Telenor Ethics and Anti-Corruption Programme

These standards are set out in our Code of Conduct, the Group Policy on Anti-Corruption, Group Policy on Third Party Risk, and other guidance and governing documents. These standards are implemented in all subsidiaries directly or indirectly controlled by Telenor ASA, and where we are not a controlling owner we require these companies to comply with an ethical standard which is in line with Telenor’s own, and to operate within a risk based governance and compliance framework.

The Anti-Corruption Programme is part of Telenor’s Governance model which clearly defines roles and responsibility for the implementation of Telenor’s Anti- Corruption Compliance Programme and the integration of ethics and anticorruption considerations into all business activities. Our global network of Heads of Compliance, consisting of business unit policy managers or experts appointed by local policy owners, contributes to best practice-sharing across the Group.

Status and ambition

Telenor seeks to work with partners who share our commitment to ethics and compliance. In 2018, we prioritized strengthening our processes to do background checking and monitor business partners including suppliers and vendors. Telenor’s integrity due diligence process enables us to identify and mitigate compliance risks related not only to anti-corruption, but other important compliance areas. In 2019 we will focus on the implementation of a Group wide third party vetting and monitoring process through a specially designed digital platform. We will not make gifts, donations or otherwise support political parties or individual politicians.

A description of Telenor’s Anti-Corruption Programme and the Ethics and Compliance function is publicly available on Corporate Governance and Anti-Corruption.