Nammo AS

Based on public information, there is evidence that the company has published statements from the CEO supporting the ethics and anti-corruption agenda of the company. The CEO discusses in the 2012 and 2013 Annual Reports the company’s corporate social responsibility programme and states in the 2013 Annual Performance that anti-corruption work is a special focus area for the upcoming period. Additionally, on the company’s website the CEO emphasises the company’s zero tolerance for corruption. The company therefore scores 2.

Based on public information, there is no readily available evidence that the company’s CEO or Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. This engagement could include speaking at training events or chairing a review of the company’s anti-corruption programmes.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct. The Ethical Code of Conduct states that the company and its employees will always be honest, truthful and reliable, and that staff must be open and transparent with regard to ethical issues. The company also explains what is meant by these values.

Based on public information, there is evidence that the company is a member of the UN Global Compact.

Based on public information, there is evidence that the company has appointed the Ethical Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee ensures a common understanding of and compliance with the company’s Ethical Code of Conduct.

Based on public information, there is evidence that the company has appointed the Senior Vice President Human Resources, Bertil Pålsrud, with responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company reviews its ethical guidelines annually. However, evidence suggests this is a regular review of a particular section of the company’s ethics programme. The company therefore scores 1. To score higher the company would need to conduct a major review of its entire ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has a formal, written plan on which the review of the ethics and anti-corruption agenda by the Board or senior management is based. There is some evidence of improvement plans being implemented over the last year, as the Ethical Code of Conduct has been revised and ethical dilemma training commenced.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices, in response to actual or alleged instances of corruption. The company states that in 2012 there were no incidents of corruption, with similar statistics provided for 2013.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company has a yearly process for risk management and individual business units are responsible for developing action plans for compliance. However, this is assessed to be insufficient evidence of an enterprise-wide anti-corruption risk assessment with clear mitigation plans.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is evidence that the company conducts due diligence before entering into a contractual agreement with any third party. However, there is no evidence to suggest that the company refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is some evidence that the company has contractual rights for the behaviour of agents with respect to countering corruption. The Ethical Code of Conduct states that third parties are expected to adhere to the company’s ethical standards. However, it is not clear that the company has formal mechanisms for monitoring and auditing such individuals. The company therefore scores 1.

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 Supplier Conduct Principles clearly state that suppliers must comply with applicable laws and regulations concerning prohibited business practices, which includes the prohibition of corruption. The company has the right to terminate a contract with a supplier if they fail to comply with the standards set by the company.

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 risks when selecting 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. It prohibits all forms of bribery, including facilitation payments.

Based on public information, there is evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.

Based on public information, there is limited evidence that the company’s anti-corruption policy is easily accessible to Board members, employees and third parties. The Supplier Conduct Principles and Ethical Code of Conduct are available online, but they are only available in English. The company states that an Anti-corruption Procedure provides further details on how employees should respond to particular situations, but this document is inaccessible. The company therefore scores 1. To score higher the company would need to provide evidence that the Ethical Code of Conduct and Supplier Conduct Principles are available in multiple languages and/or that the Anti-corruption Procedure is accessible.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable. The Ethical Code of Conduct is written in accessible, comprehensible language. TI is unable to evaluate the Anti-corruption Procedure as it is inaccessible.

Based on public information, there is evidence that the company’s anti-corruption policy explicitly 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, as the policy is contained within the Ethical Code of Conduct. The policy contains a definition and several clear examples are provided for guidance.

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. The company states that promotional items of minimal value may be accepted or given as gifts, but gifts of higher value must be declared and possibly relinquished to the company. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits on the acceptable value of a gift and/or value thresholds necessary for senior management authorisation.

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. The company states that hospitality must have a clear business reason and be kept within reasonable limits. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits on the acceptable value of hospitality and/or value thresholds necessary for senior management authorisation.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments, except in situations where an individual believes that his/her own or others’ lives may be in danger. The company provides supplementary information on how this policy is to be implemented in practice, with individuals instructed to report the payment to the appropriate member of management and ensure that the transaction is recorded correctly.

Based on public information, there is evidence that the company prohibits contributions to political parties and politicians.

Based on public information, there is no readily available evidence that the company has a clear lobbying policy, or discloses the issues on which it lobbies. TI notes that the company states that it participates in public debate in an open and transparent way.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees, understand and implement the firm’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has a training programme on its ethics and compliance systems, which includes an anti-corruption policy. Since March 2013 this training has been based on ethical dilemmas. The company therefore scores 1. To score higher the company would need to provide evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme.

Based on public information, there is evidence that the company’s training programme on its ethics and compliance systems, which includes an anti-corruption policy, involves all business units. The company aims to train all employees using its ethical dilemmas training.

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 briefs personnel involved in areas such as marketing and purchasing, on applicable anti-corruption provisions and the Ethical Code of Conduct. However, it is unclear if training is provided to all employees in sensitive positions. The company therefore scores 1.

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. The Ethical Code of Conduct states that employees should report suspected conflicts of interest to the management team. To score on this question the company would need to provide evidence that employees are instructed to declare conflicts of interest to managers in writing or to an independent department.

Based on public information, there is evidence that the company has a commitment to apply disciplinary procedures to employees and Board members found to have breached the Ethical Code of Conduct. However, it is not clear that disciplinary procedures would be taken in each case. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit commitment to apply disciplinary procedures to those found to have engaged in corrupt activities, using language such as ‘will’.

Based on public information, there is evidence that the company has multiple, accessible well-publicised channels, that guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. Whistleblowing channels include employees’ superiors, the Ethical Committee and the SVP Human Resources. The Ethical Committee facilitates anonymous reporting, but it is unclear to what extent. The company therefore scores 1. To score higher the company would need to provide evidence of independent sources to report to.

Based on public information, there is evidence that all employees in all geographies, are able to report to the Ethical Committee or the Senior Vice President Human Resources by email.

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.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. These resources include the Senior Vice President Human Resources and the Ethical Committee.

Based on public information, there is evidence that the company has a commitment to non-retaliation 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.