One of the Code Principles is that we "speak up." We ask our managers and the Compliance Function when we have questions about whether activities are ethical or compliant with our Code, and we always challenge and report activities that we believe may breach our Code or applicable law. Through reporting we enable Telenor to keep its promise to operate legally and ethically and we help the company to protect its good reputation. It is a responsibility that we share as Telenor employees.
It sometimes takes courage to come forward and share your concerns. If you are not comfortable discussing or reporting an issue to your manager or the Compliance Function, you may use the Integrity Hotline which is available to all employees, business partners and stakeholders. The Integrity Hotline is designed to protect the privacy of individuals who report a concern, and individuals who are the subject of a reported concern, through a reporting channel that is operated by an independent company. All reports are treated as confidential and a very restricted number of people are allowed access to them. The channel is always open and is available in most local languages. You may choose to remain anonymous. Your identity is kept confidential unless you agree otherwise.
All reported concerns are taken seriously and given fair and objective follow-up. The reports are first received and reviewed by Group Internal Audit & Investigation (GIAI). In cases that present serious allegations or concerns, GIAI will undertake an independent investigation to clarify relevant facts. Other cases are transferred to the Business Unit and managed by an appointed independent function. All functions are required to maintain all information in the strictest confidence to ensure the integrity of the process.
An important part of our compliance programme is taking effective corrective action and, where appropriate, employee discipline. In all cases, the Compliance Function supports management in resolving the investigated concerns to determine whether disciplinary or corrective actions are required. Anyone who violates the law, the Code, or a Telenor Policy or Manual 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.
It is important to remember that we can all report suspected unethical or illegal behaviour without fear of retaliation. Telenor does not tolerate retaliation of any kind against those who speak up in good faith.
Click on the Speak Up icon at the bottom of your screen if you want to report an incident to the Integrity Hotline or if you have a question to the Compliance Function about how the Code applies.