Anti-corruption policy

Owner/approver: CEO Lerøy Seafood Group

Valid from: 2022-04-01

Purpose

This policy provides a brief and principal description of how Lerøy promotes ethical business culture by working transparently, with integrity and always lawfully wherever we operate and with everyone we do business with.

We are committed to conduct our business with integrity and in accordance with the standards and principles for business conduct and ethics outlined in our Business Code of Conduct,  this policy, applicable laws, rules and regulations, as well as internationally accepted guidelines, conventions or similar initiatives relating to anti-corruption, money laundering, fraud, slavery, environment, human rights, or similar activities. 

Lerøy has zero tolerance for corruption. The company opposes corruption in all forms – direct as well as indirect, active as well as passive, and in both private and public sector. Implementing anti-corruption measures is an integral part of our corporate responsibility protecting our reputation and the interests of our stakeholders. Business relations that are unwilling, or unable to comply with our Business Code of Conduct or this policy shall be terminated.

Lerøy shall provide training and guidance to its employees and workers regarding its Business Code of Conduct which communicates the baseline expectations regarding business conduct as well as ensuring that the employees and workers receive advice on how to handle ethical dilemmas which they might encounter in their work.

Concerns regarding corruption can be reported via independent internal or external reporting channel. Reporting can also be performed anonymously.

Principles for anti-corruption:

Never conceal corrupt or potentially corrupt activity;

Avoid activities that may facilitate any form for corruption;

Stay clear of fraudulent or dishonest activity;

Never accept or offer something that can be perceived as bribery or kickback.

In case of uncertainty regarding the content of this policy or the Business Code of Conduct employees and workers shall seek guidance. The first step should always be consulting the Business Code of Conduct or this policy. If the situation still remains unclear, seek advice from the management.

VALID FOR

This policy applies to all employees and workers in the Group. Contracts with business partners operating in relation with Lerøy shall include requirements for compliance with the contents of this policy.

DEFINITIONS

Corruption – abuse of entrusted power for private gain. Corruption erodes trust, weakens democracy and hampers economic development.

Employee - an individual who is in an employment relationship with the organization, according to national law or its application. Employees have a written employment contract directly with the organization.

Worker – an individual who performs work for a certain period of time (for example, seasonal workers etc.) and who is hired via manning agency. Workers have a written employment contract with manning agency.

FRAMEWORK AND PRINCIPLES

Lerøy is committed to complying with prevailing anti-corruption regulations, guidelines and principles, defined in the following documents:

ROLES AND RESPONSIBILITIES

• All employees and workers at Lerøy are responsible for complying with this policy and for contributing towards transparent and ethical business conduct.
• The top management in Lerøy Seafood Group and local management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local anti-corruption regulations.

POLICY OWNERSHIP AND IMPLEMENTATION

• CHRO Lerøy Seafood Group is the owner of this document, and is responsible for updates.
• The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
• The CEO of Lerøy Seafood Group has overall responsibility for the policy.