What we need to know

  • Public Officials execute governance functions that are vital to the societies in which we operate and our license to operate there
  • Telenor interacts with Public Officials at various levels and for many different purposes
  • Information shared with Public Officials may become public due to laws regulating public access to government held information
  • Public Officials include all individuals employed by or acting on behalf of a government including anyone holding a legislative, administrative, executive or military office

What is expected of us

  • We do not engage in conduct which could, or could be perceived to, improperly influence a Public Official
  • We always provide truthful and accurate information to Public Officials
  • We exercise appropriate caution toward Public Officials when Telenor is engaging in a commercial or approval process
  • We are always compliant with local laws or rules that apply to Public Officials, including those on business courtesies
  • We understand that individuals employed by state-owned companies may be considered Public Officials
  • We do not offer gifts to Public Officials except promotional items of minimal value, and only when it would be customary to do so
  • We do not pay travel, accommodation or related expenses for Public Officials
  • We offer only modest hospitality to Public Officials when there is a clear and legitimate business purpose, the costs are reasonable, and the context is open and transparent
  • We always discuss offering business courtesies to Public Officials with our manager and seek guidance from the Compliance Function as needed
  • We do not make facilitation payments to Public Officials and we report requests for such payments to the Compliance Function
  • We only use lobbyists to advocate on our behalf in special circumstances with full transparency and with prior written approval by the Business Unit CEO
  • We do not engage in external discussions with Public Officials on behalf of Telenor unless we have been previously authorized to do so
  • We seek exceptions only in special circumstances subject to a review by the Compliance Function and prior written approval by the Business Unit CEO

What to look out for

  • A Business Partner directly or indirectly interacts with Public Officials on our behalf
  • A Public Official asks for the personal data of Telenor employees, customers or any other individual
  • A Public Official requests Telenor to send information or messages to our subscribers
  • A Public Official owns, manages or is affiliated with a Business Partner
  • A Public Official, or a close family member or business associate of the Public Official, applies for a position within Telenor

Resources and Tools