High Business Integrity standards are prerequisites for succeeding in delivering on Norfund’s mandate.
Corruption, money-laundering and other economic crime have wide-ranging negative effects on societies and are detrimental to reach the United Nation’s Sustainable Development Goals (SDGs). Norfund has a zero-tolerance approach to corruption and other forms of economic crime, and we are committed to promoting integrity, transparency and accountability in all our investments.
The framework that governs our work
Overall framework
Norfund has adopted a governance framework consisting of overarching policies adopted by our Board of Directors, relevant underlying guidelines and requirements approved by the management and detailed procedures and templates to help ensure compliance and consistency throughout the organization. The governance framework underwent a major overhaul in 2020 and implementation efforts continued throughout 2022. The governance framework is regularly reviewed to make sure it is up to date and relevant. In 2022, we introduced an HR Policy, updated both our Code of Conduct and our Compliance System and made numerous updates and additions to our underlying steering documents.
Business Integrity framework
The management of Business Integrity risks is an integral part of Norfund’s investment process. We require the companies we invest in, our business partners and our employees to promote and adhere to high standards, including:
- Norfund Code of Conduct
- Norfund Supplier Code of Conduct
- Norfund Compliance System
- Norfund Business Integrity Policy
- Norfund Responsible Tax Policy
- Gift and Hospitality Guidelines
- Whistleblowing and reporting procedures
Risk-based approach
The Business Integrity framework describes how we work to identify, assess and manage the Business Integrity risks associated with the operations of our investments, and provides an overview of the cross-cutting principles that guide our work. To further enhance this framework, a risk assessment of our investment portfolio was conducted in 2022. In addition to outlining the Business Integrity risks that Norfund is exposed to, the assessment includes a review of existing mitigating measures and suggested additional measures. The assessment has provided a valuable external benchmarking and will help strengthen Norfund’s Business Integrity processes and procedures going forward.
Dedicated resources
To further raise awareness and secure harmonized practices between all offices, one Business Integrity Ambassador has been appointed for each of Norfund’s regional offices. The Ambassadors work closely together with the Compliance & Legal Counsel and participate in a joint Business Integrity Ambassador network.
Business Integrity Week
Norfund held its second, annual Business Integrity Week in November 2022. The topic of the event was anti-corruption, which is one of Norfund’s four cross-cutting issues. The purpose of the event is to spread awareness and provide training in important Business Integrity practices to the whole organization and continue to build a strong Compliance culture in Norfund.
Whistleblowing and reports
Norfund encourages the reporting of any suspected breach of its governance framework or applicable laws or regulations in connection with or related to its investments or activities. Norfund staff can report suspected violations to internal functions, and such reporting is also encouraged via Norfund’s external whistleblowing channel. The whistleblowing channel caters for anonymous reporting of illegal, unethical or other unacceptable circumstances within Norfund and our investments. The whistleblowing channel is also open to Norfund representatives, business partners and other stakeholders, and reviewing and following up on Business Integrity incidents has a high priority in Norfund.