Code of Conduct
Grieg Seafood employees, officers and directors
The Code of Conduct (“Code”) applies to all employees worldwide, as well as all officers and directors of Grieg Seafood companies.
The Grieg Seafood Code of Conduct applies in its entirety to all fully or majority owned Grieg Seafood subsidiaries.
Subsidiaries is defined as greater than 50% ownership.
Minority owned subsidiaries
Minority owned subsidiaries are encouraged to adopt and follow the Grieg Seafood Code of Conduct.
Minority owned is defined as 20-50% ownership.
Third parties such as customers, suppliers, consultants, law firms and contractors are expected to adhere to values and principles that are consistent with Grieg Seafood`s Code of conduct.
Grieg Seafood employees working with third parties must:
- Provide them with information about Code requirements.
- Ensure that they agree to comply with relevant aspects of the Code including our no tolerance policy for bribery or other corruptive acts. Such compliance may be contractually agreed.
- Take appropriate action, up to and including terminating a contract, after learning that a third party failed to follow our requirements.
Intermediaries such as agents, consultants and others who act as middlemen between Grieg Seafood company and a third party in matters concerning business, are expected to adhere to values and principles that are consistent with Grieg Seafood`s Code of Conduct.
Grieg Seafood employees working with intermediaries must:
- Provide them with information about Code requirements.
- Ensure that they agree to comply with relevant aspects of Code including our no tolerance policy for bribery or other corruptive acts.
- Ensure that all agreements with intermediaries are in writing, defining compensation and services to be rendered. Compensation should be appropriate and justifiable for the legitimate services rendered.
- Take appropriate action, up to and including terminating a contract, after learning that an intermediary failed to follow our requirements.
Fraud and fraudulent behavior
Overall principle – Zero tolerance
We have zero tolerance for all forms of fraud, corruption, facilitation, payments, kickbacks, bribery and other misconducts, and all employees have a legal, corporate and ethical responsibility to ensure they are not knowingly providing support in a transaction involving fraud or corruption. Any involvement in fraud, bribery or corruption will lead to serious consequences for parties involved.
Fraud: Deception deliberately practiced in order to secure unfair or unlawful gain for one self or others.
Corruption: The abuse of entrusted power for private gain. Active – The promising, offering or giving by any person, directly or indirectly, of any undue advantage .. for himself or herself or for anyone else, for him or her to act or refrain from acting in the exercise of his or her functions. Passive – The request or receipt.., directly or indirectly, of any undue advantage, for himself or herself or for anyone else, or the acceptance of an offer or a promise of such advantage, to act or refrain from acting in the exercise of his or her functions.
Facilitation payment: Small unofficial payments made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement.
Kickbacks: A payment or bribe given by a person as a reward for an improper action.
Bribery: The offering, giving, receiving, or soliciting of any item of value to influence the actions of an official or the other person in discharge of a public or legal duty. Bribes can include money, gifts, hospitality, expenses or any direct or indirect benefit or consideration.
Misconduct: Any disloyal, blameworthy, unjust or illegal action and/or breach of Code of Conduct.
Leading by example
Managers in the Grieg Seafood Group (fully and majority owned subsidiaries) are expected to lead by example and demonstrate ownership of the anti-fraud and anti-corruption program. They shall ensure consistent communication, support, enforcement and training.
- Norwegian Civil Penal Code
- UK Bribery Act: Generally prohibiting organizations that are either established in the UK or conduct some part of their business in the UK from bribery offences.
- Legislation within the countries and territories where Grieg Seafood or its majority or fully owned subsidiaries operates.
Fraud risk and risk assessment
Grieg Seafood Group`s anti-fraud and anti-corruption program covers all aspects of the Group`s business.
Fraud risk assessment responsibilities
Regional managers/the Head of Ocean Quality are expected to assess relevant fraud risks at least annually. The CHRO or compliance manager will facilitate and consolidate the risk assessment.
Risk based approach to risk assessment
We should take a risk based approach to managing bribery risk. Six principles should be followed in a good procedure to prevent bribery:
- Efforts should be proportionate to the bribery risks the organization faces. This means that it should focus on the relevant risk in the order of priority that they affect us.
- The top-level management and board must be committed to preventing bribery. They must foster a culture in which bribery is never acceptable.
- There should be a documented periodic assessment of bribery risk in place in the organization (in GSF this should happen annually, and documentation is a local responsibility).
- The organization should have a risk based approach to choosing who we allow to perform services on our behalf within the organization.
- The anti bribery procedures should be embedded and understood throughout the organization.
- The organization monitors and reviews procedures designed to prevent bribery and makes improvements where necessary.
Factors to consider in a risk assessment
The risk assessment shall, among other factors, consider:
- Gifts, hospitality and entertainment, political and charitable contributions.
- Use of agents and other intermediaries, joint ventures or similar relationships.
- Use of contractors and suppliers.
- Routines for segregation of duties.
- Routines for employee`s subsidiary occupation.
- Actual or apparent conflict of interest in personal and professional relationships.
- Compliance with laws and regulations.
- Breach of accounting principles.
- Error in reporting or manipulation of information (including management override).
- Damage to the environment.
- Fraud related to asset management.
What we expect from our employees
Grieg Seafood is made up of more than 700 individuals with different backgrounds, nationalities, cultures and customs. Behaving with integrity rooted in our values and ethical guideline, is a prerequisite for us to e considered a preferred provider of sustainable produced Atlantic salmon, recognized by our stakeholders as a dependable, reliable and competent partner. As a Grieg Seafood employee, you are expected to act according to the Code of Conduct at all times. Employees expected to:
Understand the Grieg Seafood Code of Conduct
- Understanding the implications of the Code of Conduct for your personal behavior.
- Learn and understand the details of all Grieg Seafood Group policies relevant to your job.
Raise your concerns
- Promptly raise concerns or questions about Group policies and potential violations.
- Know the different channels for raising concerns.
- Be open and honest in any inquiries related to concerns.
- Go to your manager, employee or union representative, group management or Human Resources with any questions about Grieg Seafood Group policies.
What we expect from our leaders
Leaders must actively promote the Code of Conduct, act as role models to create a culture where employees understand their responsibilities and feel comfortable raising concerns about ethical issues and compliance with the law.
Business results are never more important than ethical conduct, health and safety of our people, and compliance with Grieg Seafood policies. In order to ensure that all employees understand this, leaders need to:
Ensure that guidelines are known and respected
- Verify that employees are trained in, and understand the Code of Conduct.
Prevent compliance issues
- Identify business and compliance risks, and ensure that these risks are known and addressed.
Respond to compliance issues
- Take prompt corrective action to fix identified weaknesses.
- Take appropriate disciplinary action when needed.
- Cooperate with regulators and law enforcement authorities if under investigation.
Detect compliance issues
- Promote effective compliance systems.
- Facilitate effective use of channels for raising concerns.
Concerns may be raised through numerous channels – we encourage you to use the channel most comfortable to you. We also encourage you to raise your concerns early as the longer you wait, the more difficult it may become to solve the problem. Your concern may be raised orally or in writing.
Chief Human resource officer
The ethical decision test
Three questions you should ask yourself:
Is it legal?
Will I be violating civil law, company policy, or ‘standard practice’?
Is it balanced?
Is it fair to all parties involved today and in the long term?
Does it promote a solid relationship in the future?
Is it justified?
Do I jeopardize Grieg Seafood`s or Ocean Quality`s reputation if my decision became known to the public?
How would I feel about myself if my friends, family or colleagues read about it in the (social) media?
Who you can contact and what happens next?
Contact your manager
The quickest and often most efficient option.
Contact your managers manager, HR, your union representative or the whistleblower channel
Use one of these channels if you feel that you cannot go directly to your manager or if you feel that he or she is not appropriately responsive to your concern.
The Grieg Seafood Whistleblowing procedure describes in detail what will happen next if you raise a concern.
Whistleblower Routine for Grieg Seafood
What is whistleblowing?
Whistleblowing is to notify about unacceptable conditions regarding the business to someone who can do something about it.
When and how may you notify?
The Norwegian Working Environment Act section 2-4 provides a general right of workers to report unacceptable conditions in the workplace.
Grieg Seafood has established a system for notifications in order to strengthen the ability to detect misconduct in the workplace.
The system shall provide an easy and safe way for employees to notify, and is in line with Grieg Seafood’s values «open, respectful and ambitious».
Notification may be given in various ways. The starting point is to bring unacceptable conditions to the attention of your immediate supervisor. Alternatively, you may go to the next supervisor level, union representative or safety delegate. In addition, Grieg Seafood has engaged Ernst & Young (EY) to receive notifications on our behalf.
You may notify by Web - Intranet, letter, telephone or in person. You may choose to notify anonymously or by name.
You may contact EY via telephone or mail:
+47 24 00 20 14 (in service Monday through Friday from 9 a.m. to 4.00 p.m).
Att: Whistleblowing Service
Fraud Investigation & Dispute Services (FIDS)
P.O. Box 20 Oslo Atrium
What constitutes unacceptable conditions?
Examples of factors eligible for notification are (not exhaustive):
- Financial crime, corruption and violations of the competition rules, financial fraud/embezzlement, fraud, insider trading etc.
- Violations of other laws and regulations, including environmental laws, licencing regulations and the tax- and accounting rules
- Violation of internal guidelines
- Harassment or discrimination of employees
- Conditions that pose danger to life or health
Is there a duty to notify?
Employees have a duty to notify about possible criminal offenses.
The Norwegian Working Environment Act section 2-3 defines some further cases where you have a duty to notify. This applies to situations that could endanger the life or health and where you are unable to remedy the situation, as well as situations implying harassment or discrimination in the workplace.
There is also a duty to notify if an employee is injured at work or contracts an illness that the employee believes to result from the work or conditions in the workplace. A duty to notify may also follow from other laws and regulations or contractual obligations.
Who may notify?
Grieg Seafood’s system for notifications applies to all employees.
What should the notification contain?
- Name of whistleblower (may be anonymous, see below)
- Place of work/department of affiliation (may be anonymous, see below)
- Date of notification
- Period, or the date and time of observation of the unacceptable conditions
- Specifically what is observed (persons involved, place, action/situation, etc.)
- Witnesses or others who may have relevant information and who may be contacted in the matter
- Information regarding previous conditions that may be of relevance to the matter
- Documentation that may be relevant or contribute in clarifying the matter should be attached.
In case of oral notification, the recipient will document the notification in accordance with the above content list.
If you wish to report anonymously, you may proceed normally without disclosing your name. Alternatively, you may identify yourself and request your identity not to be disclosed.
What are the requirements for notification?
The procedure for notification must be justifiable. Justifiable means that you have grounds for criticism, and that you have taken sufficient account of the employer’s legitimate interests with respect to the manner in which notification is done.
The requirement to notify justifiably generally means that notification ought to be done through Grieg Seafood’s established whistleblowing system or to public authorities.
You may in any regard notify in accordance with a duty to notify or through Grieg Seafood’s established whistleblowing system.
What principles apply to the follow-up of notifications?
Follow-up of notifications should be balance the interests of relevant interests involved: the whistleblower, the person against whom the notification is directed, the company and other interested stakeholders. Grieg Seafood’s whistleblowing system shall safeguard basic principles for safe follow-up of notifications, including:
- All notifications should be taken seriously
- All notifications shall be followed up without undue delay
- It is possible to notify anonymously
- All notifications shall be kept confidential and the whistleblower’s name is treated as confidential information
- Basic legal principles must be maintained, including the affected parties’ opportunity to comment (contradiction)
How is a notification followed up?
The person who receives a notification is responsible for initiating follow-up. Grieg Seafood has established rules for follow-up of notifications (Procedural Rules) to be followed by the person or persons who follows up a notification. The person who receives a notification may always transfer the matter to EY for follow-up.
If the line manager of the responsible line receives the notification, he/she shall initiate appropriate follow-up and transfer the matter to EY for follow-up.
If a safety delegate or union representative receives the notification, he/she shall forward the matter to transfer it to EY for follow-up.
If the person who receives the notification is covered by the unacceptable condition, this person shall transfer the matter to EY for further follow-up. If notification is vague or does not contain sufficient information and/or documentation, follow-up of the notification may be difficult. The same may apply if the notification is anonymous, partly because it is not possible to ask follow-up questions to an anonymous whistleblower.
The matter may nevertheless be subject to follow-up, e.g. by collecting information on other grounds in order to obtain information which may be of relevance to the matter.
A full follow-up of a notification covers the following main steps:
- Registration of the notification and submitted information, and preliminary investigations.
- If the matter may easily be resolved by the person who received the notification, he or she shall resolve it. Alternatively, the notification shall be transferred to EY for clarification with the CEO and CFO of Grieg Seafood ASA of whether further investigations are required.
- If it is decided to investigate the matter further, the CEO and CFO is responsible for initiating a decision about who shall do the investigation, and how the matter shall be followed up further.
- The matter shall be investigated properly and reported to relevant leaders for decision on any action.
- Upon conclusion, the matter shall be archived and sensitive personal data shall be deleted.
Will you receive feedback on your notification?
The whistleblower shall, if possible, be given a confirmation that the notification is received. Upon conclusion of the matter, the whistleblower will, if possible, always get feedback on how the matter was followed up and the outcome, provided that this can be done without disclosing confidential information.
A whistleblower who has questions or otherwise wants feedback during follow-up of a specific notification, may contact EY in this regard.
Consideration of the person against whom the notification is directed
The person against whom the notification is directed should basically be informed about the notification and the information provided. This gives the person an opportunity to present his or her version of the matter. The time for such information may depend on the circumstances of the matter and the need to safeguard information. When the matter is concluded, the person against whom the notification is directed should be notified, regardless of the outcome of the matter.
Retaliation is prohibited
The system for notifications can be used without fear of reprisal. If management or colleagues disagree with the allegations, disagreement with substantive arguments is still permitted.
Responsibility to report
If you have a concern about compliance with our Code of Conduct, you have a responsibility to raise that concern. You may remain anonymous, but if you identify yourself, we are able to follow up with you directly and provide feedback. Your identity and the information you provide will be shared only on a ‘need to know’ basis with those responsible for resolving the concern.
Retaliation is a violation of our Code of Conduct
We prohibit retaliation against anyone for raising or helping to address a concern about violation of the Code of Conduct. Retaliation is rounds for sanctions, up to and including dismissal.
Situations where retaliation could potentially be a concern should be raised as early as possible at the level felt appropriate to the situation (See Raising concerns).
If you are not sure whether practice is ethical or not, you ask yourself these questions:
Is it legal?
How would it be perceived if this practice became public knowledge?
Would I want my family or friends to read about it in the newspaper or in social media?
What should you do if you cannot answer positively to these questions?
- Ask a trusted colleague what he or she thinks, so that you can be sure whether the practice violates the Code of Conduct or not before you decide whether to notify you immediate manager.
- Confront the person who is responsible for the practice to find out what they think.
- Notify as soon as possible your manager, your managers manager, union representative, Group management, Human Resources or directly to Grieg Seafood’s independent Whistleblower Channel, managed by EY.
As an employee, you have a right and responsibility to raise concerns or questions whenever you have any doubts. Raise concerns early, because the longer you wait, the more difficult it might be to fix the problem. Where reporting to the line management is not possible or difficult, we recommend you use the Whistleblower channel. Please refer to the Grieg Seafood Whistleblowing Policy.
You report a common practice to your manager that to you appear to be a violation of the Code of Conduct. Time passes, and the practice continues. You still have concerns whether the practice is permitted according to the Code of Conduct, or not.
What should you do?
- Ask your manager whether he or she has investigated the matter. If your manager explains that the practice is permitted by the Code of Conduct, then you can trust this is correct and you do not need to do anything else about the matter.
- Nothing. You have done what was expected of you by reporting the matter to your manager. It is now up to the manager to take the matter further.
- Go straight to your manager’s manager, union representative, Group management, Human Resources or directly to Grieg Seafood’s independent Whistleblower Channel with your concerns in order to reassure yourself that the matter will be handled in a responsible manner.
If your manager does not respond to your enquiry and you still have concerns, you have a responsibility to go to your manager’s manager, union representative, Group management, Human Resources or directly to Grieg Seafood’s independent Whistleblower Channel, managed by EY to air your concerns. You will then have raised your concerns at the level expected of you.
Can you be punished if you raise a concern in good faith about a matter that turns out not to violate the Code of Conduct after all?
- It varies, depending on what the case is about.
- Yes, if your allegations lead to others being wrongly accused of violating the Code of Conduct, you may be subject to minor punishment.
- No, Grieg Seafood absolutely prohibits retaliation against anyone for raising a concern in good faith about violation of the Code of Conduct.
All types of retaliation are prohibited. Retaliation is grounds for sanctions, up to and including dismissal.