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Code of Conduct – Gjensidige’s ethical framework

Gjensidige is completely dependent on the trust of our surroundings to carry out our social mission, namely safeguarding lives, health and assets. Ethics is essential in this context.

The basis for our ethical work

From the CEO.
Our Code of Conduct, our ethical framework, is an important guiding principle for how we work on our attitudes, and describes what is expected of you as an employee or as someone acting on behalf of Gjensidige. It is therefore important that all members of staff familiarise themselves with our Code of Conduct, and act according to the code in their day-to-day work.

As a large, listed company, we are increasingly facing more requirements from customers, authorities, investors, analytics companies, and voluntary organisations.  They are concerned with how we conduct ourselves as a supplier of insurance services, as an investment manager and purchaser – and the attitudes we convey. We must increasingly document and highlight this for external stakeholders, so that they can evaluate us on the basis of publicly available information.

Our core values
The core values will contribute to forming a common identity and corporate culture throughout the Gjensidige Group. They will guide us in the right direction, whether we are carrying out small or large tasks, or making major or minor decisions. The following three core values will give us the energy to deliver the Gjensidige Experience:

Create a sense of security
A sense of security is created by leaving room for error, showing trust, openness, and listening to, seeing and supporting each other. A sense of security allows us to challenge the status quo, and takes us a step further. A secure setting gives us courage.

Apply new thinking
New thinking is about being inquisitive and being willing to do things better, be they big or small. Share your own thoughts and ideas, and actively engage in those of others. New ideas lead to learning, create dynamics, challenge us and take us one step further.

Go for it
Dare to go for it. Demonstrate determination and finish in style. Go for it! That is how we face the future head-on.

Code of Conduct (ethical framework)
Gjensidige safeguards life, health and assets. Our business is completely dependent on securing the trust of customers, authorities, shareholders and the rest of society. Everything we do must, therefore, stand up to public scrutiny.

This means that everyone who represents Gjensidige must conduct themselves in a careful, proper and fair manner, and in line with our ethical rules. It is the individual's responsibility to familiarise him with these and other guidelines. If an individual breaks the rules, it will have consequences for the Group, and for the individual.

Gjensidige’s basic rules of conduct

Open and honest communication
Open and honest communication is important, both internally and externally. This must naturally be weighed in relation to the necessary confidentiality and duty of secrecy. Open and honest communication is a prerequisite for making the right decisions and for elucidating all aspects of a matter. Furthermore, it is important that you report any matters that warrant criticism.

Only those authorised to make statements on behalf of the company may do so externally. You are also expected to be cautious about how you express yourself in social media in contexts where you could be perceived as a representative of Gjensidige.

Ethical rules
Gjensidige shall be characterised by high ethical standards. A good business culture and a positive reputation are preconditions for our business. You are responsible for keeping up-to-date with the guidelines and statutory provisions that apply to your area of responsibility. The ethical rules also provide guidance on how you should act in order to comply with Gjensidige's values and norms. If you are in doubt, contact your immediate superior.

The ethical rules can be viewed here

Discrimination and harassment
In Gjensidige, we have a joint responsibility to contribute to a team spirit and a good working environment. Each employee is expected to behave with respect and consideration and to display common courtesy in relation to colleagues, competitors, customers and others. By being inclusive and involved, we make each other better. Gjensidige has zero tolerance for discrimination and harassment. This includes unwanted sexual attention. Anyone who feels that they have been discriminated against or harassed shall be taken seriously.

Discrimination refers to unequal treatment due to gender, age, ethnicity, cultural background, religion, social affiliation, disability, sexual orientation, marital status or political convictions. Harassment refers to someone being subjected to negative actions over time from one or more persons.

How to help combat discrimination and harassment:

  • You must treat everyone with respect and openness.
  • Always keep in mind that reward and recognition should be given based on what a person does, not based on who he or she is.

Data protection and declaration of confidentiality
Data protection concerns the right to a private life and to control your own personal data.

Gjensidige's customers and employees must be able to trust that this information is handled in accordance with the applicable laws and regulations, and that relevant information is accessible and of a high quality.

All personal data must therefore be processed in a legal and fair manner, and in a way that enables the person concerned to access the information.  

Personal data shall only be obtained for specific, explicitly stated and justified purposes, and not be further processed in a manner that is incompatible with these purposes.

You are responsible for familiarising yourself with the relevant guidelines for your area of responsibility, and acting in accordance with these.

Corporate social responsibility and sustainability
Gjensidige has taken its corporate social responsibility seriously and created a sense of security for over 200 years. We are expected to do even more going forward. Corporate social responsibility is ingrained in the overall strategy and is recognised in the Group as a key factor for long-term, sustainable value creation. Goals that will influence our choices in future have been developed as a means of implementing the overall strategy. Gjensidige’s sustainability goals also underpin the UN's sustainable development goals, and form the basis for status reports on our work in relation to climate and the environment, social conditions, and management and control.

Health, safety and the environment (HSE)
Gjensidige aims to develop and maintain a positive internal working environment. It is, therefore, important that our employees take active responsibility for ensuring a good working environment. In order to succeed in our HSE work, every individual must be familiar with their duties and adhere to the guidelines that apply to their work.

How to act according to our HSE rules:

  • You are familiar with the laws, regulations and established procedures that apply to your work.
  • You contribute to a secure and positive working environment and prevent harm to the natural environment
  • You speak out when you need competence-raising measures and training.
  • You use the necessary protective equipment or other aids as necessary or when required.
  • You inform your employer or safety delegate if any harassment or discrimination is brought to your attention.
  • You contribute to the development and implementation of follow-up plans if you are absent due to an accident, illness, etc.
  • You inform your immediate superior of any breaches of laws/regulations/errors or defects (deviations)

Notification
Notification (whistleblowing) means reporting censurable matters to someone who can do something about them. Examples of censurable matters are violations of statutory provisions and internal rules and guidelines.

Since such matters can be rectified, notification is essential, both for the Group and for society at large. Employees who are willing to report censurable matters are therefore an important resource for the Group.

There are several channels for giving notification. Employees can always give written or oral notification to their superior, the HR partner, Director of Risk Management HR, employee representatives, safety delegates or the chair of the Working Environment Committee. You can also use Gjensidige's notification channel, where you will also be able to remain anonymous.

How to become a good whistle-blower:

  • You familiarise yourself with our notification procedures.
  • You inform us of unacceptable conditions, and notify us about censurable matters in the workplace.
  • Keep in mind that you have a special duty to report criminal offences, or if life or health is at risk.

Good business conduct

Customer service
Gjensidige shall know the customer best and care the most.

Everyone acting on behalf of Gjensidige is responsible for giving our customers a good experience – the Gjensidige Experience. Everything we do should be characterised by a great degree of integrity and that we care. We must treat all customers with respect and in line with good business practice and industry standards.

How we create the Gjensidige Experience:

  • We keep our promises
  • We always deliver quality
  • We make complicated things simple
  • We ensure that the customer is satisfied.

Openness and honesty
Openness is a prerequisite for motivation, trust and security. That is why openness should define our corporate culture. Everyone should feel safe to discuss both small and big issues with their superior or with others in the Group. Everything we do must stand up to public scrutiny. It is important that we can justify everything we have done, how we have evaluated and which decisions we have made.

How to contribute to openness 

  • You should be able to document everything you do in accordance with the rules that apply to your work.
  • Everything you do must stand up to public scrutiny and maintain trust in Gjensidige.

Compliance
All employees and others who act on behalf of Gjensidige must adhere to laws, regulations and agreements in all aspects of our business. This applies to both external requirements and internal regulations, such as agreements, policies, standards, instructions, processes and routines/procedures. Deviations must be handled in accordance with the Group’s procedures for handling deviations and incidents.

Where regulations overlap, the most restrictive regulations apply, unless otherwise stated.

How to be compliant: 

  • You are familiar with and follow the rules and procedures that apply to your work.
  • You consult a more experienced member of staff or a manger if you are in doubt.
  • You are familiar with and follow set procedures for reporting any breaches of internal or external rules.

Money laundering and corruption
Money laundering is a social problem that both Norwegian and International law demands we actively combat.

Gjensidige must actively combat money laundering, financing of terrorism and corruption. We must do what we can to protect Gjensidige from being exploited by criminals, and the potential risk of damage to our reputation, trust and money.

How to combat money laundering: 

  • You are familiar with and follow set rules and procedures that apply to anti-money laundering, financing of terrorism, and anti-corruption.
  • You can identify suspicions of money laundering, financing of terrorism and corruption.
  • You report any suspicions of money laundering, financing of terrorism, and corruption in accordance with the Group's procedures.

Gift registration
Before you give/accept a gift/activity, you must be aware of the gift’s/activity’s value, whether it/they are appropriate, and how frequently the transaction occurs. Assess whether the gift/activity entails a sense of obligation or influences evaluations. Keep in mind that everything we do must stand up to public scrutiny.

Employees or related parties cannot give or accept gifts or other benefits (private discounts/bonuses, etc.) worth more than NOK 500. Relation-building activities must be in accordance with our guidelines. Gjensidige strives for transparency, and all gifts and relation-building activities not conducted under the auspices of the employer, must be registered in the Group's gift register, with its estimated value.

How to proceed when you receive a gift/activity:

  • You must assess whether ethical rules and other regulations permit the receipt of gifts/activities.
  • You cannot receive gifts from external parties worth more than NOK 500.
  • If you accept gifts/activities from external parties worth less than NOK 500, this must be registered in the gift register.

 

Every employee has a responsibility to protect Gjensidige

Protecting our values, information and brand
Everyone acting on behalf of Gjensidige has a duty of secrecy in relation to business matters and matters of a private nature relating to customers, employees and others that they become aware of in connection with their performance of work for the Group. The duty of secrecy also applies after the employee leaves Gjensidige.

We must also prevent internal communication being distributed outside the company.

How to take responsibility for protecting values, information and the brand:

  • You are familiar with and follow the information security rules and procedures that apply to your work.
  • You report any information security breaches immediately.
  • You neither distribute nor take assets and information outside Gjensidige without an official need.

Conflicts of interest (impartiality)
You must not take part in – or seek to influence the processing of – a case if there are circumstances that could diminish trust in your independence/impartiality. If you have a direct or indirect financial or other personal interest in a case, you must not become involved in the processing. As a rule, lack of impartiality on the part of a superior also means that the case cannot be decided by anyone reporting directly to him/her.

How to avoid conflicts of interests:

  • You are open about personal and close relationships to other Gjensidige employees.
  • You discuss relevant issues with your immediate superior or others in the professional environment.
  • You must report any situations in which a conflict of interest may arise.

Insider information
As a listed company, Gjensidige must comply with the provisions of the Securities Trading Act when handling inside information. As an employee or a representative of Gjensidige, you could be granted access to information that could be defined as inside information and that could influence the price of the Gjensidige share or another financial instrument.

None of us must use or contribute to use by others of inside information about the Group or other companies as a basis for trading in securities.

How to deal with inside information

  • You are expected to act in accordance with the relevant inside information guidelines, to ensure such information is not misused. You are also expected to act with due care when trading in financial instruments.

Intoxicants
When alcohol is served at various events after working hours in Gjensidige, alcohol should be consumed in moderation, without abusing the substance, and without endangering health and social relations.

All events organised by the company for the employees must be organised in such a way that they do not encourage excessive alcohol consumption. Furthermore, non-alcoholic beverages must be as accessible as alcoholic beverages.

Leaders have a particular responsibility to practice what they preach, display attitudes and set norms through their own behaviour, also in relation to alcohol. This applies both in relation to internal and external events. The individual leader must be loyal to Gjensidige’s provisions, and he/she is responsible for creating a good organisational culture and a good working environment in their area of responsibility.

Each employee is responsible for ensuring that their alcohol consumption is appropriate, in relation to the company’s guidelines and the individual event. Inebriation that endangers one’s own and/or the life and health of others, causes offensive or socially unacceptable behaviour, is not acceptable under any circumstances.