High business integrity standards are prerequisites for successfully delivering on Norfund’s mandate.
Corruption, money laundering, and other economic crimes have wide-ranging negative effects on societies and are detrimental to reaching 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 2023. The governance framework is regularly reviewed to make sure it is up to date and relevant. In 2023, Norfund further updated the Code of Conduct, Business Integrity Policy, IT requirements and other underlying steering documents. Changes to streamline and enhance Norfund’s internal systems and reporting were also implemented, both in relation to the overall governance framework and corresponding working procedures, as well as Business Integrity incident reporting.
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
- Norfund Gifts and Hospitality Guidelines
- Whistleblowing and Incident Standard
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. In 2023 the focus was on updating existing due diligence routines in response to the risk assessment of our investment portfolio that was conducted in 2022 through 2023. The assessment outlined and weighed Business Integrity risks Norfund is exposed to, reviewed existing mitigating measures and suggested certain additional measures. The assessment has provided 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 together with the Compliance function and participate in a joint Business Integrity Ambassador network. In 2023, Norfund implemented a new screening tool and enhanced the training requirements of employees. In addition, the Compliance team was strengthened by hiring an Integrity Due Diligence analyst, who will contribute to enhancing Norfund’s Business Integrity capabilities and routines on an ongoing basis.
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. An assessment of Norfund’s whistleblowing channel against the Norwegian Working Environment Act was conducted by a consultancy firm in 2023, which provided valuable input into further enhancing Norfund’s whistleblowing channel and working procedures.