For Telenor, anti-corruption is not only a legal obligation and an ethical standpoint. Corruption is a threat to business and society in all countries. It undermines legitimate business activities and distorts competition. It ruins reputation and exposes individuals to risks.
At Telenor we are all responsible for understanding the important legal and ethical issues that affect our business and for acting with integrity at all times. Integrity means complying with both the spirit and the letter of the laws and regulations that govern our industry.
Corruption includes bribery and trading in influence. Any corrupt activity – either in public or private sector (between private parties) – is prohibited. It is prohibited to offer, give, ask for, accept or receive any form of bribe, including facilitation payments. Telenor’s zero tolerance on corruption and ethical standards are set out in our Code of Conduct, Group Policy Anti-Corruption and other governing documents, which are implemented in all Telenor’s subsidiaries directly or indirectly controlled by Telenor ASA. All suppliers and third parties that have a direct contractual relationship with Telenor and offer products or services to Telenor must comply with to our Supplier Conduct Principles. These principles set out the minimum standards that we expect to see achieved over time, including on ethics and anti-corruption.
Top-level commitment is vital for establishing a transparent and enterprise-wide culture which works against corruption. The Code of Conduct is Telenor’s management is committed to sending clear, unambiguous and regular messages to all staff and business partners that corruption and bribery is unacceptable. Leaders have a particular responsibility to act as good role models and to build a safe, trustful and transparent culture in their teams.
The Sustainability and Compliance Committee of Telenor ASA’s Board of Directors supports the Board in fulfilling its responsibilities with respect to ethics and anti-corruption.
Our Anti-Corruption Program
Telenor Group Anti‐Corruption Policy states that Telenor shall actively attempt to ensure that corruption does not occur in Telenor’s business activities through an adequate and risk-based Anti‐Corruption Program. Telenor’s Anti-Corruption Program is rooted in our Code of Conduct and Group Policy Anti-Corruption. Its design, implementation and enforcement are risk-based and tailored to prevent corruption throughout Telenor’s business activities.
The program includes several elements working together: proportionate procedures; top level commitment; risk assessment; integrity due diligence; communication and training; monitoring and review; and enforcement and sanctions. The Group Anti‐Corruption Policy and the effectiveness of the Anti‐Corruption Program are assessed and revised on a regular basis, with the aim of continuous improvement and alignment with prevailing international standards. Telenor’s Governance framework clearly defines roles and responsibility for implementation of the Anti-Corruption Program, both at Group and locally in each subsidiary.
The Code of Conduct is approved by the Telenor ASA Board of Directors. The Code of Conduct is also approved locally by the board of directors of each subsidiary. The Group Policy Anti-Corruption is approved by the Group President and CEO, and locally by the CEO in each subsidiary.
The Anti-Corruption Program works together with Telenor’s Ethics & Compliance function, which is an important component of Telenor’s governance, risk management and internal control systems. All employees may report any concerns to the Local Ethics & Compliance Officer, or Telenor Group Ethics & Compliance function at Telenor’s “Ethics & Compliance Hotline”. All reporting shall be treated confidentially.
Anti-Corruption Handbook, Awareness & Training
Telenor’s anti-corruption training activities for employees range from on-boarding and online learning programs to dilemma-training, town halls and other “Telenor Way” awareness activities. Telenor strives to consistently improve and tailor the training programme in order to ensure that our commitment against corruption is known and lived by throughout the company.
Telenor’s Anti-Corruption Handbook is a practical guide to help all Telenor employees to understand and live Telenor’s values and formal policy relating to anti-corruption. Our Anti-Corruption Handbook shall assist our employees to navigate challenges related to gifts, events and representations, facilitation payments, public authorities and business partners. The guidelines shall help each employee to make the right decisions. The Handbook cannot provide answers to every situation and dilemma that our employees may face. Our employees are strongly encouraged to seek advice when in doubt.
Anti-corruption in supply chain and third party relations
Integrity is a vital part of Telenor’s business. We recognize that our business partners, whether new investments, partners, agents, consultants, contractors or suppliers, will be associated with Telenor. Due care shall be exercised to the selection and use of business partners to ensure compliance with Telenor’s ethical standards. Telenor has implemented mandatory requirements for screening and conducting integrity due diligence assessments (IDD) of our business partners.
All suppliers and parties that have a direct contractual relationship with Telenor and offer products or services to Telenor must adhere to our Supplier Conduct Principles. These principles set out the minimum standards that we expect to see achieved over time, including on ethics and anti-corruption. Anti-corruption is part of the regular supplier engagement and forms part of supplier training & awareness activities in various forms in the local markets.
Telenor monitor compliance through a systematic, risk-based approach, which may include both announced and unannounced site visits. We encourage our suppliers to implement an efficient anti-corruption program to minimize corruption risk.
Telenor is active in international fora to discuss and find solutions to common challenges facing the industry. One such initiative is a guide to help preventing corruption in the supply chain, developed by UN Global Compact and Telenor with inputs from UNGC Advisory Group members. The guide is used in supplier training and outlines preventive measures companies are encouraged to have in place to minimize corruption risk.
Telenor Group is a multinational company with operations in very different markets. Telenor’s governing documents set one single standard which shall govern all business activities, regardless of where such activities take place. Some markets in which we operate are emerging economies with potentially complex and sensitive political and social contexts, including markets associated with high corruption risks. This creates challenges that require robust, targeted measures to mitigate such risks. All Telenor business units have a responsibility to conduct regular risk assessments and risk-based reviews of their anti-corruption procedures and implement remediating measures to address risks.