Compliance and Business Code of Conduct 

Lerøy Seafood Group (the Group) has a strict policy to promote and ensure compliance with all applicable laws and regulations. 

The Group constantly determines and monitors compliance obligations related to its business activities and evaluates how these should be applied to the organization. Relevant compliance requirements are taken into account when planning, implementing and maintaining the Group’s compliance obligations as well as assessing its compliance performance. 

The Group strongly believes that an ethical business culture is key for creating and maintaining a sustainable company. The Group is committed to working ethically, with integrity and always lawfully everywhere we operate and with everyone we do business with. 

The Group has developed a Business Code of Conduct which outlines the Group’s fundamental standards and principles for business conduct and ethics, human and labor rights, environment, anti-bribery and corruption, whistleblowing and data privacy protection. We require both our employees and our suppliers to respect, support and comply with the Code as applicable. 

The Code is complemented by the Group’s set of values which define our behaviors at work. In order to verify whether and to what extent the Group’s Business Code of Conduct is applied by the Group’s suppliers, they are requested to fill out a questionnaire which requires the suppliers to explain in detail how the Code is applied and complied with. The questionnaire addresses such issues as governance, certifications, digital infrastructure and cybersecurity, supply chain, sustainability practices, human and labor rights and other subject specific requirements. 

All employees shall be able to apply the principles laid out in the Code and have received Business Code of Conduct and Ethics training to raise awareness of and compliance by employees.  All new employees have to familiarize themselves with the Code of Conduct and the Group’s set of values. Existing employees are invited to revisit and review Th Group’s Code of Conduct annually.

The Code of Conduct is reviewed by the Board annually. It is a permanent agenda item of the first Board meeting of each year. The Code is reviewed in order to evaluate its relevance and appropriateness with regards to organizational context changes, social developments, particular cases as well as feedback form relevant stakeholders.

The Group has zero tolerance for corruption. Elimination of corruption has been defined as one of the priorities of the Group. Implementing anti-corruption measures is an integral part of our corporate responsibility protecting our reputation and the interests of our stakeholders. 

The Group is a signatory of UN Global Compact and has committed to both avoiding corruption as well as developing policies and implementing measures to address corruption internally and within our supply chain. 

All our employees and workers have received training on our Business Code of Conduct which, amongst other subjects, includes information on the Group’s anti-corruption policies and procedures. 

All our suppliers are informed of and have to commit to our Business Code of Conduct, and they are expected to conduct their business in an ethical and manner as well as act with integrity complying with international and local anti-corruption and bribery laws and standards.  

All companies within the group complete detailed compliance reporting quarterly. The reporting covers such issues as compliance breaches, data privacy and protection, business code of conduct, whistleblowing, concerns regarding customers, credit policy, potential corruption cases and other issues of concern. In case of discrepancies an appropriate action is taken. The nature of the action taken is defined by the nature and severity of the discrepancy.  

Employees and workers as well as others who are required to respect and comply with the Business Code of Conduct can suggest changes and updates to the Code. If appropriate and necessary, the Business Code of Conduct is amended, updated or explained in greater detail in case there is a necessity for more clarity regarding how an issue should be handled or resolved. 

Concerns regarding compliance and business conduct can also be reported anonymously via an independent whistleblowing channel. 

I 2021 there were zero confirmed incidents of corruption and no employees were dismissed or disciplined for corruption.

There were no confirmed incidents where business partners were terminated or not reviewed due to violations related to corruption. No public legal cases regarding corruption were brought against the organization or the employees/ workers during the reporting period. 

Number of Registered Corruption Cases in 2021: 0

The Group does not support individual political  parties or individual politicians, but does engage in public debate when in the interests of the Group.

Every effort shall be made to safeguard local, regional  and global environmental aspects. Aspects regarding animal ethics shall also be given full consideration.

Supplier agreements shall contain requirements that the principles in ethical guidelines are followed. Particular care must be taken when engaging intermediaries and associated payments.

In procurement, conflicts of interest must be identified, assessed and handled in accordance with guidelines and authorizations.

How different cases are followed up will depend on the type of case, scope and degree of seriousness. Various matters will be followed up with measures by the general manager, executive vice president for the segment or by the group manager. Notification matters are reported to group management and the board.