Ethical rules for Gjensidige

Laid down by the Board 12 June 2014.

Gjensidige is defined in this context as the Gjensidige group.

The main principles are described in greater detail below.


1. Gjensidige's value base and ethical rules

A good business culture and a positive reputation are a basic premise for Gjensidige's business. All activity shall reflect this.

Decisions and actions shall be controlled by norms, values and ethical rules that are in accordance with the general interpretation of the law and Gjensidige’s position as a significant contributor to society and a participant in the Nordic general insurance market.

Gjensidige’s business is dependent on trust from the Group's various interested parties. Trust must be developed with time and must be maintained. All of the activities at Gjensidige shall bear scrutiny. Therefore, it is expected of employees that their conduct be in keeping with the Group's ethical rules at all times.

Each individual is responsible for staying informed about the guidelines and rules of law that apply within his/her area of work. The line manager is responsible for familiarising employees with the ethical rules and seeing that they are complied with. Relevant ethical issues should therefore be put on the agenda at regular intervals; e.g. at department meetings.

The ethical rules also provide guidance about how an employee should act in order to comply with the Company’s values. If he/she is in doubt, the person in question should contact his/her immediate supervisor.

2. Who is covered by the rules?

The ethical rules indicate the expectations and requirements that Gjensidige has for its employees’ behaviour and conduct. Employees, the Board and other officers, temporary help and hired consultants are covered by the ethical rules in the activities they perform for Gjensidige.

In some situations, the ethical rules also apply to the employee’s nearest relatives, who have later been called “closely related parties”. Closely related parties are defined as spouse, cohabitant, partner and children under age 18, otherwise close family as well as companies, associations, teams, etc. in which the employee or some of his/her nearest relatives have significant influence. Other personal relationships may also be of such a nature that they will be treated equivalently with closely related parties (e.g. neighbours, close friends, etc.).

3. Behave with respect and consideration

There is a common responsibility to help develop a team spirit and a good working environment. Each individual is expected to behave with respect, consideration and general politeness to colleagues as well as competitors, customers and others. By being inclusive and involved, we make each other better. Discrimination or harassment shall not occur.

4. Avoid conflicts of interest and corruption*

The relationship to managers and colleagues
Gjensidige wants to create a positive, challenging working environment with opportunities for self-development. Trust, respect, cooperation and openness to managers and colleagues are the basis for achieving this goal. All employees are responsible for helping to create a good working environment in Gjensidige.

The relationship to customers and suppliers
An employee must not let decisions or actions be affected by undue pressure or offers of financial gain from self-interested parties. If such situations arise, the employee shall report the matter without delay to his/her immediate supervisor (there may be self-interested parties both inside and outside the Group).

Employees may not receive benefits or goods from others who may have a relationship to the employee’s work in Gjensidige because this may entail the risk of a conflict of interest. If there is any doubt, the immediate supervisor shall be informed in writing of any such relations.

Employees or closely related parties shall not receive discounts on personal purchases of goods or services from Gjensidige's connections with whom the employees have contact through their work unless it involves arrangements that are open to all of Gjensidige's employees.

Payments and/or fees from Gjensidige to external service providers shall be reasonable relative to the normal market rates and the correct tax rates shall always be paid.

If an employee may somehow be regarded as disqualified through conflicts of interest from dealing with external service providers, all agreements must be pre-approved by the immediate supervisor.

*)A separate leaflet: Do you know enough about corruption "is distributed to employees

The relationship to government authorities
All employees shall familiarise themselves with the rules, laws and regulations that apply to their own area of responsibility and ensure that these are complied with. The employees must under no circumstances recommend or take the initiative to a violation or circumvention of current laws and rules, e.g. with regard to taxation.

Family relations
As a general rule, siblings, parents and/or children or spouses and/or cohabitants shall not work under the same manager (line manager) or in the same department. Employees who are related to each other shall not prevent, judge, approve, audit, check or in any other way affect the work of a relative.

Representation, travel, etc.
Gjensidige expects that employees who represent or can be identified with Gjensidige by virtue of their position do so in a way that invites trust of both Gjensidige and the employee.

Gjensidige opposes the purchase of sexual services. Thus, employees on assignments or travel for Gjensidige must refrain from purchasing sexual services. The purchase of sexual services may contribute to illegal trafficking in human beings and violation of human rights.

Customer-oriented arrangements shall be distinguished by sobriety and have a commercial content for both the customers and Gjensidige. Relationship activities shall be in accordance with prepared guidelines.

An employee may not take part in travel or events offered by Gjensidige's connections unless this has been cleared with his/her immediate supervisor. As a general rule, travel and stays in connection with the performance of work for Gjensidige shall be covered by Gjensidige. This also applies to travel and stays in connection with seminars and other professional arrangements.

Sponsoring activities must be in accordance with the approved sponsoring strategy at any given time.

The company has a ban on political donations and all payments that could be aprehended as support for organizations shall be under full transparency.

5. Impartiality

Decisions and administrative procedures
An employee must not take part in or try to influence a decision when there are circumstances that are likely to diminish confidence in his/her impartiality. Employees must therefore not take part in consideration of or decisions about any matters in cases where the employees themselves or closely related parties have any financial or other personal interests.

The employee shall inform his/her immediate supervisor immediately if he/she becomes aware of any conflict that may arise with regard to his/her impartiality. The supervisor shall evaluate whether other employees or external parties may harbour doubts about the employee’s impartiality or ethical integrity. If it is maintained that an employee should be disqualified due to conflict of interest, he/she shall not take part in the ongoing handling of the matter.

For members of the Board of Directors, supervisory board or control committee, cf. the special provisions regarding disqualification due to conflict of interest in Section 3-12 of the Act relating to financing activities and financial institutions.

An employee shall not use his/her position to affect hiring matters in such a way that favouritism comes into play on the basis of criteria other than those that are directly relevant to the position in question.

After termination of employment
An employee who resigns from the Group may not take along or copy the Company’s knowledge base, routines, internal systems or other organised knowledge that is purchased or developed by and for employees in the Group.

Executive management in Gjensidige who are in a position to influence the accounts may not take part in the conduct of an external auditor’s audit in the Group until at least one year after their employment in the Group has terminated.

6. Financial matters

If employees come under strong financial pressure, it may be perceived as a diminishing of the respect and independence that Gjensidige aims for. An employee who understands that he/she will not manage to meet his/her financial obligations must therefore immediately inform his/her immediate supervisor or a specially appointed staff advisor in writing about the situation. The advisor shall pass on this information to the employee’s immediate supervisor unless the financial situation is of only a temporary nature.

Tidiness in personal finances
Gjensidige is dependent on the trustworthiness of its employees and therefore requires that its employees’ private finances are in order. It is expected that the employees will ensure at any given time that their financial obligations to Gjensidige are in order – including customer relations with the Company.

Employees who enter positions with authorisations to bind Gjensidige financially must accept that Gjensidige will conduct a credit check.

An employee shall not undertake registrations and changes of terms and conditions for their own or closely related parties’ insurance contracts or other contracts. However, this does not prevent employees from using the same service channels as are open to other customers. Payment of an employee`s own expenses must be endorsed by the employee`s superior in accordance with his/her authorisation.

The fringe benefits that the employees in Gjensidige enjoy must not be used for purposes beyond those specified in the arrangement.

Participation in illegal gambling activities that entail financial risk is not compatible with Gjensidige’s activities.

Inside information
As an employee of Gjensidige Forsikring ASA and other companies in the Gjensidige Group in Norway and in other countries, you may gain access to inside information about Gjensidige. It is forbidden to trade in or encourage trading in financial instruments that are issued by or related to Gjensidige Forsikring ASA if you possess inside information about Gjensidige Forsikring ASA. If you have inside information, you are subject to a duty of confidentiality and have a duty of disclosure to the CFO/Head of Investor Relations.

Securities trading
Investment in securities must occur within responsible financial constraints. Gjensidige’s interests shall always have priority over the employees’ personal interests, and those interests should be kept separate.

Employees must not use information from discussions or memos concerning Gjensidige's possible own purchase and sale of securities, on their own behalf or on behalf of closely related parties, in order to buy, sell or give advice about buying or selling such securities. Such information is confidential and can also be insider information that results in a statutory trading ban subject to penalty. If you are in doubt, contact the Group secretariat.

Employees must exercise great caution with respect to accepting gifts or other benefits from customers or suppliers. An employee or a related party of an employee may not accept gifts worth more than NOK 500. If there is a risk that employees` impartiality or independence can be placed 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 of any kind in connection with negotiations or as a return favour for entering into business agreements on behalf of Gjensidige.
Corresponding limitations apply when gifts are given to business connections. Neither Gjensidige`s motives nor the integrity of the recipient must be placed in doubt.

7. Communication shall be open, honest and clear

All communication in all channels to all target groups shall be open, honest and clear.

In connection with sales and counselling, the individual employee has a special responsibility to ensure that the customer is offered this information in accordance with good business and/or counselling practices. The employee shall also try to ensure that the customer is familiar with the consequences of the choices that he/she makes.

All statements to the media about Gjensidige or a company’s situation shall be made by employees who are specially designated to make statements on the Group’s behalf. Other employees shall refer the media to the Group's and or the Company’s Communications/ Information Department.

8. Use of Gjensidige's equipment and assets

Gjensidige's computer equipment and systems shall not be utilised for purposes other than those for which they are meant to be used.

As a general rule, employees shall only use Gjensidige's computer equipment or other assets for work-related purposes. Private use shall never occur at the expense of performance of the work. No one shall make unreasonable use of the telephone, copying machine, fax, e-mail or Internet for private purposes. Uses of such devices that are related to computer games, gambling, pornography, racism or other purposes that can be perceived as offensive shall not occur. Cf. the Security Manual.

9. Information, professional secrecy and whistle blowing

Gathering of information
An employee shall not actively seek information about other employees or customers through the computer systems or in any other way unless it is necessary for his/her work in Gjensidige.

Duty of confidentiality
Employees have a duty of confidentiality concerning all information about Gjensidige or Gjensidige's business connections that comes to their knowledge as a result of the performance of their duties. The duty of confidentiality applies in relation to colleagues, advisers, family and all other persons unless the CFO or person authorised by the CFO has consented to the exchange of such information.
The duty of professional secrecy does not apply when an employee is obligated to furnish information pursuant to the law. In cases of doubt, the person who requests information from Gjensidige must document him-/herself that the information can be furnished without any breach of confidentiality.

Duty of disclosure and duty to give notice
The duty of professional secrecy does not prevent an employee from informing his/her supervisor about matters in Gjensidige that are assumed to conflict with current laws, rules or regulations laid down by the authorities or in the event of a material breach of internal provisions. If it is suspected that a matter has occurred that must be regarded as an irregularity or a fraudulent act, the employee is also obligated to report this matter directly to Compliance.

The employee should be able to notify the Group about such matters without it having any consequences for his/her employment. If he/she does not want to inform his/her immediate supervisor about the matter, the employee can consult some other supervisor, the safety representative and/or chief safety delegate, Human Resources (HR) or Compliance. Another possibility is to send an e-mail to ”Etikkpostkassen” (The Ethics Mail Box), Inquiries will be handled confidentially if the person in question so desires.

Employees who notify the Group about blameworthy matters in an acceptable way in accordance with this section shall not be subject to reprisals, etc.

Pursuant to Section 2-4 in the Working Environment Act, employees have the right to notify the Group about blameworthy matters at the workplace. The whistleblower will be given legal protection against reprisals pursuant to Section 2-5 of the Working Environment Act; cf. Gjensidige’s information bulletin, cf. appendix 1 to these ethical rules.

10. Participation in other businesses

Business activity
An employee shall not conduct, be mentioned in connection with or participate in economic activities or receive remuneration from outside of Gjensidige unless his/her immediate supervisor has been informed about this.

After an assessment of the individual case, Gjensidige may issue a prohibition against the employee conducting private business activities if such activities intervene with working hours, make significant demands on the employee’s working capacity or are not compatible with the person in question’s position in Gjensidige or Gjensidige’s other business.

An employee must notify his/her immediate supervisor if the employee or a closely related party has a material stake in businesses that have customer or supplier relations with Gjensidige. If the ownership can raise doubt about the employee’s loyalty or independence, Gjensidige may set a deadline for winding up the ownership or customer relationship.

An employee must not conduct business that competes with Gjensidige.

Unless they have obtained special permission from their immediate supervisor, employees in management positions may not participate as responsible members or be board members in companies that conduct business activities or credit activities.

Social commitment
Employees may assume posts outside Gjensidige. If an employee is in doubt about whether this involvement will be detrimental to his/her work in Gjensidige or in conflict with Gjensidige's values, this should be discussed with the immediate supervisor. In cases where Gjensidige is mentioned, a correct and loyal attitude is expected in dealings with external parties.

11. Marketing

An employee shall not plan for any form of sales or marketing that may be perceived as offensive or in conflict with regular social norms.

In all advertising, information, product pricing and terms and conditions, the employees shall practice an ethical social responsibility through awareness of the environment.

12. The relationship to other ethical regulations

As a supplement to these rules, special rules have been laid down for special areas of the business, including computer security, use of the Internet, banking, investment management and the sale of financial instruments. In addition, there are professional ethical rules for some professions that the employees in question must also comply with.

13. Consequences in the event of a violation

Gjensidige requires that all employees familiarise themselves with and comply with these ethical rules. Gjensidige will not tolerate violations. In accordance with relevant statutory provisions, a violation may result in internal disciplinary measures, termination of employment, dismissal and/or legal proceedings.

If there is suspicion of a criminal offence or a serious breach of the Ethical Rules, Compliance shall be notified in accordance with “Rules of procedure for handling fraudulent acts or irregularities in Gjensidige”.

If an unfortunate practice or an irregularity should occur, Gjensidige is obligated to make the necessary corrections and initiate preventive measures to avoid any repetition.