Why we have a Code of Conduct

As a company with strong values, our conduct is not only about performance, goals and achievement. It is also about how we behave towards each other and the world around us. We strive to be a trusted partner – to our customers, shareholders and colleagues, and to our business partners and the communities in which we operate. Our business depends on this trust and we are committed to conducting our business in a responsible, ethical and lawful manner. The Code of Conduct is the foundation of our corporate culture and sets out high standards of integrity on how we do business. Everyone in Telenor must follow these standards. We make decisions every day that may influence our reputation. An uninformed decision, even made with best intentions, can damage our reputation.

The Code Principles set out the core requirements for our conduct in Telenor. The Code Sections include specific requirements and guidance for critical risk areas. The Code of Conduct helps us all make informed decisions and explains where to go for more information and guidance.

Code Principles

The Code Principles form the foundation of our ethical culture and define the core of our business conduct.

We play by the rules

We follow laws, regulations and our policies and, if these are in conflict, we uphold the highest standard

We are accountable for our actions

We actively seek information, understand our responsibilities, and recognise our wider impact on the societies in which we operate

We are transparent and honest

We are open and truthful with our challenges

We speak up

We ask questions and raise concerns when in doubt and we encourage others to do so by creating a culture where retaliation against those who report a concern in good faith is not accepted.

Who must follow the Code

The Code of Conduct applies to all employees and everyone acting on behalf of Telenor, including the Board of Directors. We also expect our business partners to commit and uphold the same high ethical standards.

How to use the Code

The four Code Principles and specific requirements contained in the Code Sections form our basic obligations. Additional requirements in our Policies and Manuals must also be understood and followed. At the end of each Section of the Code you will find links to the applicable Policies and Manuals as well as links to available guidelines, practical tools, training material and other helpful resources.

The Code sets clear requirements for our day-to-day operations and guides us when we are confronted with challenges and ethical dilemmas. You may always contact your line manager or the Compliance Function when you have questions or concerns. You may also seek advice or ask a question using the Integrity Hotline, and may even remain anonymous if necessary.

The Code cannot cover every dilemma or situation we will face in our day-to-day work. There will continue to be business challenges and uncertain legal and regulatory developments. In such cases, we are not relieved from the obligation to uphold the highest ethical standard, but we should seek guidance to help us make the right decision. Beyond setting out our own ethical standards, the Code Principles require us to comply with applicable laws and regulations. You should always familiarize yourself with the laws where you operate and seek guidance from the Legal Function if you have questions.

What is expected from us as employees

As an employee of Telenor, you are expected to:

Always act with high integrity

Read, understand and follow the Code, Policies and Manuals

Raise issues of concern as described under the section “How to Speak Up”

Attend training sessions on the Code in a timely manner

Know when and how to seek further guidance

Cooperate fully and transparently in all investigations

Avoid any practices that may be unlawful, unethical or harm Telenor’s reputation

Assess the risks you may encounter and seek appropriate training and guidance to effectively manage them

What is expected from our leaders

Leaders in Telenor are not only expected to follow the requirements above, but are also expected to:

Live the “Tone from the Top” and communicate regularly on the importance of compliance

Identify and anticipate business compliance risk areas that affect your teams’ operations

Proactively identify actions that will mitigate compliance risks

Ensure that teams are sufficiently trained and prepared to deal with relevant dilemmas and provide guidance where necessary

Foster an environment of open reporting to ensure that all team members are comfortable raising concerns without concern of retaliation

Act as role model for our behaviours as demonstrated in decision-making and other processes

Promote diversity and inclusion in the workplace

Use high standards of integrity as a criterion in recruitment and promotion processes

Avoid strategies, targets or timelines that could create pressure on employees or business partners to engage in unethical business practices