Code sections

• Anti-corruption
• Business partners
• Competition
• Confidentiality and Information Handling
• Conflicts of Interest
• Climate and Environment
• Financial Integrity and Fraud
• Gifts, Hospitality and Travel
• Health, Safety and People Security
• Human Rights and Labour Rights
• Insider Trading
• Money Laundering
• Privacy
• News and Social Media
• Public Officials
• Safeguarding our Assets
• Workplace Environment
• Speak up

Anti-corruption

Telenor has zero tolerance for corruption.

What we need to know

• Telenor does not tolerate bribery or improper payments or advantages of any kind
• We are committed to conducting our business in an open and transparent manner
• Bribery is illegal and exposes those involved and Telenor to reputational and legal risk
• Bribery may take many forms including facilitation payments, kick-back schemes and the use of shell companies or hidden owners
• Public Officials are often subject to strict anti-corruption rules and so should be treated with extra caution
• Corruption in our supply chain may create significant risk for Telenor even if we are not directly involved
• Gifts and hospitality may be considered bribery or providing an improper advantage in certain situations
• Even charitable donations or sponsorships can be seen as bribes if undertaken to secure a commercial advantage

What is expected of us

• We never engage in bribery or trading in influence
• We never give, offer, ask for or accept an improper payment or advantage
• We never make facilitation payments unless we believe that our life or health is in danger
• We always report any request from any 3rd party for a bribe or facilitation payment
• We never request someone else to engage in conduct that we are not allowed to engage in ourselves
• We carefully select our Business Partners and monitor their commitment to ethical and lawful conduct
• We maintain our books and records to accurately and fairly reflect our business
• We exercise appropriate caution when interacting with Public Officials
• We always speak up to our managers, the Compliance Function, or through the Integrity Hotline when we have concerns regarding corrupt conduct of our colleagues or business partners

What to look out for

• If we become aware of unusual or inflated payment terms that appear to have no clear business purpose
• If we suspect that a business partner is not complying with Telenor’s standards for business conduct
• If we become aware of that a business partner is interacting with public officials on our behalf
• If requests are made to donate to charities or sponsor organizations that may be affiliated with a public official
• If we are offered or requested to provide gifts, travel, donations or lavish entertainment or to make cash payments for any reason

 

Business Partners

We expect our Business Partners to meet our standards and respect our values when working for or with us.

What we need to know

• The actions of our Business Partners can damage our reputation and expose us legally
• Business partners include individuals and entities, with whom Telenor engages or plans to engage, such as suppliers, agents, distributors, franchisees, joint venture partners, sponsorship and donation recipients, sustainability partners and other relevant parties

What is expected of us

• We only work with business partners that demonstrate satisfactory standards of responsible business conduct and ethical values
• We expect our business partners to abide by all applicable laws to meet Telenor`s Supplier Conduct Principles for responsible business conduct and to protect us from risks while working for or with us
• We exercise caution when selecting business partners, and we follow Telenor’s procedures including risk assessments
• We monitor and support our business partners to conduct their activities in accordance with Telenor’s standards for responsible business conduct
• We carefully evaluate business opportunities to ensure that they are in compliance with applicable trade controls including sanctions regimes and import-export requirements
• We treat all business partners with respect and in a fair and transparent manner

What to look out for

• If we encounter a business partner not fully committed to following our standards including, Telenor’s Supplier Conduct Principles, where applicable
• If we seek to engage a business partner who will operate as a lobbyist, agent or other party which will act on behalf of Telenor
• If we become aware of that a Business Partner conducts business in a way that could reflect negatively on Telenor
• If any business partner has not been properly assessed and managed according to Telenor’s requirements
• If we become aware of other behaviour or circumstances that make us question the conduct or ethics of a business partner

 

Competition

We compete fairly.  

What we need to know

• Fair competition is important to society and creates long-lasting business opportunities for Telenor, in all countries where Telenor is present
• Creating or benefiting from an unfair advantage will harm our reputation with our customers, business partners and the public
• Anti-competitive agreements or practices are not only against our standards, they are against the law

What is expected of us

• We make our own pricing and business strategy and compete on the merits on our offerings
• We limit communications with our actual or potential competitors and do not share commercially sensitive information
• We do not, formally or informally, enter into agreements or practices with actual or potential competitors to share markets, fix prices or limit input or sales
• We obtain approval from the Business Unit according to the Group Manual before joining a Trade Association or Industry Forum
• We remove ourselves immediately from the discussion and report the conversation to our Legal Function and/or integrity hotline should a conversation with an actual or potential competitor turn to an inappropriate, anti-competitive subject
• We have an obligation to promptly report suspected violations of competition laws to the Legal Function

What to look out for

• If we are approached by actual or potential competitors, customers or business partners with information about their pricing, strategies, business tactics or similar topics
• If we suspect formal or informal agreements exist, or otherwise are to be entered into, that limit our actual or potential competitors’ access to customers or related markets
• If we plan to attend informal or social meetings with actual or potential competitors
• If we plan to interact with actual or potential competitors where there are indications that the objective is to exchange competitive sensitive information
• If we plan to establish pricing strategies or other market strategies that could be viewed as abuse of dominant position
• We plan to establish pricing strategies or other market strategies that could be viewed as abuse of dominant position

 

Confidentiality and Information Handling

We treat information as a valuable asset and act accordingly.

What we need to know

• As employees of the company, we sometimes come into possession of valuable information regarding Telenor, customers or Business Partners
• Most information is digital and can easily be accessed, modified, shared and replicated
• Records are information with high corporate value. They are important to Telenor and must be identified and protected
• There may be external requirements as to how long you can or must retain different types of information
• Confidentiality is critical for Telenor’s reputation and for protecting Telenor’s interest in competitive and regulatory processes, and for securing the integrity of our assets

What is expected of us

• We only share confidential information when we are authorized to do so and there is a legitimate reason for doing so
• We protect confidential information from unauthorized access
• We promote a knowledge-sharing culture but take precautions when processing confidential information
• We treat information from third parties with the same level of confidentiality and care as our own information
• We do not discuss sensitive topics in public places
• We ensure that all information from Telenor is reliable and correct and complies with high professional and ethical standards
• We use Telenor approved systems and perform information processing activities in line with any issued requirements

What to look out for

• If we overhear a Telenor employee speaking about non-public information in public
• If a business partner requests us to sign a confidentiality or non-disclosure agreement
• If we are handling information or company records which are sensitive and should be protected
• If someone attempts to engage us in discussions that lead into details of Telenor’s business
• If you are sharing confidential information with any external parties

 

Conflicts of Interest

We always act in the Telenor's best interests.

What we need to know

• A conflict of interest exists when our personal interest conflicts, or could be perceived to conflict, with Telenor’s interests
• Personal interests include our financial interests, business opportunities, outside employment or the interests of people close to us, like close family members, personal friends or business associates
• Even the perception that we may not be acting in the best interest of Telenor can call into question our integrity and adversely affect our reputation
• All decisions that are made on behalf of Telenor must be based on an objective and fair assessment of the company’s interest without being impacted by our personal interest
• Openness and transparency are essential to manage actual, potential, or perceived conflicts of interest
• A conflict of interest can still exist even if the company benefits in some way

What is expected of us

• We avoid conflicts of interest and other situations which could impact our judgment
• We recuse ourselves from situations and decisions where we have a potential or perceived conflict of interest
• We promptly disclose actual, potential, and perceived conflicts of interest to our manager
• We work with our manager to resolve conflicts of interest and document our decisions and actions
• We always involve the Compliance Function if a conflict of interest cannot be avoided
• We do not hold external duties or positions that could affect, or be perceived to affect, our responsibility to act in Telenor’s best interest
• We obtain written approval from our manager before accepting external directorships or other material assignments, and we keep records in accordance with company procedures

What to look out for

• If we have a financial or other interest in an existing or potential Business Partner of Telenor
• If we hold outside employment or positions which could interfere with our ability to perform our duties for the company
• If we are recruiting, hiring, or directly supervising a family member, friend, or individual with whom we have a close personal relationship
• If we are offered anything of value in our personal capacity from existing or potential business partners including gifts, discounts or other benefits
• If a Business Partner of Telenor is or will provide services to us in our private capacity

 

Climate and Environment

We are committed to protecting the environment and contributing to the prevention of climate change.

What we need to know

• We comply with local laws and internationally recognized environmental standards
• We are committed to minimising our use of resources including energy, water and raw materials 

What is expected of us

• We seek to make reasonable efforts to minimise greenhouse gas emissions from our operations
• We consider climate and environmental impact when purchasing products and services, and evaluate our suppliers on responsible business criteria
• We support sustainable waste management including making reasonable efforts to minimise our waste
• We are transparent and report on how our activities impact the climate and environment
• We report incidents we see that are harming the climate and the environment

What to look out for

• If we become aware of Telenor`s operations and suppliers that fail to meet our climate and environmental standards
• If we become aware of that applicable environmental regulations or company guidelines are being breached

 

Financial Integrity and Fraud

We maintain accurate financial records and comply with all disclosure standards.

What we need to know

• Financial integrity is key to maintaining the trust of our shareholders, customers, business partners and employees
• Meeting International Financial Reporting Standards is not only required, it also enables us to best manage our business

What is expected of us

• We follow Telenor’s Accounting Principles (TAP) and abide by internal controls implemented by Telenor
• We register all transactions correctly in accordance with legal obligations and good accounting practices
• We report accurately, reliably, transparently, consistently and in a timely manner
• We ensure that expenses are reasonable and recorded properly when we spend the company’s money
• We make decisions in accordance with applicable Group or Local Authority Matrix and ensure segregation of duties where applicable
• We verify facts and completeness of information and underlying business rationale before approving a transaction or signing a document
• We do not create fraudulent records, falsify documents or otherwise misrepresent facts, transactions or financial data

What to look out for

• If we see financial or accounting irregularities
• If we become aware that a colleague or business partner has falsified any documentation
• If we are unsure if we have recorded a transaction correctly
• If we become concerned that any employee is misreporting financial information, including sales results or forecasts
• If we become concerned that Telenor’s resources are not being spent or recorded consistent with our policies

 

Gifts, Hospitality and Travel

We avoid business courtesies that may be perceived as impacting business decisions.

What we need to know

• Business courtesies like gifts, hospitality and travel may create a conflicts of interest or be considered bribery in certain circumstances
• Gifts are something given without the expectation of anything in return, including goodwill
• Hospitality takes many forms, including meals and beverages, seminars, receptions, social events and entertainment
• Travel includes the costs of transportation including taxis, buses, trains, flights, accommodation and hotels, and other incidental travel costs
• Business partners, including public officials, may need to comply with strict rules on what they may give or receive

What is expected of us

• We never offer or accept business courtesies which could, or could be perceived to, improperly influence a business decision
• We never offer or accept cash or cash equivalents, or expensive and extravagant gifts
• We do not offer or accept gifts except promotional items, of minimal value normally bearing a company logo, and only when it would be customary to do so
• Should an employee receive a gift that is not in compliance with these rules, it shall be returned or be turned over to Telenor as soon as possible
• We may offer or accept hospitality when the business purpose is clear and legitimate, the costs are reasonable, and the context is open and transparent, but we prefer to cover our own costs
• We always pay our own costs for travel, accommodation and related expenses. Likewise, we do not pay for travel, accommodation and related expenses for others
• We do not allow business courtesies to be extended to family or close friends
• We always discuss offering or accepting business courtesies with our immediate supervisor

What to look out for

• If business courtesies are offered during sensitive situations like ongoing negotiations or procurement processes
• If asked to sponsor, donate or contribute to faith-based organizations, political, governmental, military, police and/or other public institutions and entities
• If we become aware of business courtesies that are not offered or accepted in an open and transparent manner
• If we believe that offering or accepting business courtesies could lead others to question our independence, objectivity or integrity
• If we become aware of repeated offers to or from the same business partner, or a related one

 

Health, Safety and People Security

We provide a safe and secure workplace for all employees and our supplier.

What we need to know

• We all have a responsibility to provide a healthy, safe and secure working environment for all employees, business partners and visitors
• We recognise a shared commitment and responsibility to ensure the health, safety and well-being in our operations and throughout our value chain
• We comply with international and local HS&S legislation and guidelines, and aim to perform to the highest standards within this area
• We promote as one of our core values a proactive work culture of engagement and commitment towards the health, safety and well-being of employees and everyone who works for us
• We promote a culture of proactive HS&S incident reporting from employees and suppliers

What is expected of us

• We are conscious of our work environment, act responsibly and are accountable for our own actions
• We proactively foster a safety culture and collaborate with our suppliers in identifying and mitigating health, safety and security risks
• We make ourselves aware of potential risks in our workplace and continuously work to minimise any hazards to the health, safety - and well-being of our employees and business partners
• We ensure that incidents, near-misses, unsafe acts and conditions are reported regardless of their severity for lessons learned and continuous improvement
• We immediately stop and report unsafe work

What to look out for

• If we see any unsafe acts and conditions that might put ourselves, our colleagues or suppliers at risk
• If we have any concerns for the health, safety and well-being of any employee
• If our policies and requirements are not followed or do not comply with HS&S legislation
• If there are any signs of unsafe situations, elevated stress, inappropriate behaviour or poor well-being of employees and/or business partners

 

Human Rights and Labour Rights

We respect human rights and labour rights

What we need to know

• We are all equally entitled to human rights and labour rights without discrimination as set out in international fundamental principles, conventions and local laws 
• We have the responsibility to respect human rights. Respect for human rights is integral to Telenor’s business and how we operate.
• Labour Rights are a vital part of human rights
• We are committed to contributing towards a positive human rights impact on society

What is expected of us

• We take necessary measures in order not to violate, nor are we complicit in violations by others, of the human rights and labour rights of our colleagues, the employees of our business partners, our customers and anyone impacted by our operations
• We will report on any actual or potential violation of human rights or labour rights to our manager or through other existing mechanisms, such as the Integrity Hotline
• We will contribute to positive human rights impacts, including children’s rights and digital inclusion

What to look out for

• If we experience, become aware of or suspect any violation of human rights of our colleagues, employees of business partners or of any people where we operate
• If we, or one of our colleagues, are prevented from joining legitimate employee engagement forums, e.g. labour unions
• If anyone, including public officials, asks for personal data on Telenor employees, customers or business partners without the right authorization and without following due process
• If a contract we are negotiating has such a low price or short delivery period that it will likely lead to low wages or excessive working hours for business partner employees.
• If an existing or potential business partner refuses to commit to the Supplier Conduct Principles or is not willing to collaborate in relation to inspections, audits or other transparency efforts

 

Insider Trading

We do not share or act on insider information.

What we need to know

• Inside information is any non-public information that would impact the stock price of a company if it was known to the public, such as financial results not yet disclosed publicly, potential mergers and acquisitions, senior management changes and significant legal matter
• Trading on inside information violates our ethical standards and is a personal criminal violation under any jurisdiction’s laws, and may lead to severe consequences for you personally and for Telenor as a company
• Sharing inside information with others who then trade on that information is considered tipping and is a violation of both our governing documents and the law

What is expected of us

• When in possession of inside information about Telenor or any other company, we do not trade, engage in tipping or suggest that others should trade in any securities
• We treat all inside information that is not generally available to the investing public as proprietary and confidential

What to look out for

• If we become aware of a business or legal issue that may have positive or negative consequences for the price of Telenor’s stock or that of a customer or business partner
• If someone suggests that we buy or sell a security based on material non-public information
• If we are notified that we are on an insider list
• If we are part of a merger acquisition or key strategic project
• If your business unit is publicly listed (stock exchange)

 

Money Laundering

Telenor is opposed to all forms of money laundering.

What we need to know

• Money laundering is the process of hiding or disguising the proceeds of a crime
• The proceeds of a crime can be anything of value including money, goods, assets and real estate
• Money laundering may take many forms and can occur in all kinds of deals and transactions, including banking, investments, invoicing and property
• Trusts and shell companies may disguise the true owners of money and increase the risk of money laundering
• Money laundering also includes the use of legitimate funds to support criminal activity or terrorism criminal activity or terrorism

What is expected of us

• Telenor seeks to engage business partners involved in legitimate business activities with funds derived from lawful sources
• We avoid money laundering by screening and monitoring our business partners in accordance with Telenor’s procedures
• We question unusual payments or banking arrangements and report unusual requests
• We always consult the Legal and/or Tax Function if we are in doubt about the origin or destination of money and property
• We promptly report suspicious transactions or incidents of money laundering
• We are attentive to potential under or over-valuing of invoices or assets

What to look out for

• If payments are requested or performed in a different manner than what is agreed to in the contract
• If payments are received in cash and are not customarily paid in this way
• If payments come from offshore bank accounts
• If payments come from unusual accounts not typically used by the party in question

 

Privacy

We earn trust by protecting all personal data.

What we need to know

• We hold personal data on all our customers and employees and we have an obligation to protect it and only use it for legitimate business purposes
• Personal data includes employee, customer and business partner information such as content of communications, phone numbers, e-mails, addresses, locations, call and payment history, salaries and health information
• All personal data is to be considered confidential
• Responsible use of personal data is instrumental in maintaining our customers’ and employees’ trust

What is expected of us

• We do not share personal data with anyone who does not have a specific business purpose for it, unless sharing the data has been authorized or is legally required
• We only access personal data for specific business purposes
• We are open and honest with our customers and employees about how we use their data
• We ensure that personal data is not processed without proper access control, security and data protection measures in place
  We stay informed of our responsibilities related to privacy when we work with projects or initiatives that involve personal data processing
• We follow established privacy procedures and processes

What to look out for

• If there is unauthorized access to personal data, including sharing of data with third parties without appropriate privacy safeguards in place
• If we are collecting data about our employees or customers which they would not reasonably expect us to collect or use in this way
• If the personal data of our employees or customers is being used in a way that may be considered intrusive
• If a government official requests information about an employee or a customer, including business records without following proper procedure
• If there are any indications that personal data has been or may be compromised

 

News and Social Media

We always act responsibly in our external communications.

What we need to know

• Telenor employees are encouraged to share non-confidential news, milestones and achievements related to Telenor on their social media account(s)
• However, only mandated individuals are allowed to speak on behalf of Telenor, including on social media or other digital platforms
• Telenor does not take political positions or associate with political movements, though we may participate in public debates on topics important to our strategy and business performance
• Telenor does not support political parties, neither in the form of direct financial support, in-kind donations, nor paid time

What is expected of us

• We do not engage in external discussions, including on social media, on behalf of Telenor unless we have been previously authorized to do so
• We do not discuss sensitive or confidential information from our work in public or social media
• We reflect only our personal views in social media. However, as a Telenor employee we are mindful that social media posts can spread rapidly and are difficult to retract, and therefore exercise caution before we post
• We refer external questions about Telenor from journalists/media to the Communication Function and appropriate spokespersons
• We are mindful that Telenor operates across multiple countries with diverse values and legal frameworks, which means that local communication can have global impact
• We may participate in political activity provided it is lawful, conducted in our own time, with our own resources, and not linked to our employment in Telenor

What to look out for

• If we become aware of public discussions on social media or other media platforms with a potential reputational risk to Telenor
• When planning to speak at external events or other forums where we represent Telenor
• If we are concerned that our communications with outside sources could reflect negatively on the company
• If we promote our company and receive backlash from an external audience on social media or other media platforms

 

Public Officials

We follow high ethical standards when interacting with Public Officials.

What we need to know

• Public officials include all individuals employed by or acting on behalf of a government including anyone holding a legislative, administrative, executive or military office
• Public officials execute governance functions that are vital to the societies in which we operate and are also vital to our license to operate there
• Telenor interacts with public officials at various levels and for many different purposes
• Information shared with public officials may become public due to laws regulating public access to government-held information
• Individuals employed by state-owned companies may be considered public officials

What is expected of us

• We do not engage in conduct which could, or could be perceived to, improperly influence a public official
• We exercise appropriate caution toward public officials when Telenor is engaging in a commercial or approval process
• We are always compliant with local laws or rules that apply to public officials
• We do not offer gifts to public officials except promotional items of minimal value, and only when it would be customary to do so
• We do not pay travel, accommodation or related expenses for public officials
• We offer only modest hospitality to public officials and only when there is a clear and legitimate business purpose, the costs are reasonable, and the context is open and transparent
• We always discuss offering business courtesies to public officials with our manager and seek guidance from the Compliance Function as needed
• We do not make facilitation payments to public officials and we report requests for such payments to the Compliance Function
• We only use lobbyists to advocate on our behalf in special circumstances with full transparency and with prior written approval by the Business Unit CEO
• We ensure the third party towards whom any lobbying activity is being conducted is aware of our relationship with the lobbyist. In the event a lobbyist is used, it shall be promptly disclosed to the third party the lobbyist represents Telenor. The obligation shall be included in the agreement with the lobbyist
• We do not engage in external discussions with public officials on behalf of Telenor unless we have been previously authorised to do so special circumstances subject to a review by the Compliance Function and prior written approval by the Business Unit CEO

What to look out for

• If a business partner directly or indirectly interacts with public officials on our behalf
• If a public official asks for the personal data of Telenor employees, customers or any other individual
• If a public official requests Telenor to send information or messages to our subscribers
• If a public official owns, manages or is affiliated with a business partner
• If a public official, or a close family member or business associate of the public official, applies for a position within Telenor

 

Safeguarding our Assets

Security is embedded in everything we do.

What we need to know

• Company assets are everything that our company owns or uses to conduct business including equipment, facilities, systems and information
• Protecting company assets is a core responsibility for all of us
• Intellectual property such as trademarks, copyrighted works, inventions, trade secrets and know-how, are often valuable and may be important to Telenor's success in the market
• Security threats can affect our assets and have significant financial, operational and reputational impact

What is expected of us

• We always assess the security risks and follow security policies and requirements when we make business decisions
• We report any security incidents immediately and in accordance with local procedures, laws and regulations
• We protect company assets from loss, damage, theft, waste and improper use
• We limit employee and third party access to company assets to what is necessary to accomplish assigned work
• We always follow proper protocols for granting access and do not share our access credentials, including PIN codes and passwords
• We only use Telenor approved systems for information sharing and storage 
• We protect our premises from unauthorised access and we wear our Telenor badge visible when in the office
• We protect Telenor’s intellectual property as appropriate and respect the intellectual property rights of others

What to look out for

• If we observe people on our premises or trying to enter our premises without authorisation or properly-displayed credentials
• If our cell phone, laptop or computer is lost, stolen or suddenly behaves differently
• If we receive emails, messages or calls that are suspicious
• If we detect vulnerabilities in our systems, processes or facilities

 

Workplace Environment

We treat each other with respect and dignity.

What we need to know

• All employees deserve a workplace environment, independent of work location, that is free from harassment, intimidation, discrimination or threats of violence for any reason, including actions based on gender, sexual orientation or identity, race, ethnicity, disability, national origin, religious or cultural beliefs or citizenship
• We view employee diversity as a competitive advantage, as it broadens our perspective and allows us to better understand our customers’ needs and wants
• Telenor does its utmost to actively promote equality in all employment practices
• We foster a working environment where people are treated honestly and professionally and are valued for their unique ideas and differences

What is expected of us

• We show respect for our co-workers and treat them as we ourselves would like to be treated
• We do not retaliate against any employee, business partner or customer for raising a good faith concern
• We do not engage in conversations or send communications of any kind that contain offensive name-calling, jokes, slurs, stereotyping, blackmailing or threats, nor do we display or share offensive pictures, cartoons, drawings or gestures
• We actively listen to different points of view and consider those perspectives exclusively on their own merits
• We confront any incidents of harassment or inappropriate behaviour and proactively protect our work environment
• We do not use alcohol or illegal drugs in the workplace, or abuse prescription medication, and we never purchase sexual services on business trips or other assignments

What to look out for

• If we experience, witness or hear of any form of bullying, mocking, or harassment of any kind
• If we experience or become aware of incidents of harassment, sexual harassment or discrimination of any kind involving anyone
• If our managers and supervisors are repeatedly identifying one colleague or a specific group of colleagues for criticism or special treatment based on characteristics unrelated to their work
• If we suspect that certain colleagues are not receiving fair consideration for promotions or project assignments
• If we are concerned that certain individuals or groups of colleagues are excluded from participating in activities or discussions

 

How to Speak Up

One of the Code Principles is that we "speak up." We ask our managers and the Compliance Function when we have questions about whether activities are ethical or compliant with our Code, and we always challenge and report activities that we believe may breach our Code or applicable law. Through reporting we enable Telenor to keep its promise to operate legally and ethically and we help the company to protect its good reputation. It is a responsibility that we share as Telenor employees.

It sometimes takes courage to come forward and share your concerns. If you are not comfortable discussing or reporting an issue to your manager or the Compliance Function, you may use the Integrity Hotline which is available to all employees, business partners and stakeholders. The Integrity Hotline is designed to protect the privacy of individuals who report a concern, and individuals who are the subject of a reported concern, through a reporting channel that is operated by an independent company. All reports are treated as confidential and a very restricted number of people are allowed access to them. The channel is always open and is available in most local languages. You may choose to remain anonymous. Your identity is kept confidential unless you agree otherwise.

All reported concerns are taken seriously and given fair and objective follow-up. The reports are first received and reviewed by Group Internal Audit & Investigation (GIAI). In cases that present serious allegations or concerns, GIAI will undertake an independent investigation to clarify relevant facts. Other cases are transferred to the Business Unit and managed by an appointed independent function. All functions are required to maintain all information in the strictest confidence to ensure the integrity of the process.

An important part of our compliance programme is taking effective corrective action and, where appropriate, employee discipline. In all cases, the Compliance Function supports management in resolving the investigated concerns to determine whether disciplinary or corrective actions are required. Anyone who violates the law, the Code, or a Telenor Policy or Manual may be subject to disciplinary action, up to and including termination of employment. Such violations may damage Telenor's reputation and result in commercial loss, and violations of the law may expose Telenor, and even the individual violator, to fines, penalties, damages and, in some cases, imprisonment.

It is important to remember that we can all report suspected unethical or illegal behaviour without fear of retaliation. Telenor does not tolerate retaliation of any kind against those who speak up in good faith.