Ethical principles

The values, principles, and perceptions of reality that everyone in Eksportfinansiering Norge (hereinafter Eksfin) shares form the culture that we are part of. Eksfin’s ethical principles are an important part of our business and define the ethical standards for how we all work and act as responsible and good representatives of Eksfin.

The ethical principles should guide us in our day-to-day dilemmas and are the basis for how we behave and protect Eksfin’s integrity. Furthermore, the ethical principles shall form the basis and framework for more detailed guidelines and procedures established by Eksfin’s management. Eksfin’s board approves Eksfin’s ethical principles.

Eksfin issues loans and guarantees, and it manages major assets on behalf of the Norwegian state as owner and principal, and it is thus endowed with both authority and trust. It is important to protect Eksfin’s reputation and to contribute to the agency having a high level of ethical awareness and integrity.

Ethics are more than just mandates and prohibitions enshrined in law, regulations, rules, and principles. Ethics are also attitudes and the choices we make. It is neither possible nor desirable to regulate every conceivable issue that arises.  The aim is for these ethical principles to form the basis for dealing with various issues that arise in connection with work by and for Eksfin.

In addition to our personal behaviour within Eksfin and in the outside world, we will face ethical decisions in our business operations. The choices we make as individuals help to shape how society around us perceives Eksfin’s ethical standards.

Scope and responsibilities

Eksfin’s ethical principles apply to all employees in the agency, including temporary employees, hired-in personnel, board members, and others who perform work for Eksfin or act on its behalf.

Managers at all levels have a special responsibility to exercise good ethical judgement and must ensure that all employees have access to and knowledge of the ethical guidelines that apply to the organisation. The individual is responsible for familiarising themselves with and following the guidelines. Each year, all employees must confirm that they have read Eksfin’s ethical principles.

Eksfin’s employees must help to uphold trust in Eksfin and its reputation by maintaining a high ethical standard, acting with social responsibility, and complying with applicable laws and regulations. In case of doubt, or where the ethical principles do not provide sufficient guidance, a senior manager must be consulted. We have an obligation to carry out our tasks and comply with the orders of our superiors, as well as to act loyally towards Eksfin, both inside and outside of our work. Eksfin’s employees have an independent responsibility to help ensure that Eksfin’s reputation is upheld. This requires employees to act in an ethically sound manner and to refrain from engaging in illegal acts or otherwise acting negligently in a way that may undermine Eksfin’s reputation.

Purpose, vision, and values

Eksfin’s purpose is to promote Norwegian exports that generate value and investments abroad by issuing loans and guarantees on behalf of the Norwegian state in a responsible and sustainable manner. What we offer must be competitive, accessible, and effective.

Eksfin’s vision “From the whole of Norway to the whole world” is an expression of what we want Eksfin to be and is the starting point for: 

  • the goals we set ourselves,
  • the paths we choose to take,
  • our actions, and
  • the results we achieve.

Eksfin’s values are: competent, dynamic, enthusiastic, and transparent. These values should steer Eksfin’s culture and guide us in the ethical issues we face internally and externally, as well as motivate us to put in effort and perform at our best. Eksfin’s employees must be:

Competent

Our work is based on a high level of professional expertise and must be characterised by high quality. Eksfin’s employees must be competent and up to date. We will act with sincerity and responsibility towards our customers, colleagues, and partners. We will have good expertise and know our field. We will fulfil our role without losing sight of the whole and not be afraid to make decisions. We will always act honestly and credibly and create trust and security through our actions. This means that we must act professionally and reliably and treat all our colleagues with respect, fairness, and consideration.

Dynamic

We will develop in line with market changes. We will work to develop systems, guidelines, and skills that facilitate Eksfin’s development. As a value, dynamism will help us to be vigilant towards development and changes in economic, financial, technological, and regulatory framework conditions, as well as be solution-oriented in our day-to-day work.

Enthusiastic

Working at Eksfin should be meaningful and enjoyable. We will support each other and learn to develop as people. We will be committed to the agency, our customers, and exporters in order to enable us to do our work with positivity and contribute to an engaging work environment. We will be proactive, attentive, and available to our customers and those around us. We will listen to each other and treat people with respect.

Transparent

By being transparent, exporters, customers, and partners perceive us as being dependable and reliable.

Ethical principles in Eksfin

Eksfin’s employees

  • shall perform their tasks to the best of their ability in line with Eksfin’s instructions, policies, and guidelines and in accordance with the agency’s goals and interests,
  • are responsible for familiarising themselves and complying with relevant legislation and other internal and external regulations,
  • shall strive to uphold a high ethical standard in conducting their work,
  • shall constantly strive to do their work in line with the key principles of integrity, impartiality, discretion, and accountability, and
  • are expected to be loyal to Eksfin and its values and goals. Any form of deliberate and disloyal act, for the benefit of oneself or others, is regarded as misconduct and may be punishable with appropriate sanctions.
Conflicts of interest and impartiality

Conflicts of interest arise when a party has professional obligations or personal or financial interests that could affect their objectivity. Conflicts of interest may exist even if there is no partiality under the Norwegian Public Administration Act.

§ 6 of the Norwegian Public Administration Act regarding partiality applies to Eksfin’s employees. A public official is partial in the preparation of a basis for a decision or in making a decision in an administrative case when they or their family are a party in the case, when they represent a party in the case, or when they are a manager of, hold a senior position in, or are a member of the board or corporate assembly of a company that is a party in the case, unless it is wholly publicly owned. 

A public official is also partial when there are other particular circumstances that weaken confidence in their impartiality. Here, emphasis shall be placed on, for example, whether a decision on a case would entail a particular advantage, loss, or inconvenience for the official themselves or someone with whom they have a close personal connection. 

Eksfin’s employees:

– shall be impartial in all business activities and not give other companies, organisations, or individuals an undue advantage or disadvantage, 

– shall not be involved in relationships that could result in an actual or perceived conflict of interest with Eksfin’s interests or be detrimental to the general trust in Eksfin, or that may in any way have a negative impact on the official’s freedom of action or judgement,

– shall avoid situations where an actual or perceived conflict of interest may arise between their own personal and/or financial interests and Eksfin’s interests. Employees may never try to obtain benefits for themselves that are inappropriate or likely to harm Eksfin’s interests in any way.

– shall not participate in decisions where there is a personal interest in the case. This applies not only if the employee has a personal interest, whether financial or otherwise, in the case, but also where this is true of someone with whom they have a close relationship, such as a relative.

– shall not use their position to influence assessments in employment cases that could give rise to favouritism or other unreasonable discrimination,

– shall not work with or process cases where there are other circumstances that could undermine confidence in the employee’s own impartiality or the integrity of the work performed.

External engagements (other occupations/side assignments) include positions, roles, tasks, assignments, and memberships in or for other companies. External engagements that may conflict with Eksfin’s interests must be approved in advance by a senior manager. The CEO is to obtain consent from the board. External engagements that Eksfin’s employees undertake must not affect their ability to perform their role for Eksfin and must not be in conflict with Eksfin’s activities or interests. Please see the procedure for other occupations/side assignments.

Gifts and other benefits

The main rule is that employees should avoid accepting or offering gifts and other benefits, as this may mean that questions are raised with regard to the parties’ independence and integrity. Gifts or other favours to or from Ekfin’s customers or business associates must be in accordance with locally accepted good business practice and may be given or received only if they are modest in value. As a guide, gifts of less than NOK 500 are considered to be of modest value. However, a concrete assessment must always be made as to whether the gift or other type of benefit can be perceived as affecting the integrity and independence of the recipient, giver, or oneself. Monetary gifts must never be given or received. If an employee receives a gift or other type of benefit that conflicts or could conflict with Eksfin’s ethical principles, a superior manager or the compliance function must be informed immediately. Please see the procedure for representation (gifts and hospitality).

Representation assignments

Eksfin may cover representation costs and employees can always participate in representation assignments such as meals, social events, and entertainment provided that this has a clear business or professional anchoring in the agency and that the assignment can be deemed reasonable. Travel and accommodation in connection with this type of representation shall always be paid for by Eksfin. The purpose of covering these costs must never unjustly influence or appear to influence the recipient. Costs associated with a spouse’s or cohabitant’s participation in representation assignments are not covered. Such costs must be covered privately. Please see the procedure for representation (gifts and hospitality).

Business trips

There are separate guidelines for business trips in Eksfin, which are outlined in the section “Travel” in the Staff Handbook.. The procedure for booking a business trip must be seen in the context of these guidelines and of the state’s travel regulations. Please see the guidelines for business trips.

Duty of confidentiality and handling of information

Every employee, and anyone else who provides a service or does work for Eksfin, has a duty of confidentiality in respect of the information that they become aware of in connection with their service or work in respect of Eksfin’s business, employees, business associates, and/or partners.

We will not pass on confidential information to anyone who does not have a material interest in the case, and our business partners should feel confident that Eksfin complies with the rules on confidentiality in the Norwegian Public Administration Act. The duty of confidentiality also applies internally, i.e. in respect of colleagues to the extent that others do not need the information in connection with the performance of their work. The duty of confidentiality shall not prevent employees from informing their superiors of matters that are deemed to conflict with applicable laws and regulations.

All legal and regulatory provisions regarding confidentiality and privacy must be adhered to. It is the individual’s responsibility to ensure that sensitive information is stored in an appropriate manner. The duty of confidentiality also applies after the employment, service, assignment, or position of the person in question has ended. The duty of confidentiality is regulated in the contract of employment and declaration of confidentiality. Information may not be used for one’s own business or in service or work for others.

Personal data

Personal data concerning employees in the agency, including temporary employees, hired-in staff, board members, and others working for Eksfin or acting on Eksfin’s behalf, in addition to customers, partners, consultants, or others, must be handled in accordance with fundamental privacy considerations and in line with current regulations and internal objectives regarding the handling of personal data so that privacy, confidentiality, and sufficient quality of personal data are all taken into consideration. The procedure for handling personal data in Eksfin provides more detailed rules for this. Please see the guidelines for the handling of personal data.

Protection of information and property

All employees must ensure that confidential or sensitive information about customers or Eksfin’s internal affairs is protected by way of proper storage and that written and electronic data is stored securely. The securing of information, archives, and assets belonging to Eksfin and Eksfin’s customers and other business associates is everyone’s responsibility.

Eksfin provides resources and systems to be used to conduct the agency’s day-to-day work. These include materials, technology, procedures, and systems. Eksfin’s employees must protect Eksfin’s property and assets against loss, damage, and misuse. Information produced and stored on Eksfin’s IT systems is, in principle, considered to be Eksfin’s property. Eksfin’s employees are responsible for taking proper care of electronic files and archives.

Private use is permitted only for the handling of ordinary information to a limited extent. Information that may be considered illegal or offensive or which could pose a threat to Eksfin’s systems must not be handled, downloaded, stored, or disseminated under any circumstances. Please see the data discipline instructions.

Inside information

Inside information is data that is not publicly available or generally known in the market that could be used to substantially influence the price of financial instruments. Inside information must be handled with special care, and the number of people who receive inside information must be as limited as possible. The procedure for handling inside information in Eksfin provides more detailed rules on how employees and others should act when receiving inside information. Please see the compliance policy.

Securities trading

Securities must not be traded if this is incompatible with the interests that the employee and board members must safeguard in their work for Eksfin or Eksfin’s business associates, or where such trading may damage public trust in Eksfin. All employees must register their ownership of securities when they start their employment. Employees are responsible for ensuring that the information recorded is up to date at all times. The procedure for employees’ trading in securities describes, among other things, the procedure for reporting own trading. Eksfin shall have a separate procedure for board members. Please see the compliance policy.

Transparency

Eksfin’s employees have a duty to comply with the principles regarding transparency in their work, while also complying with confidentiality requirements. The public has a right of access to Eksfin’s charges log so as to gain insight into the state’s activities. Documents in Eksfin’s loan and guarantee cases are, however, exempt from public access in accordance with § 9, new sixth paragraph of the Norwegian Freedom of Information Regulations. When access is requested to documents that can be legally exempted from public access, it must nevertheless always be considered whether the document can be made public in whole or in part if the information is not subject to a duty of confidentiality.

Eksfin has a duty to disclose information, and Eksfin’s employees must always provide correct and sufficient information, whether this is to other authorities, companies, organisations, or citizens. The most important legal provisions here are the rules on the public’s right of access and open government pursuant to the Norwegian Freedom of Information Act.

Transparency is also a basic prerequisite for internal collaboration within Eksfin and for Eksfin’s reputation. Eksfin’s employees must always provide correct and complete information to their political and administrative superiors.

The CEO, or the person they appoint, is in charge of all contact with the media.

Whistleblowing

Eksfin wants to encourage open and improvement-oriented dialogue on responsible behaviour. Eksfin’s employees must immediately report any criticisable situations, situations that involve questionable ethics, or situations that breach Eksfin’s ethical principles. Attempts should be made to address the situation internally before blowing the whistle. Employees must be able to blow the whistle anonymously via an external party. Employees and third parties that report possible violations in good faith shall be protected from sanctions. Please see the whistleblowing procedure.

Equal treatment

Eksfin’s employees must always act in accordance with laws and good business ethics and ensure an adequate standard in the handling of cases, and must not discriminate between suppliers and business partners by taking extraneous or arbitrary considerations into account. Compliance with current legislation for public procurement and sales is important for ensuring good business practice. Please see the procurement procedure.

Internal interaction and conduct

Eksfin expects all employees to contribute to and uphold good internal co-operation at Eksfin. Eksfin encourages all employees to have open dialogue with their colleagues and ask for help when necessary.

Eksfin shall work actively to promote equality and offer equal opportunities and rights for all. The agency must have a dynamic, attractive, and innovative corporate culture that transcends demographic, ethnic, and individual differences. All employees must respect other people’s dignity, privacy, and rights. Eksfin’s employees shall not contribute to, practise, or experience negative discrimination on the basis of personal circumstances, age, gender, or cultural, religious, or geographical background It is further emphasised that no form of psychological, sexual, or other harassment is tolerated.

Our ethical principles in the transactions we are involved in

Eksfin manages public funds and, through its financing activities, will contribute to the promotion of sustainable solutions. Economic, social, and environmental assessments form the basis of our activities. Eksfin shall not finance transactions that pose an unacceptable risk of our contributing to illegal and unethical acts/omissions, violations of fundamental human rights, unacceptable HSE conditions or working conditions, environmental damage, corruption, money laundering, or other financial irregularities

Ethics, the environment, social conditions (in relation to both workers and local communities), and anti-corruption shall be key assessment criteria in all transactions that Eksfin is involved in. Eksfin’s employees shall promote good ethical attitudes, environmental and social responsibility, and good anti-corruption measures among our guarantee recipients, borrowers, exporters, suppliers, and other partners.

Eksfin shall apply the following principles in all the transactions it is involved in:

Anti-corruption

Eksfin has zero tolerance for corruption and aims to prevent corruption in connection with the contracts that it finances. The fight against all forms of corruption is actively supported and Eksfin is committed to working ethically, legally, and professionally. Employees must work actively to mitigate and prevent corruption and fraud. We shall not offer, provide, accept, or receive, directly or indirectly, bribes or other unfair advantages for commercial or private gain, either for ourselves or others. Employees must also not use their position to gain an unjustified advantage for themselves or others. This also applies in cases where these benefits will not affect their actions while in service. Please see the policy for efforts to prevent money laundering and the financing of terrorism, anti-corruption, and sanctions.
Reference is also made to the Norwegian Penal Code, which contains the most pertinent provisions on corruption (cf. §§ 387-389). The OECD Council Recommendation on Bribery and Officially Supported Export Credits also serves as a basis for Eksfin’s efforts to prevent corruption. The UK Bribery Act and the US Foreign Corrupt Practices Act (FCPA) contain provisions that can be enforced internationally.

The environment and social conditions

Eksfin wants to contribute to long-term sustainable development and aims for all transactions to take due account of the environment and social conditions. Employees must work actively to ensure a high level of responsibility related to the environment and social conditions in the transactions that are financed. This shall be based on national and local legislation and also on recognised international guidelines, including OECD guidelines for risk assessment in relation to the environment and social conditions, Common Approaches , Equator Principles , UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises. Please see the sustainability policy.

Tax transparency

A lack of tax transparency entails an increased risk of corruption, money laundering, and other financial crime. Eksfin shall work to ensure transparency with regard to the parties in the transaction, the parties’ ownership structure, and the transaction itself. In assessing transactions involving so-called tax havens, Eksfin shall refer to OECD and Global Forum reviews of states’ transparency and efficient exchange of information in tax matters. Please see the compliance policy.

Prevention of money laundering and the financing of terrorism

Although Eksfin does not tolerate money laundering, it is not subject to regulations on money laundering and the financing of terrorism. Eksfin shall nevertheless carry out risk-based customer checks and record customer information in line with such regulations as far as is practicable. Please see the policy for efforts to prevent money laundering and the financing of terrorism, anti-corruption, and sanctions.

Sanctions and other international restrictions

It must be ensured that the financing Eksfin participates in does not contravene Norwegian sanctions legislation. Furthermore, it must be ensured that Eksfin does not contribute to the violation of sanctions or act contrary to international sanctions in such a way that entails a risk of punishment or listing, a risk to its reputation, or operational risk.  Please see the policy for efforts to prevent money laundering and the financing of terrorism, anti-corruption, and sanctions.

Implementation and follow-up

Eksfin’s employees must ensure that they are familiar with, and perform their duties in accordance with, the requirements set forth in these ethical principles and associated regulations, as well as with applicable laws and regulations.

If an employee finds or observes conditions with questionable ethics, including conflicts of interest, the employee must immediately notify and consult with their human resources manager, legal director, or the compliance function. In situations where there is a conflict of interest, the person in question must terminate their assignment immediately. Managers are responsible for communicating requirements and providing advice in the interpretation and application of the ethical principles.

Violation of these ethical principles or relevant legal provisions may result in a verbal or written warning and will have consequences in relation to the violation. In the event of a significant breach, the CEO must be informed. Serious cases or repeated breaches may have an impact on the employment relationship.

Compliance and reporting

Each year, all employees must confirm that they have read and understood Eksfin’s ethical principles.

Eksfin’s ethical principles shall be reviewed and, if necessary, updated annually and otherwise as necessary.

The document must be approved by the board each year or in connection with material changes. The document is owned by the board of Eksfin. The CEO is responsible for presenting the document for approval.

[1]Definition of  “relative”: Under §§ 1-5 of the Norwegian Companies Act, “relative” means: 1. spouse or person with whom the person in question lives in a marriage-like (48) relationship; 2. relatives in a straight ascending or descending line and siblings; 3. relatives in a straight ascending or descending line and siblings of a person referred to in no. 1; 4. spouse of, or person who lives in a marriage-like relationship with, someone referred to in no. 2; 5. a partnership where the person in question or someone referred to in nos. 1 to 4 has a decisive influence as mentioned in §§ 1-3.

[2] Definition of  “unfair advantage”: Such an advantage normally relates to money, discounts, or items of financial value, but may also include services without a financial value. Whether an advantage is unfair or not will depend on an overall assessment covering several factors such as the purpose of the benefit, the nature and value of the benefit, the degree of transparency that exists, the set of rules that exist in the company or industry, and the position of the giver and recipient.

[3] OECD’s The Common Approaches for Officially Supported Export Credits and Environmental and Social Due Diligence

[4] Equator Principles