Anti-corruption
Checklist for the Board and Company
- Embedded in risk management and corporate culture.
- Procedures for training, prevention, and incident handling.
- Competence and insight into the risk landscape, and zero tolerance.
- Adequate resources and well-functioning systems.
- Regular testing of the effectiveness of the anti-corruption program.
Corruption includes activities such as money laundering, embezzlement, fraud, competition crimes, tax evasion, accounting manipulation, insider trading, and other forms of financial misconduct. Such practices undermine trust between parties, distort markets and fair competition, and weaken long-term value creation. Corruption can expose companies to significant financial, legal, and reputational losses, and represents a material financial risk.
Folketrygdfondet’s expectations for companies’ anti-corruption efforts are based on the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the Extractive Industries Transparency Initiative (EITI).
• Companies have an independent responsibility to prevent, detect, and address corruption. The board must ensure that the company has appropriate systems and measures in place to manage this risk.
• Companies should assess corruption risk across business areas, markets, and partners. The board must ensure that it has the competence and insight needed to understand the company’s overall risk profile.
• Companies must dedicate sufficient resources to anti-corruption work, and maintain effective systems for whistleblowing, background checks, and follow-up of business partners and ownership interests.
• We expect the board to demonstrate clear zero-tolerance for corruption, and to ensure that breaches of internal procedures are addressed immediately. Anti-corruption guidelines should be well understood internally and clearly communicated externally.
• Companies should provide thorough training for employees, especially in roles exposed to higher corruption risk.
• The anti-corruption program should be reviewed regularly to ensure that they work in practice, are further developed, and are adapted to changes in the risk landscape and new legal requirements.
• We expect companies to report openly on their anti-corruption work, including key risk areas, whistleblowing activity (broken down by topic or geography), how the work is organised, and planned improvement measures.