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For Telenor, anti-corruption is not only a legal obligation and an ethical standpoint. Corruption is a threat to business and society in all countries. It undermines legitimate business activities and distorts competition. It ruins reputation and exposes individuals to risks.
At Telenor we are all responsible for understanding the important legal and ethical issues that affect our business and for acting with integrity at all times. Integrity means complying with both the spirit and the letter of the laws and regulations that govern our industry. Telenor’s zero tolerance on corruption and ethical standards are set out in our Code of Conduct, Group Policy Anti-Corruption and other governing documents, to which all employees and business partners must adhere. We call this “The Telenor Way Framework”.
Top-level commitment is vital for establishing a transparent and enterprise-wide culture which works against corruption. Telenor’s management is committed to sending clear, unambiguous and regular messages to all staff and business partners that corruption and bribery is unacceptable. The Ethics and Sustainability Committee of Telenor ASA’s Board of Directors supports the Board in fulfilling its responsibilities with respect to ethics and anti-corruption.
Our Anti-Corruption Program
Telenor’s Anti-Corruption Program is rooted in our Code of Conduct and Group Policy Anti-Corruption. Its design, implementation and enforcement are risk-based and tailored to prevent corruption throughout Telenor’s business activities. It applies to all persons working for or on behalf of Telenor.
The Anti-Corruption Program includes several elements working together. Ethics and anti-corruption considerations are integrated into Telenor’s business activities and decisions across all functions and levels. Telenor has an organization with clearly defined roles and responsibility for implementation of the Anti-Corruption Programme, both at Group and Business Unit level. The Group Policy Anti-Corruption and the effectiveness of the Anti-Corruption Program are assessed and revised on a regular basis.
The Anti-Corruption Program works together with Telenor’s Ethics & Compliance function. All employees may report any concerns to the Local Ethics & Compliance Manager, or Telenor Group compliance functions at Telenor’s “Hotline to Compliance”. All reporting shall be treated confidentially.
Our Anti-Corruption Handbook
Telenor’s Anti-Corruption Handbook is a practical guide to help all Telenor employees to understand and live Telenor’s values and formal policy relating to anti-corruption.
Corruption takes many forms. Our Anti-Corruption Handbook shall assist our employees to navigate challenges related to gifts, events and representations, facilitation payments, public authorities and middlemen and business partners. The guidelines shall help each employee to make the right decisions. The Handbook cannot provide answers to every situation and dilemma that our employees may face. Our employees are strongly encouraged to seek advice when in doubt.
Our Anti-Corruption Awareness & Training Program
Telenor is firmly committed to build and promote ethical values and behaviour within identified challenge areas. These values need to be communicated to and anchored with key individuals and we must find ways to make them part of our everyday culture.
A key element in the Anti-Corruption Program is capacity-building and regular training of all employees. Our anti-corruption training ranges from e-learning programs, dilemma-training modules and other “Telenor Way” awareness activities. Telenor strives to consistently improve and tailor the training programme in order to ensure that our commitment against corruption is known and lived by throughout the company.
Anti-corruption in supply chain and third party relations
Integrity is a vital part of Telenor’s business. We recognize that our business partners, whether new investments, partners, agents, consultants, contractors or suppliers, will be associated with Telenor. It is crucial to ensure that Telenor’s business partners are in compliance with our ethical standards. Telenor has implemented mandatory requirements for screening and conducting integrity due diligence assessments of our business partners.
All suppliers and parties that have a direct contractual relationship with Telenor and offer products or services to Telenor must adhere to our Supplier Conduct Principles. These principles set out the minimum standards that we expect to see achieved over time, including on ethics and anti-corruption. Anti-corruption is part of the regular supplier engagement and forms part of supplier training & awareness activities in various forms in the local markets.
Telenor monitor compliance through a systematic, risk-based approach, which may include both announced and unannounced site visits. We encourage our suppliers to implement an efficient anti-corruption program to minimize corruption risk.
Telenor is active in international fora to discuss and find solutions to common challenges facing the industry. One of the key achievements last year was a guide to help preventing corruption in the supply chain, developed by UN Global Compact and Telenor with inputs from UNGC Advisory Group members. The guide is used in supplier training and outlines preventive measures companies are encouraged to have in place to minimize corruption risk.
Telenor Group is a multinational company with operations in very different markets. Some of these markets rank high on indexes such as Transparency International’s Corruption Perceptions Index. Telenor has developed a robust ethical platform with zero tolerance on corruption. Telenor’s governing documents set one single standard which shall govern all business activities, regardless of where such activities take place. We acknowledge however that our ethical standard cannot be achieved without addressing local differences. All Business Units have a responsibility to assess local risks and challenges. Local policies and manuals shall ensure that such risks are managed in accordance with Telenor’s zero tolerance-policy.
Telenor Group Anti-corruption programme