Ethical rules for Gjensidige

Laid down by the Board 19 September 2013.

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 protect life, health and assets performing this in a way that takes account of the interests of all of the Company's stakeholders.

A sound business culture and a positive reputation are fundamental conditions for Gjensidige's activities. The Group's activities require the trust of customers, authorities, shareholders and society at large. Gjensidige's ability to inspire trust is dependent on professionalism, aptitude and high ethical standards in everything we do both as a part of business activities and in the treatment of individuals. All employees shall act with due care, honesty and objectivity, and shall refrain from actions that can weaken trust in the Group. Managers have a particular responsibility and shall act as good examples. All activities in Gjensidige shall be open to scrutiny. For this reason all employees are at all times expected to act in accordance with the Group's ethical guidelines.

The ethical guidelines indicate how an employee shall act in order to comply with the Company's value norms. If an employee is unclear as to how to act in a given situation they shall get in contact with their immediate superior.

2. Target group

The ethical guidelines apply to all employees of the Group, all officeholders, and all hired consultants, when acting on behalf of the Group - see further point 6.8 in the impartiality rules.

The ethical guidelines are not legally binding on customers or other third parties, such as close family members, but employees shall in their compliance with these ethical rules take account of their relationship to these parties.

3.Other rules

The ethical guidelines constitute base requirements for ethical behaviour, but cannot cover every type of sound behaviour. The Group has prepared additional guidelines and regulations which expand on the ethical guidelines. It is therefore essential to apply judgment in considering what an ethically correct treatment in a given situation is.

Furthermore it is expected that employees shall loyally submit to complying with laws, external regulations, circulars, relevant ethical guidelines for the industry and internal regulations which are applicable to the Group's activities. Managers shall ensure that each employee is given the opportunity to study the regulations applicable to the individual's tasks, but the individual employee has a clear responsibility to comply with those regulations.

4. Openess

A key characteristic of Gjensidige's corporate culture shall be openness. It is a basis for motivation, trust and security. It is our goal that all employees shall feel secure to raise both major and minor matters with their manager or others in the Group.

Ethical guidelines cannot determine what is right and wrong in all situations. It is therefore important that one is open about one's actions and raise the matter with others in the case of uncertainty. If there is doubt remaining the problem should be addressed to one's manager or the HR department. It is also possible to use the ethics email address etikk@gjensidige.no for questions related to ethical dilemmas. Any email to this email address will be treated in confidence.

5. Sound business practice

5.1. Human rights
The Group respects fundamental human rights as these are expressed in, amongst other sources, the convention on human rights of the United Nations and the International Labour Organisation (ILO). The Group's financial investments shall subscribe to established principles for ethical investment with respect to human rights.

5.2. Environment and procurement
The Group will strive to reduce the environmental impact of its business activities and will facilitate the employees in reducing their environmental impact on society.

The Group is a major purchaser of goods and services and shall be actively engaged in ensuring that manufacturers and suppliers perform their business activities in line with internationally accepted principles and guidelines related to human and employee rights, environmental issues and anti-corruption. Products delivered to Gjensidige shall comply with our environmental standards.

5.3. Fair competition and sales
The Group's activities in the marketplace shall always be performed in accordance with relevant competition and marketing legislation. Extra attention should be paid in connection with work carried out on behalf of industry organisations and where competitors are involved. Such activities shall always be carried out with the mandates and/or guidelines established.

The Group shall not use methods of selling or marketing which can be perceived as offensive or are in conflict with social norms. Advice will always be driven by customers' needs, financial situation and risk appetite. The Group shall give advice which is in the customers' interest. We shall know the customer best and care the most.

5.4. Tax and public regulations
Gjensidige shall comply with tax legislation in the countries in which it operates. In the case of any actions or transactions which Gjensidige does not believe are sufficiently clarified in the law, the tax office will be provided with full disclosure. Gjensidige shall not through its business activities support or facilitate others in the avoidance of taxes or public fees. .

All employees shall acquaint themselves with the rules, laws and regulations applicable to their own area of responsibility and ensure that these are complied with. Employees may not recommend or take initiative to noncompliance or avoidance of applicable laws and regulations.

5.5 Corruption
Corruption is the misuse of one's position to achieve personal or business benefits either on behalf of one's self or others. The Group shall via its anti-corruption programme work actively to stop corruption arising in the Group's business activities.

No-one shall derive benefit either for themselves or for others from the Group's business connections f that benefit has its background in their position of employment. In like manner no-one shall provide benefits to business connections. Benefits may include gifts, discounts, travel and bonuses for private purchase, financing etc. The exception from this rule applies to benefits the Group has negotiated for all employees either in the whole or part of the country where the company has activity,

An employee shall not allow decisions or actions to be influenced by inappropriate pressure or the offer of financial benefits from parties with self-interest in the result. Employees shall in no way recommend or take initiative to breaking laws or regulations in the areas of corruption and financial crime.

Employees shall be acquainted with the content of the Gjensidige folder "Do you know enough about corruption?" which is available here.

5.6. Money laundering
Money laundering refers to the conversion of the profits from illegal activities into apparently legal income or wealth creation. The Group shall avoid any dealings with funds which might be the result of criminal acts and shall have routines which employees in their front line contact with customers shall comply with in order to reduce the likelihood of money laundering.

6. Personal conduct

6.1. Discrimination and victimisation
Everyone has a common duty to promote and develop a team spirit and a good working environment. The individual is expected to act with respect, sensitivity and good behaviour towards colleagues as well as competitors, customers and others. It is by being inclusive and engaged that we bring out the best in each other. Discrimination or victimisation is forbidden. The person who may feel discriminated against or victimised shall be taken seriously.

6.2 Conduct towards managers and colleagues
Gjensidige wishes to create a positive, developing and engaging working environment. Trust, respect, cooperation and openness towards managers and colleagues are fundamental to achieving this goal. All employees are responsible for contributing to the creation of a positive working environment in Gjensidige.

6.3 Duty of confidentiality
Employees shall treat confidential all matters pertaining to customers, employees and other business or private matters of which they become aware in connection with the performance of their work for the Group. This does not apply however if they are legally bound to furnish the information or if they have a duty or have been asked under these ethical guidelines to make a report, The duty of confidentiality applies not only to outside the Group but also internally between the various companies of the Group. The duty of confidentiality is also applicable in respect of others in the same company who do not have any need to know the information in order to perform their work

The duty of confidentiality applies towards colleagues, consultants, family and all other persons, unless the person whose information shall be kept confidential gives explicit consent to the passing on of this information. The CFO or the person appointed by the CFO for this purpose may, in concrete situations relating to financial information, give consent to the passing on of information.

The duty of confidentiality shall also continue to apply after leaving the position of employment in Gjensidige.

An employee shall not actively seek information regarding other employees or customers via the computer system or other means, unless this information is necessary for the performance of their work in Gjensidige.

6.4 Conduct in respect of business relationships
No-one shall carry out acts which can inhibit impartial performance in respect of the Group's customers, suppliers, shareholders or other of the Group's business connections. Restraint shall be demonstrated in respect of private meetings and in the exchange of benefits with companies and persons with whom one through one's work in the Group has business connections. Furthermore restraint shall be demonstrated in respect of business deals with persons with whom one has a personal relationship.

If an employee has a personal relationship with a business connection, it shall be reported to the employee's immediate superior.

6.5 Entertainment and events
It is expected that employees who because of their position represent or can be identified with the Group behave in a wat which builds up trust in the Group and its employees. Events organised by the Group shall be characterised by moderation and demonstrate a relevant and plausible professional content.

If the arrangement entails travel and accommodation for external parties who are invited this cost shall be borne by those invited (either directly or indirectly through a participation fee).

An employee shall not participate in travel or events offered by Gjensidige's business connections unless this has been cleared with their manager. Travel and accommodation costs in connection with the performance of work for Gjensidige shall, as a general rule, be covered by Gjensidige. Any deviation from this practice must be approved by the individual's manager. This also applies to travel and accommodation costs in connection with seminars and other professional activities, which are paid for either directly or by way of a participation fee.

Sponsorship activities shall be in line with the applicable sponsorship strategy.

Gjensidige prohibits any political donations and any payments which can be considered as support for organisations shall be fully transparent.

6.6 Gifts and benefits
Employees shall exhibit great care when receiving gifts or other benefits from customers, suppliers or other parties with whom Gjensidige has business connections. An employee or their close relatives (defined in point 6.8) shall not receive gifts from a donor with a value exceeding NOK 500 within one calendar year. If there is a danger that the employee's impartiality or independence may be drawn into doubt such gift shall not be accepted. Any returning of gifts shall be performed in a way that is as inoffensive as possible to the donor.

An employee shall not receive any form of gift or benefit in connection with or prior to any negotiations or as a reward for business agreements entered into on behalf of Gjensidige.

When gifts are provided to business connections the same limitations shall apply. Gjensidige's motives or the integrity of the potential recipient shall be above reproach.

Gjensidige desires openness and all gifts received as well as relationship activities shall be registered in the Group's gift register.

6.7 Family connections
Siblings, parents/children or spouses/partners shall as a general rule not work under the same manager (line manager) or in the same department. Such a situation shall be clarified in advance with the immediate superior for the department in question. Employees who are related are prohibited from stopping, evaluating, approving, auditing, controlling or in any other way influencing the work of a relative.

6.8. Impartiality
No-one shall participate in or seek to influence the treatment or decision in a case when there are grounds which may exist that would serve to diminish trust in their independence.

In no situation whatsoever shall anyone treat, decide or have influence over a case in which that individual themselves or any directly or indirectly related person has a financial or other personal interests in that case. By related person is meant spouse partner or child under the age of 18 as well as limited companies, associations, club etc. where the employee or any of their close relatives excercise a material influence. Other personal relationships may also be of such a character that they will be counted as equivalent to a related person (e.g. neighbours, close friends etc.).

If an immediate superior is not impartial in deciding a case the case shall as a general rule not be decided upon by a directly reporting employee.

Employees are required to inform their immediate superior as soon as they become aware of the fact that a conflict of interest may arise. The immediate superior shall evaluate whether other employees or the outside world will raise doubts about the employee's impartiality or ethical standards. If it is believed that there is a situation of conflict of interest that person may not participate in the further deliberation of that case.

An employee shall not use his position to influence employment cases so that a decision is based on other criteria than those which are directly relevant to the position concerned.

6.9 Secondary occupation and participation in other companies and organisations
No employee shall without the permission of the employer work, act in a board position, manage or have financial special interest in business operations within the same type of business as any of the Group companies or have any business relationships with those companies.

The permission of the employer shall be sought in advance if an employee occupying a leading position in the Group wishes to carry out private business activities or take paid employment in their free time. Permission may be granted so long as the secondary occupation/employment is compatible with the full and adequate performance of their work for the Group, including compatible with the individual's position in the Group.

Secondary occupations that are so work intensive that they may impair the employee's work shall be approved by the immediate superior. The immediate superior shall be informed in respect of political positions, which are legally regulated, and care must be taken to ensure that the position does not disadvantage the Group.

An employee must inform their immediate superior if the employee or related person has ownership interests in businesses which have a customer or supplier relationship with Gjensidige. If the ownership position can lead to doubt as to the employee's loyalty or independence then Gjensidige may require the ownership or customer relationship shall cease and give a deadline for such divestment/liquidation.

Employees in key positions shall not without express permission from their immediate superior participate as a responsible partner/shareholder or be a board member in a company which is a commercial undertaking.

Employees may take on a leading position outside of Gjensidige. If an employee is in doubt as to whether the position may be detrimental to Gjensidige or against Gjensidige's values this matter shall be raised with their immediate superior. In cases where Gjensidige is mentioned it is expected that the employee shall demonstrate a correct and loyal attitude.
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6.10 Insider information and share dealing
Insider information refers to specific information which may influence the market value of Gjensidige stock resulting in either an increase or decrease in that value i.e. it is information which a reasonable investor would be likely to use as a basis for an investment decision. No employee shall use or assist others to use insider information about the Group or other companies as a basis for a share deal. This applies both in a private capacity as well as on behalf of the Group.

Private share dealing shall be carried out within an acceptable financial limit. Gjensidige's interests shall always be prioritised before personal interest and these two interests shall be kept separate.

Employees shall not on their own behalf or on behalf of a related person use information from discussions or memos concerning Gjensidige's own share trades to deal in these shares or give advice on the purchase or sale of these shares. Such information is confidential and is to be treated as confidential to the company and can also be insider information which may trigger legal prohibition to trade in the Company's shares on pain of prosecution.

If there is doubt about whether insider information is involved or about share dealing the CFO or Head of Investor Relations should be contacted prior to any deal being made.

For Board members reference is made to the specific rules governing conflict of interest and the duty of confidentiality cf. the Norwegian law of financial institutions paras. 9-5 and 9-6.

6.11. Use of the Group's equipment and assets
No-one shall to an excessive extent make use of the Company's data, IT-equipment, materials or other assets for private purposes or for activities unrelated to their work. It is prohibited to make use of computer games, gambling, pornographic or racist material or material for other purposes which may be considered offensive. Further information regarding this subject matter can be accessed on the intranet under Security.

6.12. Ordered personal finances and financial affairs
Gjensidige expects its employees to have their personal finances in order. It is expected that employees at all times shall ensure that financial commitments to Gjensidige are in order, including customer relationship with the Company.

It may be perceived a betrayal of the respect and professional independence the Group aspires to if the employee is under major financial pressure. An employee who that they are not able to cover their financial commitments as they fall due must inform their immediate supervisor, unless such financial situation is purely temporary in nature.

Employees in positions with power of attorney to financially commit Gjensidige must accept that Gjensidige will carry out a credit check.

An employee shall not key in details or changes the conditions of their own or related person's insurance agreements or other contracts. This does not prohibit the use by the employee of self-service channels which are open for all customers.

If an employee is denied payment because of making a false claim (insurance fraud) this will have consequences for the work contract. A similar impact will also result from an employee's dishonest behaviour as a customer within the other business areas of the Group.

The approval of payments for an employee's own personal expenditure must be approved by the immediate superior or superiors as appropriate according to authorisation limits.

The additional benefits that employees in Gjensidige have must not be used for other purposes than that intended by the facility.

Partaking in illegal gambling with financial risk is not compatible with Gjensidige's activities.

6.13. Human dignity
In connection with business activity or on business trips an employee shall not act in a way which may offend human dignity. This includes amongst other matters the prohibition of the purchase of services of a sexual nature.

6.14. Self-interest
Employees shall not take action with the aim of achieving an unfair financial or other advantage.

An employee who leaves the group shall not take with them or copy the Company's proprietary files, customer lists, routines, internal systems or other organised form of knowledge, right or copyright which has been bought or developed by the employee or others for the Group.

7.Whistleblowing

Whistleblowing concerns the reporting of critical matters to someone who can do something about it. Critical matters include, for example, breaking legal requirements and internal rules and guidelines.

Whistleblowing is important for the Group and society as critical matters can be addressed and that may assist in the further development of the Group. Employees who are willing to blow the whistle are therefore an important resource for the Group.

Any person who becomes aware of matters that in their opinion are critical or matters contrary to laws and guidelines applicable to the Group's activities is encouraged to report this. The employees are legally bound to report criminal activities and matters that may put life and health in danger.

There are many ways that whistleblowing can take place. As a starting point an employee may warn either in writing or orally their immediate superior, an HR partner, the HR director, an employee representative, a health and safety officer or the Head of the Working Environment Committee. In addition a whistleblowing may be made through Gjensidige's external whistleblowing channel. If it is necessary for the whistle-blower to preserve their anonymity then the action must be taken through the external whistleblowing channel.

8. Responsibility and monitoring

All employees shall be aware of and comply with the ethical guidelines and at all times evaluate their actions in the light of these rules. If doubt arises the individual must desist or take the matter up with their immediate superior or via the ethic email address on the intranet.

Managers at all levels have a particular responsibility to ensure that their own and their subordinate's behaviour is in accordance with the regulations. The line manager is responsible for ensuring that the ethical guidelines are known and monitoring that they are complied with.

HR has the overall responsibility for managing the ethical regulations including monitoring the gifts' register and the ethics email post box. HR shall assist management by facilitating the awareness of all employees in respect of what the rules mean in their day-to-day work.

Infringement of the Group's ethical rules will normally have consequences as shown in the sanction 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)).