraudulent activities conducted by its middlemen. We thus need to ensure that middlemen or Business Partners do not commit any corrupt or fraudulent activities on Telenor’s behalf.

Telenor uses the term “Business Partner” as a collective term for joint venture partners, agents, consultants, intermediaries and middlemen. Business Partners will be associated with Telenor, and it is important to ensure that the Business Partners are reputable and does not risk Telenor being associated with corrupt activities.  Prior to entering into a relationship with a Business Partner, you shall always consult the Group Manual Integrity Due Diligence as regulated in the Group Policy Anti-Corruption.

What you must do

• Ensure that a middleman and business partner are reputable, credible and genuine entities or persons
• Follow Telenor’s Group Manual on Integrity Due Diligence when required
• When relevant follow the Group Policy Sourcing and Group Policy Supply Chain Sustainability

What you need to be aware of

The following “red flags” may indicate an unacceptable risk in relation to middlemen and business partners:

• The business partner may not be willing to certify that he/she will not take unlawful actions
• Unusual payment patterns (including payment to “tax-havens”)
• Lack of transparency in expenses and accounting
• Apparent lack of resources or qualifications
• Kickbacks or similar
• Fees are not proportionate to the services provided
• Business reputation and track record