Ethical guidelines for our employees

06.09.2007

CONTENT

1. About the guidelines
2. KLP’s business behaviour
3. Personal behaviour
4. Implementation and monitoring
5. Reporting

ETHICAL GUIDELINES FOR KLP

KLP runs a business that needs the confidence of customers, the authorities and society as a whole. With substantial responsibility for the welfare of members and as the manager of other people’s assets, KLP and its individual employees are subject to particularly stringent requirements in regard to professionalism, proficiency and ethical values. In no way is it to be possible to associate KLP with corruption, discrimination, abuse of power, unlawful business behaviour or other behaviour that contravenes good business practice. All employees are responsible for their own behaviour and are to act in accordance with KLP’s ethical values in every context in which they act on behalf of KLP. Also in other matters all employees are to behave in such a way that they do not damage KLP’s reputation. These high standards must be met through a conscious awareness of how we act and behave in relation to the world around us and the reaction to actions from those with whom KLP is interacting.

In these guidelines ‘KLP’ means all companies in the KLP Group: in other words Kommunal Landspensjonskasse and its subsidiaries.


1. ABOUT THE GUIDELINES

KLP’s ethical guidelines are to help employees and, as appropriate, members of directing and supervisory bodies in the context of the discharge of their duties in KLP, take an ethically responsible and proper stance in their daily work. The guidelines cover KLP’s business behaviour and the personal behaviour of KLP employees as well as internal matters.

The ethical guidelines are based on and complement relevant laws and regulations, official circulars and the industry’s ethical rules. Every individual employee must at all times comply with applicable legislation.

The guidelines are not exhaustive. Further guidance and rules may be found in special guidelines. See the intranet for an overview of these sets of rules.



2. KLP’s BUSINESS BEHAVIOUR

In all circumstances KLP’s employees are to adopt the same ethical behaviour in relation to KLP’s customers and business contacts as is expected of them in relation to KLP and KLP’s employees. Events for KLP’s customers and business contacts to be set up in such a way, both professionally and socially, that KLP’s ethical guidelines are reflected and KLP does not place individuals from customers and business contacts in a difficult ethical situation. Gifts given by KLP are to be of insignificant value. KLP’s motives and the recipient’s impartiality and integrity must not be drawn into doubt.

If KLP supports cultural or professional initiatives arranged by others, such support is not to be made conditional on links with KLP. Support is to be provided only if the event is in keeping with KLP’s ethical guidelines and guidelines for events for customers and business contacts.

KLP subjects all its financial investments to ethical filtering. Investments are not made in companies that contravene the principles of the UN Global Compact.



3. PERSONAL BEHAVIOUR

3.1 KLP’s general expectations of its employees
All employees are to behave loyally in regard to decisions made by KLP and to behave ethically properly in all circumstances. Employees are to endeavour to comply with KLP’s values: Open, Clear, Responsible, and Committed. All employees are to contribute to the best of their abilities to a good and inclusive working environment and to compliance in day-to-day working life with KLP’s values and ethical guidelines.

3.2 Duty of confidentiality
All have a duty of confidentiality about customers’, fellow employees’ and others’ personal or business matters knowledge of which they have acquired through their work for KLP. The duty of confidentiality also covers information on KLP’s business operation and matters of an internal and/or confidential nature.

The duty of confidentiality applies externally and in relation to colleagues who have no need for the information in connection with their work.

Individuals must not actively seek information about employees or customers when there is no need for such information in the individual’s work.

The duty of confidentiality does not prevent staff reporting reprehensible matters; see Paragraph 5 of this booklet.


3.3 Secondary employment and appointments in other companies/organisations
No KLP employees may hold directorships in other entities unless it is clear that the position cannot conflict with KLP’s interests. Employees’ directorships in other entities are to be approved by the Group Chief Executive Officer. The Group Chief Executive Officer’s directorships are to be approved by the Board of Directors.

KLP’s employees are not to have paid work or appointments outside their employment with KLP that may come into conflict with KLP’s interests or that are likely to undermine confidence in KLP or the employee. Employment or appointments that after careful consideration may have a particular financial significance for the employee or that may have an effect on the individual’s work for KLP are always to be approved by the Group Chief Executive Officer.

All are free to engage in democratic political work and voluntary organisations, provided this is done without reference to the individual’s relationship with KLP.

3.4 Use of KLP’s property
KLP’s property and assets are to be treated responsibly and are to be used only for the purpose for which they are intended.

The individual’s use of information, IT systems and internet services must be conducted on the basis of the individual’s work needs and not on the basis of their personal interests. Private use of equipment made available for the individual employee’s work is allowed, provided that private use is limited and is not at the expense of work use. Private use of storage capacity on KLP’s IT equipment is allowed, but only in processing ordinary information of limited size. Information that may be offensive or inappropriate is in no circumstances to be downloaded, stored or passed on.

3.5 Gifts and personal benefits
No one must accept gifts and/or personal benefits from KLP’s customers or business contacts: this includes travel, entertainment and agreements on discounts and supplies privately. This does not prevent employees or others being able to receive gifts of insignificant value, such as promotional material, flowers and similar, as well as making use of discounts introduced as a general scheme for KLP employees. Gifts are never to be accepted during a procurement or negotiation phase. Gifts received are to be looked on as gifts to KLP and should as far as possible benefit the unit/section collectively. Gifts and benefits with an estimated value of more than NOK 500 are to be reported to the recipient’s immediate manager, who is to decide whether the gift is to be retained or returned.

The costs of business travel are to be met by KLP unless otherwise agreed with the Group Chief Executive Officer. Invitations to participation in courses, seminars, company visits and similar are only to be accepted if the professional content legitimately justifies participation regardless of who is the host. Participation must not take the form of a gift/personal benefit or in some other way place in doubt the participant’s impartiality and independence. Acceptance of invitations is to be approved by the employee’s immediate superior. The costs of such events are to be met by KLP.

Care is to be shown in regard to private business agreements with companies and individuals with whom there is a business relationship through the individual’s work in KLP, even if the private business arrangements are entered into on market terms.

This clause also covers the employee’s closest family if the benefit is in the context of the employment in KLP.

3.6 Securities trading
KLP’s employees are not to trade in securities in conflict with KLP’s or customers’ interests. Rules for trade in securities and reporting obligations about this are to be found in the Private [tr. confirm terminology] Trading Regulations.

3.7 Impartiality
No one is to participate in processing or deciding a question when there are circumstances that may weaken confidence in the individual’s independence (impartiality). Nor may that person exercise influence on people who are to participate in processing or deciding the question. This includes deciding or exercising influence in a matter in which directly or indirectly the individual personally or their close relations have financial or other personal interests.

No one is to participate in events in which the participation may create doubt about the participant’s impartiality and independence.

No one may make decisions on investments on behalf of KLP in companies in which the individual concerned has a directorship.

If a superior is not impartial in a question, the question cannot be decided by an immediate subordinate either.

3.8 Participation in events
Employees participating in events on behalf of KLP are considered to be representing KLP throughout the whole event. In participation in events for and with KLP’s contacts, no one must behave in a way that may weaken KLP’s reputation or confidence in KLP employees.

OPEN
CLEAR
RESPONSIBLE
COMMITTED [tr. ‘engasjert’: noted that both ‘committed’ and ‘involved’ are used in KLP English documents on the website: ‘committed’ is stronger, more active perhaps (one can be involved unintentionally but commitment in this context comes from within - the criminal judgement/locking up madmen sense is different!): presume KLP will want to stick with one or the other]

4. IMPLEMENTATION AND MONITORING

4.1 KLP – creating the conditions for good ethical attitudes amongst employees
KLP is responsible for creating the conditions for good ethical attitudes amongst its employees. This is to be achieved through good ethical business behaviour by KLP, increasing awareness amongst employees, good ethical guidelines and advice and guidance in situations of doubt. KLP is to have an open and continuing debate about the ethical guidelines and good ethics generally.

The Director of HR is responsible for bringing the ethical guidelines to the attention of employees.

4.2 Individual responsibility
The individual employee is to be familiar with, and carry out their work in accordance with, the requirements in the ethical guidelines and relevant statutes and other guidelines. If there is doubt whether an act is ethically responsible and/or in accordance with the ethical guidelines, the act is to be avoided or to be discussed with an immediate superior. If the act is of such a nature that the employee would feel it uncomfortable if it were to become known amongst colleagues and others, there are grounds to refrain from the act.

4.3 Managers’ responsibility
Managers are to ensure that activity within their own area of responsibility is conducted in accordance with the requirements of the ethical guidelines and special guidelines. Managers are responsible for ensuring employees are familiar with the ethical guidelines and are to provide advice on their understanding and implementation.

4.4 Dealing with cases of doubt
Cases of doubt and breaches of the ethical guidelines are to be taken up immediately with one’s own manager. Managers receiving such an approach are to consult their own immediate superiors in cases of doubt.

Matters that individuals feel it difficult to take up with their own manager they may take up with the manager’s manager or the Group Legal Section, who can give advice about whom the employee may approach.

4.5 Consequences of contravention
Breach of KLP’s ethical guidelines or relevant statutory or other guidelines is considered a breach of the employment contract and may be subject to disciplinary measures. Depending on how serious it is a contravention may result in termination, summary dismissal and possibly a report to the relevant authority.


5 REPORTING

All employees are entitled to report reprehensible matters in the business.

Reprehensible matters include criminal matters, breach of other statutory rules, directions or prohibitions, breach of KLP’s ethical or ordinary ethical standards broadly supported in society. Bullying and harassment are also examples of reprehensible matters.

Reporting should normally be to the immediate manager. If this is inappropriate, reporting should be to the closest Group Director, HR Director or the Group Chief Executive Officer. If the person wishing to make the report is not comfortable about approaching any of these, the report may be to a safety representative to an elected staff representative.

If the employee does not consider it appropriate to report to anyone employed in KLP, the report may be to KLP’s Supervisory Board, the Norwegian Labour Inspection Authority or other public authorities.

The Norwegian Working Environment Act § 2-5 contains rules that provide protection for employees against retribution for reporting.