Public Officials
We follow high ethical standards when interacting with public officials.
What we need to know
Public officials include all individuals employed by or acting on behalf of a government including anyone holding a legislative, administrative, executive or military office
Public officials execute governance functions that are vital to the societies in which we operate and are also vital to our license to operate there
Telenor interacts with Public officials at various levels and for many different purposes
Information shared with public officials may become public due to laws regulating public access to government-held information
Individuals employed by state-owned companies may be considered public officials
What is expected of all of us
We do not engage in conduct which could, or could be perceived to, improperly influence a public official
We exercise appropriate caution toward public officials when Telenor is engaging in a commercial or approval process
We are always compliant with local laws or rules that apply to public officials
We do not offer gifts to public officials except promotional items of minimal value, and only when it would be customary to do so
We do not pay travel, accommodation or related expenses for public officials
We offer only modest hospitality to public officials and only when there is a clear and legitimate business purpose, the costs are reasonable, and the context is open and transparent
We always discuss offering business courtesies to public officials with our manager and seek guidance from the Compliance Function as needed
We do not make facilitation payments to public officials and we report requests for such payments to the Compliance Function
We only use lobbyists to advocate on our behalf in special circumstances with full transparency and with prior written approval by the Business Unit CEO
We ensure the third party towards whom any lobbying activity is being conducted is aware of our relationship with the lobbyist. In the event a lobbyist is used, it shall be promptly disclosed to the third party the lobbyist represents Telenor. The obligation shall be included in the agreement with the lobbyist
We do not engage in external discussions with public officials on behalf of Telenor unless we have been previously authorised to do so
What to look out for
If a business partner directly or indirectly interacts with public officials on our behalf
If a public official asks for the personal data of Telenor employees, customers or any other individual
If a public official requests Telenor to send information or messages to our subscribers
If a public official owns, manages or is affiliated with a business partner
If a public official, or a close family member or business associate of the public official, applies for a position within Telenor