How we do business
We are reliable citizens
Fully integrating our Code of Ethics and Business Conduct into our business operations at every level of our organisation is extremely important for KONGSBERG. Based on our four values, determined, innovative, collaborative and reliable, we are all committed to conducting our business ethically and in compliance with the applicable laws and regulations in the markets in which we operate.
This is a responsibility at every level of KONGSBERG. Top level management and senior management are completely committed to the lawful and proper conduct of our business. We are to both ensure and conduct business that follows our code of ethics amongst our customers, regulators and authorities, partners and colleagues.
We respect culture, environment and ethnic diversity in our operations, and are particularly aware of our legal, ethical and social responsibilities when entering new geographical areas. This applies to aspects of our own operation, including our supply chain.
Our Code of Ethics and Business Conduct is applicable to all companies within KONGSBERG, including majority owned companies. For minority owned companies, as well as partnerships and constellations not involving ownership, we encourage the same level of responsibility.
Group directors, management, employees, market representatives are entailed by this. When acting on behalf of KONGSBERG you are a representing more than yourself, you are representing an entire company with all our employees and a value chain and ecosystem that stretches beyond. We have to be proactive and aware. We are a company with a strong culture, driven by our four values. We are reliable citizens.
We are committed to conducting our business ethically and in compliance with the applicable laws and regulations in the markets we operate. We respect culture, environment and ethnic diversity in our operations, and are particularly aware of our legal, ethical and social responsibilities when entering new geographical areas. KONGSBERG is subject to Norwegian and international legislation, regulations and conventions.
All of KONGSBERGs processes and procedures are reviewed continuously based on best practice, benchmarking and legislative changes.
We know that any unwanted incidents involving or relating to KONGSBERG can damage our reputation and potentially threaten our ability to continue to do business. KONGSBERG recognizes that our values, principles and internal requirements will sometimes preclude us from pursuing business opportunities.
The Group has a management response plan which ensures that KONGSBERG responds in a timely manner to any incidents, and minimizes adverse consequences. The plan describes KONGSBERG's procedure and the internal responsibility between the Board and management for dealing with possible compliance incidents.
Before entering into an agreement with a Business Partner (customers, suppliers, Market Representatives, joint venture partners, other cooperation partners, receivers of sponsorships and charitable contributions), we shall know that the Business Partner’s ethical standard is satisfactory. We apply a risk-based approach, involving a risk assessment that include a compliance due diligence examination. With respect to lobbying activities our policy is that all lobbying firms working for us as well as any KONGSBERG employees who are authorized to engage in lobbying activities on behalf of the company, must be duly registered as such and are expected to comply with all lobbying regulations under local law, including written disclosure requirements.
We perform such compliance due diligence examinations in accordance with internationally recognized standards. The level of compliance due diligence examination depends on the nature of the potential relationship in question and we conduct screening using well-reputed screening tools. The risk assessment for a specific Business Partner is reviewed and updated on a regular basis. The frequency reflects the compliance risk associated with the specific business relationship.
KONGSBERG requires that our Business Partners act in compliance with requirements set forth in agreements enclosing our Code of Ethics and Business Conduct, our Supplier Conduct Principles or other regulation of similar ethical standard. We also have mechanisms to monitor compliance with these requirements and react to non-compliance, should that be necessary. Termination rights in the event of misconduct is one such mechanism.
The use of Market Representatives can pose a particular risk to our operations or reputation. We have a strict mandatory process governing the selection and business justification for the use of Market Representatives and this category of Business Partners is subject to thorough compliance due diligence examination as well as follow up during operations.
Agreements with Market Representatives are based on a KONGSBERG standard agreement. The agreement contains, inter alia, audit right for KONGSBERG, anti-bribery and anti-corruption clauses, and the right to terminate the relationship in the event of violation of any applicable law and/or regulation. It is our policy to audit all agreements with Market Representatives at least every third year.
When preparing an agreement with a Market Representative, special consideration is given to the compensation model. Any models including success fee or bonus must be justifiable, reasonable and in conformity with applicable law. When considering specific models we focus on, that payments should be made pro rata in accordance with the project’s life cycle.
The CEO of Kongsberg has mandated the Chief Compliance Officer (CCO) with the development, coordination and maintenance of the Code of Ethics and Business Conduct and the Compliance Program, including directives, guidelines and other relevant policies.
The CCO reports functionally to the CEO of KONGSBERG and the Audit Committee and administratively to the CFO and have direct and prompt access to the Kongsberg Group BoD and top management.
The Code of Ethics and Business Conduct will be distributed to all employees and be attached to all future employment and temporary employment/consultancy contracts. The Code of Ethics and Business Conduct will be attached to agreements associated with the signing of agency contracts, distributor contracts and other representation contracts.
The Group's Code of Ethics and Business Conduct is compatible with the UN Global Compact and the OECD's Guidelines for Multinational Enterprises and is subject to evaluation and revision, if so required, at least every other year.