Ethical rules

Gjensidige’s social mission is to safeguard lives, health and assets and to do so in a manner that takes the Group’s stakeholders into consideration.

A good business culture, sustainable choices and a positive reputation are fundamental preconditions for Gjensidige’s operations. We depend on the trust of our customers and shareholders, the authorities and society at large. In order to gain this trust, we must make sure that everything we do is characterised by professionalism, expertise and high ethical standards. This applies to both the Group’s business operations and our employees’ conduct. All employees must act with due care, honesty and objectivity, and must refrain from doing anything that could undermine people’s trust in the Group. Managers have a particular responsibility and must be good role models. 

All Gjensidige’s activities must stand up to public scrutiny. Employees are therefore expected to behave in accordance with the Group’s ethical rules. Employees who are in doubt as to what this means must contact their immediate superior.

The ethical rules apply to all employees and officers at Gjensidige, and to hired consultants when they act on behalf of the Group (cf. section 6.8 of the impartiality rules). 

The ethical rules set out requirements for ethical conduct, but do not cover all aspects of what constitutes ‘correct behaviour’. The Group has other guidelines and regulations that supplement the ethical rules. It is important, therefore, that employees use their own judgement as regards how to act in an ethically correct manner in each situation. 

In addition to following the ethical rules, employees must loyally comply with laws, regulations, circulars, relevant codes of ethics for the industry and internal rules that regulate the Group’s activities. Managers must ensure that employees are given an opportunity to familiarise themselves with the rules that apply to their particular field of work. However, it is the employee’s own responsibility to follow these rules.

The Group’s corporate culture shall be based on openness, which is a precondition for motivation, trust and a sense of security. We want all employees to feel confident about raising both minor and major issues with their superiors or others within the Group.
 
The ethical rules will not always tell us what is right and wrong in a given situation. It is important that employees raise relevant matters or actions with their manager or the HR department if they are unsure. Another option is to use the ethics mailbox. All enquiries will be treated confidentially.

5.1. Human rights
The Group shall support and respect fundamental human rights, among other things as described in the UN Universal Declaration of Human Rights and by the International Labour Organization (ILO). The Group’s financial investments shall be in accordance with recognised principles for ethical investments from a human rights perspective.

5.2    The environment and procurements
Gjensidige shall endeavour to reduce the business’s environmental impact on society, and ensure that employees can do the same. 

The Group is a major purchaser of goods and services. We must therefore make active endeavours to ensure that manufacturers and suppliers conduct their business operations in accordance with internationally recognised principles and guidelines relating to human rights and labour rights, the environment and anti-corruption. Products delivered to Gjensidige must meet our environmental requirements.

5.3    Healthy competition and sales 
The Group shall always act in accordance with relevant competition and marketing legislation. We must show due care in connection with work carried out under the auspices of industry associations, and where competitors are involved. Such work shall always be carried out in accordance with the remits and/or guidelines we have drawn up in advance. 

The Group must not engage in any form of sale or marketing that can be perceived as offensive or that comes into conflict with generally accepted social norms. We must always give advice in accordance with good business practice that is based on the customer’s needs, financial situation, and willingness to take risk, and the advice must serve the customer’s interests. We shall know the customer best and care the most.

5.4    Tax and official regulations
Gjensidige must follow the relevant tax legislation in the countries where the Group operates. Gjensidige must inform the tax authorities about any transactions and dispositions where Gjensidige considers the law to be unclear. The Group shall not support or facilitate tax avoidance by other parties.

All employees must familiarise themselves with the rules, laws and regulations that apply to their own area of responsibility and ensure that they are complied with. Employees must not recommend or initiate violation or evasion of applicable laws and regulations.

5.5    Corruption
Corruption means abusing one’s position to obtain improper personal or business advantages for oneself or others. Through its anti-corruption programme, the Group shall actively endeavour to prevent corruption. 

No one may accept benefits for themselves or others from the Group’s business connections if such benefits are a result of their employment relationship. Correspondingly, no one may offer such benefits to business connections. Examples of benefits are gifts, discounts, travel and rewards in connection with private purchases, loans etc. This does not apply to more trivial gifts (cf. section 6.6). Advantages that the Group has negotiated for all employees in a country or parts of a country where the Group operates are an exception from this rule.

Employees must not let their decisions or actions be influenced by undue pressure or offers of financial advantages from parties with an interest in the matter. Nor may they recommend or initiate violation or evasion of applicable laws or regulations relating to corruption and financial crime.

Employees must be familiar with the content of the Gjensidige leaflet ‘Do you know enough about corruption?’.

5.6    Money laundering and financing of terrorism 
Money laundering means converting the proceeds of criminal offences into apparently lawful revenues or capital gains. The Group must avoid any dealings with funds that stem from criminal activities. 

Financing of terrorism means to provide money or other assets for the purpose of financing acts of terrorism or the planning of such acts. 

Suspected money laundering or financing of terrorism must be reported to the anti-money laundering officer. 

6.1    Discrimination and bullying
All Gjensidige employees have a shared responsibility for building a team spirit and a good working environment. The Group expects employees to behave with respect and consideration and to display common courtesy in relation to colleagues, competitors, customers and others. By being inclusive and committed, we make each other better. Discrimination and harassment must not occur. Anyone who feels that they are being discriminated against or harassed shall be taken seriously. 

6.2    Relations with managers and colleagues
Gjensidige aims to create a diverse, positive, stimulating and enthusiastic working environment. Trust, respect, cooperation with and openness in relation to managers and colleagues are fundamental to achieving this goal. All Gjensidige’s employees have a responsibility for helping to create a good working environment.

6.3    Duty of secrecy
Employees have a duty of secrecy in relation to business matters and matters of a private nature relating to customers, employees and others that they become aware of in connection with the performance of their work for the Group. This duty applies unless they are legally obliged to disclose the information or are obliged or urged to report such matters pursuant to these ethical rules. The duty of secrecy does not only apply in relation to third parties, but also between the companies in the Group.

The duty of secrecy applies in relation to colleagues, advisers, family members and others, unless the party entitled to confidentiality has expressly consented to the disclosure. The CFO or a person authorised by the CFO may, in specific cases concerning financial matters, consent to the disclosure.

The duty of secrecy also applies after an employee has left their job with Gjensidige.
 
An employee shall not actively seek information about other employees or about customers via the computer systems or in any other manner, unless this is necessary for the employee’s work in Gjensidige.

The duty of secrecy equally applies when working from home. Extra caution is required from employees handling confidential information while working from other places than the primary workplace.

6.4    Relations with business connections    
No one may act in a way that prevents them from acting impartially in relation to the Group’s customers, suppliers, shareholders or other business connections. Employees must exercise caution when entering into private agreements and exchanging services with companies and persons with whom they have dealings through their work for the Group. They must also exercise caution in relation to business agreements with persons with whom they have a private relationship. 

Employees who have private relations with a business connection must notify and clarify this with their immediate superior. 

6.5    Hospitality and events
Employees who, by virtue of their position, represent or can be identified with the Group must conduct themselves in a way that ensures the trust of both the Group and other employees.

Events organised by the Group shall be characterised by moderation and have a relevant and adequate professional content. If alcohol is to be served at a Gjensidige event, non-alcoholic options must always be available. Any costs of travel and overnight stays for external parties shall be covered by those parties themselves (either directly or through a participation fee). 

Employees who are considering participating in trips or events under the auspices of Gjensidige’s business connections must clarify this with their immediate superior. Travel and stays in connection with the performance of work for Gjensidige shall, as a rule, be covered by the Group. Any deviation from this rule must be clarified with the employee’s immediate superior. This also applies to travel and accommodation in connection with seminars and other job-related events that are covered directly or as part of the participation fee. All employees shall comply with the national procedures for welfare measures, seminars, gifts and rewards for own employees, and for customer relations. The HR department is responsible for ensuring that updated procedures are in place and are available to employees.

Sponsor activities must be in accordance with Gjensidige’s sponsorship strategy.

Gjensidige has prohibited political donations, and full transparency is required about all payments that can be perceived as support for an organisation.

6.6    Gifts and benefits
Employees or their related parties may not accept/offer gifts or other benefits, including discounts or rewards in connection with private purchases, from/to customers, sponsors or suppliers, that can be related to the employee’s employment relationship in the Gjensidige Group. 

Benefits that the Group has negotiated for all employees are exempt from this main rule. Employees can also receive gifts of limited value from external parties on special occasions. These gifts must be registered in the gift and hospitality register and cannot exceed a value per donor of 600 in local currency (NOK/DKK/SEK) per year. If there is a risk that an employee’s impartiality or independence can be questioned, the gift must not be accepted. If gifts are returned, this shall be done in a manner that causes as little offence to the donor as possible.

An employee must not accept gifts or services of any kind in connection with or prior to entering into negotiations or as a return favour for entering into business agreements on behalf of Gjensidige.

Corresponding restrictions as mentioned above apply when gifts are given to business connections. Gjensidige’s motives and the integrity of the recipient must be beyond doubt.

6.7    Family relations
As a rule, related parties, such as siblings, parents/children or spouses/cohabitants/partners, shall not work under the same manager (line manager) or in the same department. Potential situations of this kind must be clarified in advance with the HR department. Related parties shall not obstruct, assess, approve, audit, check or in other way influence each other’s work.

6.8    Impartiality
No one may participate in or influence the handling of or decision in a matter where circumstances exist that could weaken trust in their independence. 

No one may consider, decide or seek to influence a matter if they themselves or any of their related parties have any direct or indirect financial or other personal interests in the matter. By related parties is meant spouses, partners, cohabitants and children, as well as any companies, associations, clubs etc. in which the employee or any of their related parties have a significant influence. Other personal relations may also by their nature be considered equivalent to related parties (for example neighbours, close friends etc.).

As a rule, if a superior is deemed to be disqualified on grounds of partiality, this also means that the matter cannot be decided by anyone reporting directly to them. 

Employees shall inform their immediate superior as soon as they become aware that a conflict of interest may arise. The superior shall consider the risk of the employee’s impartiality or ethical integrity being questioned by other employees or external parties. In such case, the employee in question must not participate in further consideration of the matter.

Employees must not use their position to influence appointments so that preference is given to a candidate on the basis of other criteria than those that are of direct relevance to the position in question.

6.9    Secondary jobs and offices and assignments for other companies and organisations
No employee may, without their employer’s written consent, work for, serve on the board of, operate or have financial interests in undertakings that engage in the same type of business as one of the Group’s companies or that have business relations with such companies.

An employee whose primary position is with the Group and who wishes to start a private business or take paid employment during their free time must clarify this with the employer in advance. If the secondary job/office can be combined with fully satisfactory work performance and the position in the Group, the employee may be granted permission for this. Managers must be informed about political offices, which are regulated by law, and arrangements must be made to minimise any inconvenience to the Group.

Employees must notify their immediate superior if they or any of their related parties have ownership interests in businesses with which Gjensidige has a customer or supplier relationship. If there is a risk that such ownership interest will give rise to doubt about the employee’s loyalty or independence, Gjensidige may demand that the ownership or customer relationship be terminated and set a deadline for its termination.

Unless express written permission has been obtained from the employee’s immediate superior, an employee in an executive position may not be a board member or member with other responsibilities in a company engaged in business activity. Other employees may hold offices outside Gjensidige. If an employee is in doubt about whether such an engagement will affect their work in the Group or is in conflict with the Group’s values, they must raise the matter with their immediate superior. In cases where the company’s employees refer to Gjensidige in the media, the Group expects a courteous and loyal attitude.

6.10    Insider information and security trading
Insider information is precise information that an investor is likely to use as the basis for investment decisions, and that could influence the price of the Gjensidige share upwards or downwards. No employee may use or contribute to others using insider information about the Group or other companies as a basis for trading in securities. This applies to both private trading and trading on behalf of the Group.

Private investments in securities must take place within a responsible financial framework, to avoid situations where the individual is exposed to strong financial pressure. Gjensidige’s interests shall always take precedence over employees’ personal interests, and such interests must be kept separate.

Employees must not, on their own behalf or on behalf of related parties, use insider information about possible securities trading by Gjensidige to trade in or give advice about buying or selling securities. Such information is confidential and will be considered a trade secret, and could also constitute insider information that triggers a statutory prohibition on trading and criminal liability. 

Any doubts concerning insider information and securities trading must be raised with the CFO or Head of Investor Relations in advance of any trading.

Board members are referred to the rules on impartiality and the duty of secrecy; see Sections 9-5 and 9-6 of the Financial Undertakings Act.

6.11    Use of the Group’s equipment and property
ICT equipment belonging to the Group shall primarily be used for its intended purpose. No one shall use the company’s data, IT equipment, material or other property for activities that are in conflict with Norwegian law, or that may be perceived as unethical and/or offensive. Each employee is responsible for all activities they carry out using their own user account and IT equipment.

6.12    Orderly personal finances and financial situation
Gjensidige expects employees to have their personal finances in order. Employees who take up positions that confer powers to commit Gjensidige financially must expect Gjensidige to check their creditworthiness.

The Group expects employees to ensure that their financial obligations to Gjensidige are kept in order, and this also applies to customer relationships with the Company.

If an employee is exposed to strong financial pressure, this can be construed as weakening the Group’s respect and independence. Employees who realise that they will be unable to meet their financial obligations must inform their immediate superior of this, unless the financial situation is of a temporary nature.

An employee must not register or change the terms and conditions of their own or related parties’ insurance contracts or other agreements. However, this does not prevent employees from using the same service channels as are open to other customers.

If an employee’s insurance claim or attempt to take out insurance is rejected on grounds of insurance fraud, this may have consequences for their employment relationship. The same applies if employees behave dishonestly as customers in any other of the Group’s business areas. As customers, employees must conduct themselves in the same way as other external customers in their communication with the company. Internal communication channels or undue pressure must not be used. 

Coverage of an employee’s personal expenses must be approved by their superior in accordance with authorisations.

Fringe benefits enjoyed by Gjensidige’s employees must not be exploited for other purposes than those forming the basis for the arrangement.

Participation in illegal gambling activities that entail financial risk is not compatible with Gjensidige’s activities. 

6.13    Human dignity
Employees on service assignments or business travel must not behave in a manner that could violate human dignity. This means, among other things, that employees must not purchase sexual services. 

6.14    Self-interest
Employees must not behave in a way that results in unjustified enrichment or advantages for themselves.

Employees who leave the Group may not take with them or copy the company’s knowledge base, customer lists, internal systems or other organised knowledge. Nor may they take with them rights or intellectual property that have been purchased or developed by employees or others for the Group. Immediate superiors are responsible for following this up.

6.15    Dependency
Dependency refers to employees having challenges or problems relating to, for example, alcohol, narcotic substances, abuse of medication, doping, pornography, compulsive shopping, computer games or gambling.
Employees are not permitted to use or be intoxicated by alcohol or euphoriant/stimulating substances during working hours. The immediate superior is responsible for raising the matter with the person concerned. 

Whistleblowing means to report censurable conditions in the workplace. There are several ways of reporting such matters, but you can always notify your immediate superior or via the channel for whistleblowing. You can also notify the HR partner, HR Director, employee representatives, safety delegates or the chair of the working environment committee. If you wish to be anonymous, however, you must use the channel for whistleblowing. 

Censurable conditions are matters that are in breach of

• laws and regulations (legal rules)
• written ethical guidelines in the company
• ethical standards widely accepted by society

Violations of the law and criminal offences are always deemed to constitute censurable conditions.

Gjensidige encourages employees to report censurable conditions to enable swift rectification. Such disclosure is important for the Group and for society at large. Employees who are willing to report are therefore an important resource for Gjensidige. 

In some cases, you are obliged to file a report, for example  

• when a co-worker is subjected to discrimination or harassment
• about matters that may entail a risk to life or health
• when the duty is set out in other law such as health legislation or the Money Laundering Act
• when the duty is set out in regulations, instructions or rules applicable to the duties or Gjensidige in general

All employees must familiarise themselves with and comply with the ethical rules, and assess their actions in relation to the rules. In cases of doubt, employees must contact their immediate superior or use the ethics mailbox. 

Managers at all levels have a particular responsibility for ensuring that their own and their subordinates’ conduct is in compliance with the regulations. Line managers are responsible for making the ethical rules known, and for ensuring that employees act in accordance with them.

HR has overall responsibility for administering the ethical rules, including following up the gift register and the ethics mailbox. HR must assist the management by taking steps to ensure that all employees are informed about what the ethical rules mean in their day-to-day work. Furthermore, HR shall notify relevant second and third-line functions of matters that are relevant to the performance of their duties, and any violations of ethical rules shall be reported in accordance with the instructions for registration and reporting of operational incidents. 

The consequences of violations of the Group’s ethical rules are shown in the matrix below.

Severity	Negligence	Serious  negligence/ several instances of negligence	Intentional /several instances of negligence
Breach of:  Internal rules and guidelines	Verbal warning	Written warning	Consider termination, dismissal or dismissal without further notice
Laws and statutory regulations	Written warning	Consider reporting to the police, dismissal or dismissal without further notice	Reporting to the police, dismissal or dismissal without further notice

(N.B. Throughout this document the third person plural (they, them, their) is also used to denote the gender specific third person singular (he, him, his and she, her, hers)).