Kongsberg Gruppen

Based on public information, there is evidence that the company publishes a statement from the President and Chief Executive Officer Walter Qvam, supporting its strong stance against corruption, in the 2013 Sustainability Report.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, evidence shows that this engagement has been delegated. In November 2014 the Corporate Compliance Officer, Lene Svenne, took part in a forum on Scandinavian anti-corruption efforts. The company therefore scores 1. To score higher the company would need to provide evidence that the Chief Executive Officer or the Chairman have demonstrated active external engagement in anti-corruption matters, on more than one occasion over the last two years.

Based on public information, there is some evidence that the company’s CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. The CEO is the chair of the Ethics Council, which is responsible for maintaining the Code of Ethics and providing recommendations on dealing with ethical dilemmas. The company therefore scores 1. To score higher the company would need to provide at least two more examples of this internal engagement from the last two years.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct. One of the company’s values is ‘reliable’, which is explained in regard to integrity, transparency and accountability. To score higher the company would need to provide evidence either that it explains these values in greater detail, clearly showing how they are translated into company policies, or abides by at least one more of the values sought by this question.

Based on public information, there is evidence that the company is a participant of the UN Global Compact and is a member of Transparency International Norway.

Based on public information, there is some evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Audit Committee has to evaluate internal control, compliance and risk management. The company also has an Ethics Committee, which is responsible for promoting high ethical standards and good behaviour. However, limited evidence is provided publicly to fully understand the responsibility of this Committee. The company therefore scores 1. To score higher the company would need to provide further evidence of the Audit Committee’s responsibility, such as through clear terms of reference.

Based on public information, there is evidence that the company has appointed the Corporate Compliance Officer with responsibility for implementing the company’s ethics and anti-corruption agenda. The Corporate Compliance Officer is identified as Lene Svenne and her responsibilities include acting as the secretary of the Ethics Council, acting as the chair of the Business Conduct Review Board and approving ethics training materials. The company therefore scores 2.

Based on public information, there is evidence that the company conducts regular Board level monitoring and reviews of its ethics and anti-corruption agenda. Evidence shows that the Code of Ethics is reviewed and updated by the Board of Directors biennially. There is also evidence that the company’s entire ethics and anti-corruption agenda is reviewed against annual plans.

Based on public information, there is no readily available evidence of a formal, clear, written plan in place, on which the review of the ethics and anti-corruption agenda by the Board is based. However, there is extensive evidence of improvement plans being implemented when issues are identified. For example, introducing due diligence requirements for joint venture and teaming agreements. The company therefore scores 1. To score higher the company would need to provide evidence of a formal, clear, written plan, on which the review of the ethics and anti-corruption agenda by the Board is based.

Based on public information, there is some evidence that the company has a formal process to review and where appropriate updates its policies and practices, in response to actual or alleged instances of corruption. The company states that it responds to problems with corrective actions. For example, in response to a corruption case in Romania the company says it will re-evaluate its anti-corruption programme and implement the necessary improvements. The company therefore scores 1. To score higher the company would need to provide evidence of the formal review process, for example highlighting which company committees or departments are involved.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The Board of Directors reviews quarterly risk reports and the Audit Committee evaluates internal control, compliance and risk management. The company therefore scores 1. To score higher the company would need to provide evidence of how mitigation plans should be applied and who is responsible for their implementation.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. The company conducts due diligence on third parties, suppliers, joint ventures and teaming arrangements, public projects and tenders, and mergers and acquisitions.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its agents. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes the due diligence at least every three years and/or when there is a significant change in the business relationship.

Based on public information, there is evidence that the company has contractual rights and processes for the behaviour, monitoring and audit of agents with respect to countering corruption. The Code of Ethics is included in the contract between the company and agents, and the company has the right to carry out audits. The company therefore scores 1. To score higher the company would need to provide evidence that it has contractual rights to apply sanctions in the event of a breach of its contract.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. The Suppliers Conduct Principles include a prohibition of all forms of corruption. If suppliers fail to comply with these principles the company’s general policy is to encourage improvement, rather than to terminate the contract. However, this suggests that the company has contractual rights to apply sanctions in the event of a breach of its contract.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its offset partners and offset brokers.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. This includes the giving and receiving of bribes, facilitation payments and corrupt gifts and hospitality.

Based on public information, there is evidence that that the company has a zero tolerance policy towards corruption.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. A number of these policies are available on the company’s website. In particular the Code of Ethics is available to download in English, Chinese and Portuguese, and is distributed to all employees and relevant third parties.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. The policies are written in comprehensible language without dense, legal terms.

Based on public information, there is evidence that the Code of Ethics applies to all employees and Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which applies to both employees and Board members. The policy includes a definition of a conflict of interest. The company therefore scores 1. To score higher the company would need to provide evidence that it provides employees with several examples of potential conflicts of interest.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. Gifts should not be contrary to any laws or exchanged with the aim of receiving an improper advantage. Instead gifts should be of a reasonable value, be provided transparently and given in good faith. The company states that gifts that are of a significant value, set at US$100, must be reported to a superior and are generaly turned over to the company.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. Hospitality should not be contrary to any laws or exchanged with the aim of receiving an improper advantage. Instead hospitality should be of a reasonable value, be provided transparently and given in good faith. Employees are allowed to participate in and host cultural and sports events, meetings and dinners, but employees invited on a trip or to an event must discuss the invitation with an immediate superior. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of hospitality and/or has the requirement for senior management authorisation if a value threshold is exceeded.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. This policy provides guidance on how it is to be implemented in practice, for example in response to physical threats.

Based on public information, there is no readily available evidence that that the company prohibits or regulates political contributions in order to prevent undue influence or other corrupt intent. Despite the company stating it supports no political parties or their candidates, it further states that all its political contributions must be reported to senior management and comply with public disclosure requirements. To score on this question the company would need to provide evidence that it clearly regulates political contributions, for example through authorisation mechanisms, and that it publically declares recipients.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which it lobbies. However, evidence shows that the Code of Ethics applies to lobbyists who act on behalf of the company.

Based on public information, there is evidence that the the company regulates charitable contributions, in order to prevent undue influence or other corrupt intent. Charitable contributions require prior approval and written justification from the Executive Vice President of the applicable business division. The company therefore scores 1. To score higher the company would need to provide evidence that recipients are publically declared.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees, understand and implement the company’s ethics and anti-corruption agenda. The company’s Anti-Corruption Guide contains several definitions and questions and answers. The company’s website contains links to ethics and compliance e-learning modules, and references an external UN anti-corruption e-learning course.

Based on public information, there is evidence that the company has an explicit anti-corruption training module as part of its ethics and compliance training programme.

Based on public information, there is evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.

Based on public information, there is evidence that the company provides a varied ethics and anti-corruption training programme. Specific training is provided for exposed personnel, managers and market representatives, and training is noted to be risk-based.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. Employees are instructed to report conflicts of interest to an immediate supervisor or management. To score on this question the company would need to provide evidence that employees are instructed to declare conflicts of interest either to a manager in writing or to an independent department.

Based on public information, there is evidence that the company has a policy to apply disciplinary procedures to employees, Directors and Board members who have violated the Code of Ethics, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that it has an explicit commitment to apply disciplinary procedures to individuals who have violated the Code of Ethics, using language such as ‘will’, rather than ‘may’.

Based on public information, there is evidence that the company has multiple, well-publicised, accessible channels, for employees to report concerns or instances of suspected corrupt activity. These channels include the HR Department, the Ethics Council or the Board of Directors. The company states that if employees wish to remain anonymous they should report concerns verbally or write a letter to the Ethics Council. Employees in the USA and Canada are able to report using an externally operated whistleblowing system. The company therefore scores 1. To score higher the company would need to provide evidence that all employees have access to an externally operated or independent channel.

Based on public information, there is evidence that across geographies all employees have access to more than one reporting channel. These channels include local or corporate HR, the Ethics Council or the Board of Directors. The externally operated whistleblower system is only available to employees in the USA and Canada.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively. The company provides whistleblowers with feedback, but there is no evidence that this involves a discussion over the adequacy of the whistleblowing procedure.

Based on public information, there is evidence that employees have well-publicised resources available to all employees, where help and advice can be sought on corruption-related issues. These resources include compliance officers, the Corporate Compliance Officer and the Corporate Legal Department.

Based on public information, there is evidence that the company has a non-retaliation policy for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.