Corruption puts long-term value creation at risk and createsdistrust in society’s systems. It can lead to court cases and fines, or other sanctions, as well as the loss of market access, assets, and the right to operate banking operations. There are many different forms of corruption and our code of conduct is intended to contribute to, among other things, fighting corruption, extortion, bribery, whitewashing, fraud, terrorist financing, and the financing of other criminal activities. The code of conduct is intended to make people aware of the potential dilemmas and ensure that all of our employees maintain high ethical standards.
The group has its own ethics committee, which regularly assesses whether the code of conduct satisfies the requirements and expectations of customers, suppliers and society as a whole. The ethics committee includes representatives of several business areas: the EVP, Communications and Sustainability, the EVP, HR and Business Support, legal, corporate market, retail market, compliance and AML, organisation and HR, credit activities, and union representatives from the Finance Sector Union of Norway. The committee met twice in 2018.
All employees must sign the code of conduct every year. Annual refreshers on ethics are also provided via the authorisation scheme for financial advisers and the approval scheme for salespersons and advisers in non-life insurance.
The anti-corruption work includes ensuring new employees read and sign the code of conduct. This is also included as a topic in Ethics Week. We completed an anti-corruption training module for SR-Bank’s managers in 2016 and new training is planned for 2019, as part of the bank’s three-year skills-cycle. The group will also base its compliance control work on the ISO 37001 standard for anti-corruption. The control model complies with the ISO standard and the group prepares routines and control actions for the work. We review specific transactions and activities, planned and existing business connections, and various categories and groups of 23 employees. The assessments take a risk-based approach and the inspections include financial and non-financial control actions. Reporting lines have been established and any measures are followed up in line with existing routines.
Whistleblowing routines have been established for anonymous, written and verbal reports.
The routines specify:
• that whistleblowers are protected against reprisals
• how reports should be submitted – externally anonymously or not anonymously via multiple channels, including via an application that uses an untraceable QR code
• the requirements that apply for processing reports
The bank has established an external whistleblowing agreement with the law firm EY. The information will be treated confidentially by dedicated case offices in EY