Public Officials

We follow high ethical standards when interacting with public officials.

What we need to know

Public officials include all individuals employed by or acting on behalf of a government including anyone holding a legislative, administrative, executive or military office

Public officials execute governance functions that are vital to the societies in which we operate and are also vital to 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

Individuals employed by state-owned companies may be considered public officials

What is expected of all of us

We do not engage in conduct which could, or could be perceived to, improperly influence a public official

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

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 and only 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 ensure the third party towards whom any lobbying activity is being conducted is aware of our relationship with the lobbyist. In the event a lobbyist is used, it shall be promptly disclosed to the third party the lobbyist represents Telenor. The obligation shall be included in the agreement with the lobbyist

We do not engage in external discussions with public officials on behalf of Telenor unless we have been previously authorised to do so

What to look out for

If a business partner directly or indirectly interacts with public officials on our behalf

If a public official asks for the personal data of Telenor employees, customers or any other individual

If a public official requests Telenor to send information or messages to our subscribers

If a public official owns, manages or is affiliated with a business partner

If a public official, or a close family member or business associate of the public official, applies for a position within Telenor

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