ETHICAL GUIDELINES FOR INNOVATION NORWAY

The Act relating to Innovation Norway requires the company to have its own ethical guidelines. It is further required that Innovation Norway should have a high awareness of ethical issues, including corruption, the environment, human rights and the social responsibility and general conduct of the business community. The ethical guidelines for Innovation Norway were approved by the board of Innovation Norway  03.02.2005.

INTRODUCTION 

General
Innovation Norway is dependent on confidence and a good reputation to be able to contribute to innovation, internationalisation and profiling. This applies both nationally and internationally. To achieve this, we are dependent on all our employees conducting themselves in accordance with our ethical guidelines and following the requirements for conduct that are established in our branding strategy. 

The Act relating to Innovation Norway requires the company to have its own ethical guidelines. It is further required that Innovation Norway should have a high awareness of ethical issues, including corruption, the environment, human rights and the social responsibility and general conduct of the business community. Following our ethical guidelines is thus not only important for our own reputation, but also for living up to the expectations of our partners and owners. 

These ethical guidelines have been approved by the board of Innovation Norway. 

Extent and responsibility
The guidelines apply to all staff, both full and part time, trainees, temporary staff and consultants who represent Innovation Norway, as well as members of Innovation Norway’s board. The guidelines also apply to all who are stationed abroad and who represent Innovation Norway abroad. Certain provisions refer solely to employees and only apply to them. 

All those who are included in the scope of these ethical guidelines are expected to make themselves aware of them. It will be no justification to say that you didn’t know. All managers are responsible for making the guidelines known and for setting a good example. 

The managing director of Innovation Norway will handle any deviations from the guidelines. 

Infringement of the ethical guidelines will result in an appropriate response. Serious infringement of the guidelines may result in dismissal and possible referral to the police.

Putting it into practice and tackling dilemmas
The ethical guidelines are not exhaustive and cannot cover all dilemmas that you might find yourself in. If you are in doubt whether any activity is ethically acceptable, and you cannot find the answer in the ethical guidelines, you must first take it into consideration yourself. If you are still in doubt you should consult your line manager.

Causes for concern – reporting and reactions
The intention is to stimulate open discussion about responsible behaviour in an unbureaucratic way, with the focus on improvement.  

Any causes for concern or complaint that occur should normally be communicated along normal lines of administration. If you feel that this is not appropriate, communications may be directed to another manager or to the human resources unit. 

Such concerns are handled with discretion and complaints will be handled confidentially.  

A person who, in good faith, reports a possible infringement of the law or of the company’s guidelines will be protected against sanctions. To discriminate against or to persecute anyone for pursuing such questions will be considered an infringement of these guidelines.

INTERNAL SITUATION
Innovation Norway intends to create an open, involving and progressive working environment. All persons working for Innovation Norway should treat each other with trust and a positive attitude. This means that we must respect each other’s duties, competence, time and personality. 

Innovation Norway will uphold equal opportunity of employment and just treatment for all employees. Innovation Norway will consider only objective criteria when taking human resources-related decisions such as appointments, training, remuneration and promotion. 

It is moreover required that all employees must familiarise themselves with the staff regulations.

SITUATION REGARDING NATIONAL AND INTERNATIONAL LEGISLATION
Human rights standards are laid down in international human rights agreements, which are recognized by Norway and therefore apply to Innovation Norway. These agreements include employees’ rights and guidelines on corruption, among other things.  

Corruption is forbidden. Innovation Norway is bound to counteract corruption, in accordance with Norwegian law and international agreements. We will furthermore aspire to a sound knowledge of the types of corruption prevalent in various countries, so that we may advise our customers about how corruption may be avoided.

The Vienna Convention on Consular Relations deals with the formal ground rules governing diplomatic relations between countries. Staff representing Innovation Norway abroad and who for the duration of their period of duty are employed in the Ministry of Foreign Affairs are covered by this convention and by certain provisions of the Foreign Service Act.

BUSINESS ETHICS 

General
Innovation Norway administers public funds, which are to be employed to promote profitable business development throughout the country. Our promotion of wealth creation in society is to be carried out through the exercise of broad social responsibility in business practice. This means that we will base our activities on financial, social and environmental considerations and thereby contribute to sustainable global development. Our commercial conduct should, in accordance with our values, be perceived as upright and honest. This applies to both our commercial activities in the administration of public resources and our behaviour as employees of Innovation Norway.

Innovation Norway will not support businesses and projects that represent an unacceptable risk of encouraging unethical actions or omissions – such as the violation of fundamental humanitarian principles, violation of human rights, corruption or environmental destruction.  

Innovation Norway is drawing up a policy on how to safeguard, within our own target area, a broad social responsibility in business practice. Ethics and social responsibility will be among our assessment criteria for financing, consultancy, network building and profiling activities.   

Innovation Norway is to be a driving force in encouraging the same ethical attitudes among our customers and other partners.  

Our commercial decisions must be seen to be impartial, with our staff adhering to the directives about qualification in relation to personal and financial interests. 

Conflict of interests (impartiality)
The fundamental principle governing the regulations concerning impartiality in the Act relating to Innovation Norway is that our staff must not take part in, or seek to influence, proceedings, projects or decisions where conditions exist that may undermine confidence in the his/her impartiality. 

Such conditions might include a major personal or financial interest on the part of the person himself/herself or someone close to him/her, such as immediate family, relatives or friends. The same applies to questions of major financial special interest to companies, associations or other public or private institutions the person may be connected to.  

Staff must inform their line manager immediately if they become aware that a conflict of interests may occur. Partiality exists when conditions are established that may undermine confidence in the impartiality of the person concerned on grounds of an objective assessment. 

A person who is deemed to be partial must immediately terminate his/her dealings with the case.

Personal and financial interests in other businesses
Employees of Innovation Norway may not have external income from or assume directorships in other businesses, without written permission from Innovation Norway. Such consent will only be given where this activity is not considered likely to undermine public confidence in Innovation Norway. To maintain confidence in Innovation Norway, such relationships must be limited in extent and known within the organisation. Innovation Norway has created a conflict of interest database for the registration of board members’ and employees’ directorships, employment or ownership of other (not publicly listed) businesses. 

Employees are not permitted to market or perform private, paid services that are in competition with Innovation Norway’s activities.

Trading in the shares of companies not quoted on a stock exchange or within Innovation Norway’s area of activity must be notified and registered in the conflict of interest database. See Trade in financial instruments (securities), below.

Gifts and financial advantages
Our staff may not offer, promise or give any improper advantage to any person to achieve or maintain commercial advantages for Innovation Norway. 

Gifts or other benefits to our commercial connections must be made in accordance with locally accepted best practice and may only be given if they are of modest value. Monetary gifts must never be offered. 

You may not accept gifts in connection with negotiations or in recognition of a completed agreement. If you receive a gift or become aware that you are likely to receive such a gift, your line manager must be informed and decide how the case is to be handled. 

In other instances, such as gifts in connection with special events, presentations and similar, normally accepted appreciations may be received. (Value up to NOK 500). Specific guidelines apply to internal gifts. 

Neither may we accept discounts when buying goods or services for personal use from Innovation Norway’s contacts, unless these are part of a discount scheme offered to the whole staff or are publicly available. 

Representatives of Innovation Norway may not use their position to obtain financial advantages of any kind for themselves or those closely related to them. We are expected to make those closely related to us aware of the stipulations above. 

Trade in financial instruments (securities)
Subject to the limitations given below, employees have the same rights as anyone else to buy, own and sell financial instruments (hereafter: securities). This does not however include securities of great value and the trading must never be at the sacrifice of work for Innovation Norway. 

The Securities Trading Act stipulates that nobody is permitted to trade in transferable securities which are quoted on a stock exchange if the person concerned is privy to precise and confidential information which is likely to influence the price of the securities. Staff of Innovation Norway will, in the course of their work, gain access to information that is relevant to quoted prices and that is not publicly available. Such information must never be used for personal gain through trade in securities. In Innovation Norway this also applies to securities that are not quoted on a stock exchange.

Staff who choose to trade in securities connected with a company that they have obtained knowledge of through their work for Innovation Norway will be expected to exercise particular care in any trading.

Employees’ trading in shares that are not quoted on a stock exchange must be registered in Innovation Norway’s conflict of interest database.  

Special guidelines apply to all persons whose work with equity investments for Innovation Norway.

SECRECY OBLIGATION, CONFIDENTIALITY AND INFORMATION
All information given in connection with the work of Innovation Norway must be correct and dependable. Confidential information that is received in connection with case handling must be respected and not used for personal gain. Nobody should make use of files, data systems or other resources to actively seek information about customers where this is not necessary for his/her work. 

In cases where Innovation Norway, its customers or partners are discussed, a loyal and trustworthy attitude is expected. Particular care is required in the presence of representatives of the press or other media and in official meetings and assemblies. 

It is further expected that staff, when in discussion with customers and others, do not refer to Innovation Norway’s internal matters in such a way as to cause harm to the company, its employees or the services that Innovation Norway offers.

Non-disclosure and discretion
Our staff have an obligation to secrecy in respect of the commercial or private circumstances of others, to which they may become privy during the course of their work. This obligation continues to apply after the person concerned has left the employment of Innovation Norway.

The obligation to secrecy applies not only externally but also towards staff who have no need of the information for their work, always provided that this obligation should not hinder the development of commercial knowledge, cooperation and an active professional environment within Innovation Norway. 

The obligation to secrecy should not hinder the informing of line management about circumstances that may be considered to be in contravention of prevailing legislation and regulation.

Storage and protection of information
Each individual must take care that confidential or sensitive information about customers or about Innovation Norway’s internal matters must be protected by responsible storage and safekeeping of written and electronically saved information. The safekeeping of information, files and property belonging to Innovation Norway, its customers or other commercial contacts is in other words a responsibility which rests on everybody. 

All information that has been gathered, assessments that have been carried out and recommendations that have been made must be treated with the greatest care and discretion. 

Relations with media and the public
Innovation Norway’s public profile at home and in international markets is greatly affected by our ability to communicate in a consistent and professional manner with outside parties, including the media.

Innovation Norway is to be an open organisation that allows public access to its activities. Representatives of Innovation Norway must be service-oriented, proactive, honest and cooperative in their dealings with outside parties. 

The Freedom of Information Act applies to Innovation Norway. Out of regard for our customers’ need for confidential treatment, documents concerning specific applications for financing may be excempted from public access. The excemption however, does not apply to positive decisions on such applications.  

Information given to the media about Innovation Norway’s activities and plans must be correct and objective. All communication must be coordinated in such a way that Innovation Norway appears as uniform, consistent and worthy of confidence. 

Innovation Norway’s staff will in many cases be contacted directly by the media. It is then the responsibility of the individual to consider where to set the limit to what one could or should reply in the light of what is laid down in the communication strategy.

Approved by the board of Innovation Norway  03.02.2005.