Owner/approver: CEO Lerøy Seafood Group
Valid from: 2023-07-05
Purpose
The purpose of Lerøy’s anti-corruption and anti-money laundering policy is to outline clear expectations and requirements related to compliance with relevant prohibitions against corruption, money laundering and terror financing.
The policy provides a concise and principle description of how Lerøy works to promote an ethical business culture by conducting all business activities with integrity and in an open and transparent manner.
Lerøy is obliged to conducting its business in accordance with the applicable laws and regulations of the countries in which it operates. In addition, we are obliged to act in accordance with the standards and principles of business conduct and ethics as stated in Lerøy’s Code of Conduct, this policy, as well as internationally recognised anti-corruption, anti-money laundering and anti-terror financing conventions and guidelines.
Lerøy has zero tolerance for corruption in any form in both the public or private sector, including bribes, influence peddling and facilitation payments, regardless of whether this takes place directly or through a third party and whether it takes place actively or passively. Lerøy also has zero tolerance for money laundering and terror financing.
Lerøy makes an active effort to prevent activities that facilitate corruption, money laundering and terror financing, and has established secure processes to prevent, identify and manage any risks in the respective areas, including ensuring that the organisation is not misused for money laundering or terror financing purposes. These processes are described in more detail in Lerøy’s underlying procedures.
Lerøy provides training and guidance to its own employees and hired staff with regard to Lerøy’s Code of Conduct, as well as customised anti-corruption and anti-money laundering training for relevant positions. A differentiated and up-to-date training programme ensures that Lerøy’s own employees and hired staff are able to recognise conditions that can represent a risk of corruption, money laundering and terror financing.
A suspected violation of corruption, money laundering and terror financing rules must be reported immediately to the immediate supervisor and LSG Compliance Officer. A suspected violation can also be reported through an internal or external whistleblowing channel, either openly or anonymously.
General guidelines
The following guidelines provide the foundation for how Lerøy addresses anti-corruption and anti-money laundering:
Comply with this policy and other internal anti-corruption and anti-money laundering procedures/guidelines.
Do not participate in or approve corrupt or unethical business activities.
Exercise due care when making decisions and never compromise ethics in connection with business activities.
Undergo relevant training.
If you are uncertain or have any questions about the contents of this policy or Code of Conduct, seek guidance from Lerøy management.
Valid for
The policy applies to Lerøy Seafood Group ASA and its subsidiaries (Lerøy), including all employees and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way. Lerøy’s business partners are required to comply with the Supplier Code of Conduct.
Definitions
Corruption is the abuse of entrusted power for personal gain. The notion of corruption in criminal law encompasses bribing or accepting bribes in the form of money, gifts or services. Corruption is not an unambiguous concept and in the broadest sense, also includes influencing others to carry out their work in a specific way, referred to as influence peddling.
Money laundering pertains to everything related to profiting from criminal activities, including what is referred to in Norwegian criminal law as ‘heleri’, which means receiving the proceeds of crime. This encompasses both providing assistance to secure the proceeds of a criminal act for another person and concealing or disguising the proceeds of a criminal act that has been carried out personally. It also includes receiving or acquiring a share of the proceeds of a criminal act personally or on behalf of others. In other words, money laundering means contributing in some way to securing the proceeds of criminal acts by concealing where these proceeds has been transferred or who has control over them, or concealing income, other assets or the illegal origin of assets.
Terror financing is the financing of acts of terror, terror organisations or individual terrorists
Framework and principles
The provisions of the Norwegian Penal Code (LOV-2005-05-20-28) concerning the handling of the proceeds of crime, money laundering, acts of terror or terror-related activities, as well as corruption and influence peddling, are particularly relevant for Lerøy. Corruption legislation, money laundering legislation and terror financing legislation in other countries in which Lerøy operates also apply.
Roles and responsibilities
All employees of Lerøy and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way, are required to comply with this policy.
The Group management of Lerøy Seafood Group ASA and local management at all subsidiaries are responsible for ensuring that the company has staff with the skills required to ensure compliance with local anti-corruption regulations, anti-money laundering regulations, and anti-terror financing regulations.
Ownership and implementation
The CEO is the owner of the policy and responsible for all updates.
The policy has been approved by Corporate Management Group, presented to the Audit Committee and approved by the Board of Directors.
The CEO of Lerøy Seafood Group ASA has overall responsibility for the policy.