All Business Partners and other stakeholders shall be treated with respect and integrity, impartially and fairly.
Business Partners include customers, suppliers, Market Representatives (agents), joint venture partners, other cooperation partners, receivers of sponsorships and charitable contributions. Other stakeholders include investors, owners, finance institutions, governments.
We will do our outmost to conduct our operations and all our interaction with Business Partners within applicable laws and regulations. Before entering into an agreement with a Business Partner, we shall know that the Business Partner’s ethical standard are satisfactory.
The use of Market Representatives (agents) can pose a particular risk to our operations or reputation. In such cases we will apply strict mandatory processes to govern the selection of Market Representatives, together with a strong focus on the composition of the compensation model and follow up during operations.
KONGSBERG requires that our Business Partners act in compliance with requirements set forth in agreements enclosing this Code, our Supplier Conduct Principles or other regulation of similar ethical standard.
Corruption undermines legitimate business activities, distorts competition, ruins reputations and exposes companies and individuals to risk.
KONGSBERG is opposed to all forms of corruption, irrespective of which country we operate in, and will adhere to the Norwegian anti-corruption law, as well as other relevant international anti-corruption legislation.
Corruption is defined as a prohibition for anyone, for himself or other persons, to demand, receive or accept an offer of an improper advantage in connection with a position, office or assignment, or to offer or give any person the same. An improper advantage can include (but not limited to) cash, tangible gifts; cost coverage, discounts, payment of travel or lodging expenses, services, attendance to social events etc.
KONGSBERG thus prohibits for anyone to demand, receive or accept an offer of an undue advantage in connection with a position, engagement or task, or to promise, offer or give any person the same. The same also applies to promising, offering or giving any person an undue advantage, or requesting or accepting the same, if the purpose is to seek to influence someone else in their position, engagement or task. Aiding in such activities is also prohibited. This relates to situations with both governmental officials and private commercial counterparts.
KONGSBERG employees and other who acts on behalf of KONGSBERG shall always consider the following:
Could the activity involve any risk for corruption?
Is it within the law and comfortably within KONGSBERG‘s own ethical requirements?
Are the current activities transparent on both KONGSBERG’s side and the other parties’ side?
How will the activities appear if they became public or known to law enforcement authorities?
Gifts and hospitality
KONGSBERG encourage our employees to build and maintain relationships with our Business Partners through networking and social interaction, and at the same time always be aware of relevant legislation and our internal rules for gifts and hospitality.
Networking and social activity shall be business-related, reasonable and justifiable, and not lavish nor excessive, and never exercised to an extent that can be perceived as bribery or corruption, or raise question about potentially being a violation of the antitrust laws.
Giving and accepting gifts or hospitality that could affect business decisions shall be avoided. Special care shall be exercised during negotiations, decision-making processes, bids, tenders and similar situations. Gifts and hospitality shall always be made in a transparent way, within your authority or approved by your superior.
Gifts shall be modest and reasonable. KONGSBERG encourage giving promotional items bearing KONGSBERG’s name or logo.
Special caution shall be demonstrated when dealing with public officials, both national and foreign. Gifts and hospitality shall always be in accordance with the public officials internal rules, if more strict than ours. Payment of money or giving anything else of value to any public official as an individual, directly or indirectly, is not allowed under any circumstances.We will pay our own costs for travel expenses etc. and similarly KONGSBERG enables business associates to pay their own travel expenses etc., when invited to events organised by KONGSBERG.
Sponsorship, Political and Charitable Contributions
Special caution shall be taken when assessing sponsorships and charitable contributions due to the potential for appearance of impropriety and any risk of corruption. KONGSBERG shall not give political contributions, even if combined with charity, Charitable contributions shall fully comply with public disclosure requirements and shall be reported according to internal processes.
Facilitation payments are payments of small sums of money to facilitate or expedite the performance of routine government functions, such as issuing permits or licenses or processing government papers, to which one is anyway entitled.
KONGSBERG consider facilitation payments as a form of corruption, and payments of this kind is not permitted under this Code.Exemptions where facilitation payments are deemed not to be illegal are few and interpreted narrowly. Only in exceptional cases and only in order to protect life, liberty, health or, in strictly limited situations, property, from imminent threats, the prohibition against facilitation payments will not apply. Such situations shall therefore always be considered carefully with a view to their legality and necessity. In line with the general principle of correct and transparent accounting, any facilitation payment shall be recorded as such with an explanatory note correctly describing the situation that made the payment legal by exemption.
KONGSBERG shall compete fairly, and build our business and reputation on world-class quality. KONGSBERG will compete in a respectable and ethically responsible manner within the framework of antitrust and competition laws and regulations that apply in the markets in which the Group operates. Abuse of any dominant position is prohibited.
We don’t fix prices with competitors
We don’t engage in bid-rigging
We don’t engage in market allocation
We act carefully in trade associations
We don’t share commercially sensitive information with competitor
KONGSBERG is committed to complying with all applicable export, import, transit and trade compliance laws in all countries in which KONGSBERG does business. These laws include embargoes, sanctions, customs, product/country of origin marking, and anti-boycott laws. In conducting business, employees must be aware of and follow these laws and regulations.
Particular focus is placed on export of weapon systems and other military equipment, related technology and services. In Norway, and most other countries where KONGSBERG operates, export controlled equipment, services or technology, may only be exported based on a Governmental export license. Sanctions may apply regardless of the export classification and therefore we shall check the customer, and parties involved in the transaction against sanction and embargo lists.
Failure to comply, or failure to report any possible deviations, can cause severe penalties and restrictions on our business in the future.
Money laundering can be defined as transforming the proceeds of crime into the legitimate economy. It will can often be seen in connection with other types of crime, including drug trafficking, terrorism, corruption and tax evasion.KONGSBERG is firmly opposed to all forms of money laundering, and will comply with all applicable antimoney laundering laws, and take steps to prevent our financial transactions from being used by others to launder money.Before entering into a customer agreement KONGSBERG shall ensure that the customer is legally established and conducting a law-abiding business.
KONGSBERG's international presence mean that we must comply with a wide variety of tax legislation in many countries. In our opinion, a responsible approach to taxation is decisive for our long-term activities in the countries in which we operate.
This includes identifying and complying with current tax legislation, disclosing all the necessary information to the relevant authorities, and taking prudent tax positions where tax legislation allows different interpretations or choices. Transactions shall only be made if they satisfies the requirements for form as well as content pursuant to the tax legislation of the countries in question. KONGSBERG shall not employ "artificial" structures in tax havens to avoid paying tax.
All our employees shall maintain professional secrecy in respect of all business matters and other situations that could give outsiders access to confidential information.
We respect obligations of confidentiality related to information entrusted to KONGSBERG by third parties such as customers and Business Partners. An obligation to keep information confidential may follow from agreements or other forms of mutual understandings, and/or relevant laws and regulations.
Anyone working on programs on behalf of KONGSBERG including information protected by military classification rules shall adhere to any applicable security regulation, including safety obligations as set out below.
KONGSBERG are according to national safety legislation required to safeguard all military classified information in its position by:
Establishing and maintaining a system for protecting all classified documents and/or equipment and obtaining the necessary system and site approvals from our customers and national security authorities.
Ensuring that all employees and subcontractors that are given access to classified information have the necessary security clearances and authorization.
The collection and use of personal data is regulated by a growing number of countries. The commom feature for these countries are more stringent regulating of personal data as names, residency, contact information etc, both for employees, consumers and company representatives in business-to-business transactions.
KONGSBERG will handle personal data in accordance with applicable laws and regulations.
Conflicts of interest
KONGSBERG shall respect individual employees' right to privacy and personal interests, at the same time as all employees are expected to be loyal to KONGSBERG’s interests.
Employees shall not participate in financial or business-related activities that could potentially involve a conflict between KONGSBERG and their own personal, familiar or a close third-party's interests.
A conflict of interest, or even if it can appear as a conflict of interest to others, shall be disclosed to your manager. All directorships, employments or other assignments held or carried out by KONGSBERG employees in other enterprises that have, or may be expected to have, commercial relations with KONGSBERG, must be approved by KONGSBERG management.
Intellectual property rights
KONGSBERG's intangible assets are fundamental to our business. They include our knowledge, ideas, structures and working methods. These values shall be safeguarded and managed in the best interest of KONGSBERG. By the same token, we shall show respect for the corresponding values of others.
Correct information and communication
Information provided about KONGSBERG's business operations shall be communicated precisely and correctly, inside and outside KONGSBERG. Communication is a management responsibility and responsibility shall follow line management. All information not already public is confidential information. Within our obligations of confidentiality, KONGSBERG shall stand for open, correct and reliable business practices.Likewise, and at least as important, KONGSBERG shall respect the corresponding values of our Business Partners, suppliers and other third parties.
All employees, shall exercise the highest standard of care in preparing information and communication materials.
Insider information is confidential and share price sensitive informationd shall not be shared to any unauthorised individuals or companies.
Use of social media
All KONGSBERG employees can be exposed to security issues and it is important that use of social media occurs in a safe and proper manner.
Be transparent: If you are posting about KONGSBERG’S products/technologies, you must disclose that you work for KONGSBERG. Never misuse or disclose confidential information.
Be truthful: If you have a vested interest in something you are discussing, be the first to point it out and be specific about what it is.
Be yourself: Stick to your area of expertise; only write what you know. If you publish to a website outside KONGSBERG, please use a disclaimer like this one: “The postings on this site are my own and don't necessarily represent KONGSBERG’s positions, strategies, or opinions.”
Be up-to-date: If you are leaving KONGSBERG, please remember to update your employment information on social media sites.
Accounting and reporting
All accounting and reporting shall be in compliance with accepted accounting standards and relevant legislations.
Payments to Business Partners shall only be made against invoices that are issued based on agreements in writing between KONGSBERG and the other party.
Payments from KONGSBERG shall be made by bank transfer. All company funds shall be used prudently and in agreement with KONGSBERG’s governance documents.
No transaction may be intentionally misclassified, e.g. as to accounts, departments or accounting periods.
No information may be concealed from auditors; internal, external or other independent auditors.