Conflicts of Interest

A conflict of interest exists when our personal interest conflicts, or could be perceived to conflict, with Telenor’s interests

Personal interests include our financial interests, business opportunities, outside employment or the interests of people close to us, such as close family members, personal friends or business associates

Even the perception that we may not be acting in Telenor’s best interests can call into question our integrity and adversely affect our reputation

All decisions that are made on behalf of Telenor must be based on an objective and fair assessment of the company’s interest without being impacted by our personal interest

Openness and transparency are essential to manage actual, potential, or perceived conflicts of interest

A conflict of interest can still exist even if the company benefits in some way

We avoid conflict of interest and other situations which could impact our judgment

We recuse ourselves from situations and decisions where we have a potential conflict of interest

We promptly disclose actual, potential, and perceived conflicts of interest to our manager

We work with our manager to resolve conflicts of interest and document our decisions and actions

We always involve the Compliance Function if a conflict of interest cannot be avoided

We do not hold external duties or positions that could affect, or be perceived to affect, our responsibility to act in Telenor’s best interests

We obtain written approval from our manager before accepting external directorships or other material assignments, and we keep records in accordance with company procedures

If we have a financial or other interest in an existing or potential business partner of Telenor’s

If we hold outside employment or positions that could interfere with our ability to perform our duties for the company

If we are recruiting, hiring, or directly supervising a family member, friend, or individual with whom we have a close personal relationship

If we are offered anything of value in our personal capacity from existing or potential business partners including gifts, discounts or other benefits

If a business partner of Telenor is providing or will provide services to us in our private capacity