For Telenor, anti-corruption is not only a legal obligation and an ethical standpoint. We understand that corruption is a threat to our business and the societies in which we operate. We know that it can undermine legitimate business activities, distort competition, damage reputations and expose individuals to risk.
All Telenor employees are responsible for understanding the 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 laws and regulations applicable to our business, as well as with internal requirements. Telenor prohibits all corrupt activity, including bribery and trading in influence, in both the public and private sectors. We do not allow anyone involved in our business to offer, give, ask for, accept or receive any form of bribe, including facilitation payments.
Telenor’s zero tolerance for corruption and our ethical standards are set out in our Code of Conduct, Group Policy Anti-Corruption and other governing documents, which are implemented in all subsidiaries directly or indirectly controlled by Telenor ASA. Top-level commitment is vital for establishing a transparent and enterprise-wide culture that combats corruption. Our management sends clear, unambiguous and regular messages to all staff and business partners that corruption 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 Code of Conduct is approved by the Telenor ASA Board of Directors. The Sustainability and Compliance Committee (SCC) of Telenor ASA’s Board of Directors supports the Board in fulfilling its responsibilities with respect to ethics and anti-corruption. 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.
Our Anti-Corruption Programme
The Telenor Group Anti‐Corruption Policy provides that Telenor will actively prevent corruption through the establishment of a risk-based Anti‐Corruption Programme. The Programme’s core elements include conducting risk assessments; developing adequate procedures; conducting integrity due diligence of third parties; providing communication and training; monitoring and reviewing our risks and processes to identify improvement areas; enforcing sanctions; and top-level commitment. The Group Anti‐Corruption Policy and the effectiveness of the Anti‐Corruption Programme are assessed annually to ensure alignment with prevailing international standards. Telenor’s Governance framework clearly defines roles and responsibility for implementation of the Anti-Corruption Programme, both at Group level and locally in each subsidiary.
Anti-corruption in supply chain and third-party relations
Telenor expects our business partners to meet our standards and respect our values. Corruption in our supply chain may create significant risk for Telenor, even if we are not directly involved.
To mitigate risk in the supply chain, Telenor has implemented mandatory requirements for conducting integrity due diligence (IDD) and monitoring our suppliers. 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. The 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 and awareness activities in various forms in the local markets.
Telenor monitors compliance in our supply chain through a systematic, risk-based approach, which may include both announced and unannounced site visits and inspections. We encourage our suppliers to implement an efficient anti-corruption programme to minimise corruption risk.
Read how Telenor works with suppliers
Breaches of Telenor anti-corruption requirements
Telenor has established a whistleblower hotline, or “Integrity Hotline”, which is available to all employees and business partners. The Integrity Hotline is designed to protect the privacy of the people involved and allows for anonymous reporting. All reported concerns are taken seriously and given fair and objective follow-up. Anyone who violates the Code of Conduct or the Telenor Group Anti-Corruption Policy may be subject to disciplinary action, up to and including termination of employment. Such violations may damage Telenor’s reputation and result in commercial loss, and violations of the law may expose Telenor, and even the individual violator, to fines, penalties, damages and, in some cases, imprisonment. Telenor does not tolerate retaliation of any kind against those who speak up in good faith.
Telenor Group is a multinational company with operations in very different markets. Telenor’s governing documents set one single standard that 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.