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Ethical rules for Gjensidige

Laid down by the Board 19 September 2013
Last revised 12 December 2019

Gjensidige is defined in this context as the Gjensidige group.

The main principles are described in greater detail below.

 

1. Gjensidige values

Gjensidige's social mission is to safeguard people’s life, health and assets, and to do so in a manner that takes all the company’s stakeholders into consideration.

A good business culture and a positive reputation are fundamental preconditions for Gjensidige's operations. We depend on the trust of our customers and shareholders, the authorities and society at large. In order to gain this trust, we must make sure that everything we do is characterised by professionalism, expertise and high ethical standards. This applies to both business operations and how employees behave. All employees must act with due care, honesty and objectivity, and must refrain from doing anything that can undermine people’s trust in the Group. Managers have a particular responsibility and must set a good example.

All Gjensidige's activities must stand up to public scrutiny. Employees are therefore expected to behave in accordance with the Group's ethical rules. Employees who are in doubt as to what this means must contact their immediate superior.

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2. Target group

The ethical rules apply to all employees and officers of the Group, and to hired consultants when they act on behalf of the Group (cf. section 6.8 of the impartiality rules).

The ethical rules do not impose any legal obligations on customers or other third parties, such as closely related parties, but employees are required to take relations with these parties into account in their compliance with the ethical rules.

3.Other regulations

The ethical rules set out requirements for ethical conduct, but they do not cover all aspects of what constitutes ‘correct behaviour’. The Group has other guidelines and regulations that supplement the ethical rules. It is important, therefore, that employees use their own judgement as regards how to act in an ethically correct manner in each individual situation.

In addition to following the ethical rules, the employee must loyally comply with laws, regulations, circulars, relevant codes of ethics for the industry and internal rules that regulate the Group's activities. Managers must ensure that employees are given an opportunity to familiarise themselves with the rules that apply to their particular field of work. However, it is the employee’s own responsibility to follow these rules.

4. Openness and trust

The Group's corporate culture shall be based on openness, which is a precondition for motivation, trust and sense of security. We want all employees to feel secure about raising both minor and major issues with their superiors or others within the Group.
 
The ethical rules will not always tell us what is right and wrong in a given situation. It is important to raise relevant matters or actions with others if employees are unsure. When in doubt, an employee should discuss the matter with his/her manager or the HR department. Another option is to use the ethics mailbox. All enquiries will be treated confidentially.

5. Good business practice

5.1. Human rights
The Group shall respect fundamental human rights, among other things as described in the UN Universal Declaration of Human Rights and by the International Labour Organization (ILO). The Group’s financial investments shall be in accordance with recognised principles for ethical investments from a human rights perspective.

5.2. Environment and procurement
Gjensidige shall endeavour to reduce the business's environmental impact on society, and ensure that employees can do the same.

The Group is a major purchaser of goods and services. We must therefore make active endeavours to ensure that manufacturers and suppliers conduct their business operations in accordance with internationally recognised principles and guidelines relating to human rights and labour rights, the environment and anti-corruption. Products delivered to Gjensidige shall meet our environmental requirements.

5.3. Healthy competition and sales

The Group shall always act in accordance with relevant competition and marketing legislation. We must show due care in connection with work carried out under the auspices of industry associations, and where competitors are involved. Such work shall always be carried out in accordance with the remits and/or guidelines we have prepared in advance.

The Group must not engage in any form of sales or marketing that can be perceived as offensive or that comes into conflict with accepted social norms. We must always give advice based on the customer’s needs, financial situation and willingness to take risk, and the advice must serve the customer’s interests. We shall know the customer best and care the most.

 

5.4. Tax and public regulations
Gjensidige shall endeavour to reduce the business's environmental impact on society, and ensure that employees can do the same.

The Group is a major purchaser of goods and services. We must therefore make active endeavours to ensure that manufacturers and suppliers conduct their business operations in accordance with internationally recognised principles and guidelines relating to human rights and labour rights, the environment and anti-corruption. Products delivered to Gjensidige shall meet our environmental requirements.

 5.5 Corruption

Corruption means abusing one's position to obtain personal or business advantages for oneself or others. Through its anti-corruption programme, the Group shall actively endeavour to prevent corruption.

No one may accept benefits for themselves or others from the Group’s business connections if such benefits are a result of their employment relationship. Correspondingly, no one may offer such benefits to business connections. Such benefits can be gifts, discounts, travel and rewards in connection with private purchases, loans etc. This does not apply to more trivial gifts (cf. section 6.6). Advantages that the Group has negotiated for all employees in a country or parts of a country where the Group operates are an exception from this rule.

Employees must not let their decisions or actions be influenced by undue pressure or offers of financial advantages from parties with an interest in the matter. Nor may they recommend or take the initiative for violation or evasion of applicable laws and regulations against corruption and financial crime.

Employees must be familiar with the content of the Gjensidige leaflet ‘Do you know enough about corruption?’.
 

5.6. Money laundering
Money laundering means converting the proceeds of criminal offences into apparently lawful revenues or capital gains. The Group must avoid any dealings with funds that stem from criminal activities. We have established procedures that employees with first line customer contact must follow to reduce the possibility of money laundering.

6. Personal conduct

6.1. Discrimination and bullying
All Gjensidige employees have a shared responsibility for building a team spirit and a good working environment. The Group expects employees to behave with respect and consideration and to display common courtesy in relation to colleagues, competitors, customers and others. By being inclusive and committed, we make each other better. Discrimination or harassment shall not occur. Anyone who feels that they are being discriminated against or harassed shall be taken seriously.

6.2 Relations with managers and colleagues
Gjensidige aims to create a positive, stimulating and enthusiastic working environment. Trust, respect, cooperation with and openness in relation to managers and colleagues are fundamental to achieving this goal. All employees have a responsibility for helping to create a good working environment in Gjensidige.

6.3 Duty of secrecy
Employees have 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 the performance of their work for the Group. This duty applies unless they are legally obliged to disclose the information or are obliged or urged to report such matters pursuant to these ethical rules. The duty of secrecy does not just apply in relation to third parties, but also between the companies in the Group. The duty of secrecy also applies in relation to other people in Gjensidige who do not need the information in their work.

The duty of secrecy applies in relation to colleagues, advisers, family and others unless the party entitled to confidentiality has expressly consented to the exchange of such information. The CFO or a person authorised by the CFO may, in specific cases concerning financial matters, consent to the exchange of information.

The duty of secrecy also applies after an employee has left his/her job with Gjensidige.
 
An employee shall not actively seek information about other employees or about customers via the computer systems or in any other manner, unless this is necessary for his/her work in Gjensidige.
 

6.4 Relations with business connections
No one may act in a way that prevents them from acting impartially in relation to the Group’s customers, suppliers, shareholders or other business connections of the Group.

Employees must exercise caution when entering into private agreements and exchanging services with companies and persons with whom they have dealings through their work for the Group. They must also exercise caution in relation to business agreements with persons with whom they have a private relationship.

If an employee has private relations with a business connection, they must notify their immediate superior.
 

6.5 Hospitality and events
Employees who, by virtue of their position, represent or can be identified with the Group must conduct themselves in a way that wins the trust of both Group and other employees.

Events organised by the Group shall be characterised by moderation and have a relevant and adequate professional content.
 
Any travel and accommodation expenses incurred by external parties invited to an event shall be covered by those parties themselves, either directly or through a participation fee.
Employees who are considering participating in trips or events under the auspices of Gjensidige's business connections must clarify this with their immediate superior. Travel and stays in connection with the performance of work for Gjensidige shall as a rule be covered by the Group. Any deviation from this rule must be clarified with the employee’s immediate superior. This also applies to travel and accommodation in connection with seminars and other job-related events that are covered directly or as part of the participation fee.

Sponsor activities shall be in accordance with Gjensidige’s sponsorship strategy.

Gjensidige has prohibited political donations, and full transparency is required about all payments that can be perceived as support for an organisation.

 

6.6 Gifts and benefits
Employees must exercise great caution with respect to accepting gifts or other benefits from customers, suppliers or Gjensidige’s business connections. An employee or his/her closely related parties (see section 6.8) cannot receive gifts worth more than NOK 500 from any one party per calendar year. If there is a risk that employees' impartiality or independence can be put in doubt, the gift must not be accepted. If gifts are returned, this shall be done in a manner that causes as little offence to the donor as possible.

An employee must not accept gifts or services of any kind in connection with or prior to entering into negotiations or as a return favour for entering into business agreements on behalf of Gjensidige.
Corresponding restrictions apply when gifts are given to business connections. Gjensidige’s motives and the integrity of the recipient must be beyond doubt.
Gjensidige wishes to ensure transparency, and all gifts received and relation-building activities attended shall be registered in the Group’s gift register.

 6.7 Family relations

As a rule, siblings, parents/children, spouses/cohabitants or other closely related parties shall not work under the same manager (line manager) or in the same department under a member of the senior management. Any deviations from this rule must be clarified in advance with HR. Employees who are closely related shall not obstruct, assess, approve, audit, check or in other way influence each other's work.

6.8. Impartiality
No one may participate in or influence the handling of or decision in a matter where circumstances exist that could weaken trust in his/her independence.

No one may consider, decide or seek to influence a matter if he/she or a closely related party has any direct or indirect financial or other personal interests in the matter. By closely related parties is meant spouses, cohabitants and children, as well as any companies, associations, clubs etc. in which the employee or any of his/her related parties have a significant influence. Other personal relations may also be of such a nature that they are regarded as equivalent to closely related parties (for example neighbours, close friends etc.).

As a rule, if a superior is deemed to be disqualified on grounds of partiality, this also means that the matter cannot be decided by anyone reporting directly to him/her.
Employees shall inform their immediate superior as soon as they become aware that a conflict of interest can arise. The superior shall consider whether there is a risk that the employee's impartiality or ethical integrity can be put in doubt by other employees or external parties. If such case, he/she must not participate in further consideration of the matter.

Employees must not use their position to influence appointments so that preference is given to a candidate on the basis of other criteria than those that are of direct relevance to the position in question.

 

6.9 Secondary occupation and participation in other companies and organisations
No employee may, without the employer's consent, work for, serve on the board of, operate or have financial interests in undertakings that engage in the same type of business as one of the Group’s companies or that have business relations with such companies.

If an employee whose primary position is with the Group wishes to start a private business or take paid employment during his/her free time, he/she must ask his/her employer in advance. If the secondary job/office can be combined with fully satisfactory work performance and with his/her position in the Group, the employee may be permitted to hold a secondary job/office. If this secondary job/office proves to be so demanding that it becomes detrimental to his/her work for Gjensidige, the secondary job/office must be approved by his/her superior. Managers shall be informed about political offices, which are regulated by law, and arrangements shall be made to minimise any inconvenience to the Group.

Employees must notify their immediate superior if they or their closely related parties have ownership interests in businesses that have customer or supplier relations with Gjensidige. If there is a risk that such ownership interest will give rise to doubt about the employee’s loyalty or independence, Gjensidige may demand that the ownership or customer relationship be terminated and set a deadline for its termination.

Unless expressed permission has been obtained from the employee's immediate superior, an employee in an executive position cannot participate as a responsible member or board member of companies engaged in business.

Other employees may hold offices outside Gjensidige. If an employee is in doubt about whether such an engagement will affect their work in the Group or is in conflict with the Group's values, they must raise the matter with their immediate superior. In cases where the company's employees refer to Gjensidige in the media, the Group expects a courteous and loyal attitude.

 

6.10 Insider information and Security trading
Insider information is precise information that an investor will probably use as the basis for investment decisions, and that could influence the price of the Gjensidige share upwards or downwards. No employee may use or contribute to others using insider information about the Group or other companies as a basis for trading in securities. This applies to both private trading and trading on behalf of the Group.

Private investments in securities must take place within a responsible financial framework. Gjensidige's interests shall always take precedence over employees' personal interests, and such interests must be kept separate.

Employees must not, on their own behalf or on behalf of closely related parties, use insider information about possible trading in securities by Gjensidige to trade or give advice about buying or selling securities. Such information is confidential and will be a trade secret, and could also constitute insider information that triggers a statutory prohibition on trading and criminal liability.

Any doubts concerning insider information and trading in securities shall be raised with the CFO or Head of Investor Relations in advance of any trading.
Board members are referred to the rules on impartiality and the duty of secrecy, see Sections 9-5 and 9-6 of the Financial Undertakings Act.

 

6.11. Use of the Group's equipment and property
No one may use the company’s data, IT equipment, material or other property to an unreasonable extent for private purposes or for activities that are not relevant to their work for Gjensidige. Equipment must not be used for computer games, gambling, pornography, racism or for other purposes that can be perceived as offensive. More information about this is available on the intranet under the tab ‘Employee/Security’.

 

6.12 Orderly personal finances and financial situation
Gjensidige expects employees to have their personal finances in order. Employees who take up positions that confer powers to commit Gjensidige financially must expect the company to check their creditworthiness.

If an employee is exposed to strong financial pressure, this can be construed as weakening the respect and independence the Group strives for. Employees who realise that they will be unable to meet their financial obligations to the Group, must inform their immediate superior, unless the financial situation is of a temporary nature.

The Group expects employees to ensure that their financial liabilities to Gjensidige are kept in order, and this also applies to customer relationships with the Group.

An employee must not register or change the terms and conditions of their own or closely related parties' insurance contracts or other agreements. This does not prevent employees from using the same service channels as are open to other customers, however.

If an employee’s insurance claim or wish to take out insurance is rejected on grounds of insurance fraud, this may have consequences for his/her employment relationship. The same applies if employees behave dishonestly as customers in any other of the Group’s business areas. As customers of the Group, employees must conduct themselves in the same way as other external customers in their communication with the company. Internal communication channels or undue pressure must not be used.

Approval of payment of an employee's personal expenses must be given by his/her superior in accordance with authorisations.

Fringe benefits enjoyed by Gjensidige's employees must not be exploited for other purposes than those that form the basis for the arrangement.
Participation in illegal gambling activities that entail financial risk is not compatible with Gjensidige's activities.

6.13 Human dignity
Employees who are on service assignments or business travel must not behave in a manner that could violate others' human dignity. For instance, this means that employees must not buy sexual services.

6.14 Self-interest
Employees must not behave in a way that results in unjustified enrichment or advantage for themselves.
Employees who leave the Group cannot take with them or copy the company’s knowledge base, customer lists, internal systems or other organised knowledge. Nor may they take with them rights or intellectual property that have been purchased or developed by employees or others for the Group.

7.Notification

Notification means reporting censurable matters to someone who can do something about them. Examples of censurable matters are violations of laws and internal rules and guidelines.

Reporting such matters is important to Gjensidige and society at large, because it makes it possible to rectify censurable matters and can contribute to developing the Group. Employees who are willing to report censurable matters are therefore an important resource for the Group.

Everyone who becomes aware of matters that they believe to be censurable or circumstances that are in breach of the rules and guidelines that apply to the Group’s activities, is urged to report them. Employees have a duty to report criminal offences, and matters where life or health is at risk.

There are several channels for giving notification. Employees can give written or oral notification to their immediate superior, HR Business partner, SVP HR, employee representatives, safety delegates or the chair of the Working Environment Committee. It is also possible to use Gjensidige's external notification channel. If an employee who plans to report a matter wishes to remain anonymous, he/she must use the internal or external notification channel.

8. Responsibility and follow up

All employees must familiarise themselves with and comply with the ethical rules, and assess their actions in relation to the rules. If in doubt, the employee must contact his/her immediate superior or submit a notification through the ethics mailbox on the intranet.

Managers at all levels have a particular responsibility for ensuring that their own and their subordinates’ conduct is in compliance with the regulations. Line managers are responsible for making the ethical rules known, and for ensuring that employees act in accordance with them.

HR has overall responsibility for administering the ethical rules, including following up the gift register and the ethics mailbox. HR shall assist the management by taking steps to ensure that all employees are informed about what the ethical rules mean in their day-to-day work.

The consequences of transgressions of the Group’s ethical rules are shown in the matrix below.

Degree of seriousness

Negligent

Culpably negligent/repeated offences

Deliberate/ repeated cases of culpable negligence

Infringement of: 

Internal rules and guidelines

  

Oral warning

  

Written warning

 

  

Consideration of voluntary or imposed dismissal

Laws and public regulations

Written warning

 

Consideration of criminal report, voluntary or imposed dismissal

Criminal report, voluntary or imposed dismissal

(N.B. Throughout this document the third person plural (they, them, their) is also used to denote the gender specific third person singular (he, him, his and she, her, hers)).