Ethical rules for theStorebrand GroupAdopted by the Board of StorebrandASA 15 January 2013
3Contents1. Background and main principles 42. Target group 43. Other rules 44. Openness 45. Rules governing business practice 45.1. Human rights 45.2. The environment 45.3. Responsible investments 45.4. Procurement and suppliers 45.5. Sales and marketing 55.6. Corruption 55.7. Money laundering 56. Rules governing personal conduct 56.1. Discrimination and bullying 56.2. Confidentiality 56.3. Relationships with business partners 56.4. Representation and arrangements 56.5. Gifts and benefits 66.6. Close associates 66.7. Eligibility 66.8. Secondary occupations and employment by other companies and organisations 66.9. Inside information 66.10. Information and IT systems 66.11. Use of the Group’s equipment and property 66.12. Financial obligations 66.13. Purchase of sexual services 77. Whistleblowing 78. Responsibility and follow-up 7
4Ethical rules for the Storebrand Group1. Background and mainprinciplesThe Storebrand Group (hereafter referredto as the Group) offers life insurance, P&Cinsurance, health insurance, banking servicesand asset management in Norwayand Sweden. The ethical rules support theGroup’s core values.The Group’s operations depend on thetrust of customers, the authorities, shareholdersand society in general. In orderto gain trust we are dependent uponprofessionalism, expertise and high ethicalstandards in all aspects of our work. Thisapplies to the way the Group operatesand to the conduct of each individual.All employees are therefore expected tobehave with care, integrity and professionalismand abstain from actions whichmay weaken trust in the Group. Managershave a distinct responsibility and must actas role models.The ethical rules are available on theintranet and on the Group’s website.HR will help ensure that the Group’semployees are familiar with these rulesand know what they mean in their dailywork through measures such as e-learning,dilemma training, group work andanonymous Q&A service on the intranet.Compliance with the ethical rules willbe monitored through regular employeefollow-up and measured by an annualethics indicator.2. Target groupThe ethical rules apply to all employees ofthe Group. They also apply to anyone whoholds a position of trust in the Group (includingmembership of boards) and hiredconsultants acting on behalf of the Group.The ethical rules do not give customers orother third parties legal rights.3. Other rulesThe ethical rules form guidelines forethical behaviour but cannot cover allsituations. In each individual situation itis important to use common sense in assessingwhat is ethical conduct.In addition, everyone is required faithfullyto follow laws, directives, circulars, relevantethical standards for the sector andinternal rules which apply to the Group’soperations. Managers must ensure thatemployees are given the opportunityto familiarise themselves with the rulesthat apply to their own work, while eachindividual employee is responsible forcomplying with the rules.4. OpennessStorebrand strives for a business culturecharacterized by openness. Openness is aprerequisite for motivation, trust, confidenceand safety at work. Everyone shallfeel confident to raise any concern, smallor large, with their manager or anothercolleague.The ethical rules cannot state what isright or wrong in every situation. It isimportant to be open about your actionsand to talk to others. If in doubt the problemshould be discussed with your linemanager or HR. It is also possible to usethe anonymous Q&A-service for ethicsandcode of conduct-related questions onour Intranet.5. Rules governing businesspractice5.1. Human rightsIn its operations the Group shall respectfundamental human rights as describedin international human rights conventionssuch as the UN Convention on HumanRights and the labour rights conventionsof the International Labour Organization(ILO). The Group shall actively contributeto ensuring that business partners andthe companies in which the Group investsrespect human rights.5.2. The environmentThe Group shall actively work to reducethe environmental impact of its ownoperations, investments, procurementsand property management. The Group willalso facilitate and inform employees whowish to reduce their private environmentalimpact.5.3. Responsible investmentsThe Group shall be a responsible investor.The Group requires that companies in ourinvestment portfolio meet our standardson social and environmental performance.This enables us to use our power as anasset manager, to influence companieslisted on the stock exchange, to work systematicallywith corporate responsibility.See The Storebrand Group Standard forResponsible Investments for more information.5.4. Procurement and suppliersThe Group shall be a responsible purchaser.By requiring that goods and servicesprocured by the Group meet our standardson social and environmental performance,we use our power as a purchaserto influence suppliers to work systematicallywith corporate responsibility.See the Group’s Procurement policy formore information.
55.5. Sales and marketingThe Group shall not engage in any form ofsales or marketing which may be regardedas offensive or which conflicts with generalsocial norms. Financial advice mustalways be based on the needs of customers,their financial situation and their attitudeto risk. The Group must not exploitits advantages in knowledge and financein its dealings with customers, but giveadvice that serves customers’ interests,even though this may not always be mostprofitable for the Group in the short term.All advertising, information and termsand conditions must be characterised byrespect for customers, society and theenvironment.5.6. CorruptionCorruption is the abuse of a positionof trust to acquire personal or businessbenefits for yourself or others. The Groupis opposed to all forms of corruption andworks actively to ensure that this doesnot occur in the Group’s business activities.No one may receive benefits for themselvesor for others (re 6.5) from theGroup’s business contacts if such benefitsare based on the employment relationship.Correspondingly, no one shall givesuch benefits to our business contacts.Benefits may be gifts, discounts, traveland bonuses on private purchases, loansor similar. Exceptions to this rule arebenefits that the Group has acquired forall employees in all or parts of a countryin which we operate.See The Storebrand Group’s anti corruptionguidelines for more information.5.7. Money launderingMoney laundering is the process of creatingthe appearance that assets obtainedfrom criminal activity, originate from alegitimate source. The Group must avoidany involvement with assets resultingfrom criminal activity and work activelyto reduce money laundering as a socialproblem.See Guidelines for measures to preventmoney laundering and terror financing etc.in the Storebrand Group for more information.6. Rules governing personalconduct6.1. Discrimination and bullyingWe must tolerate the opinions and beliefsof our colleagues and other parties. Noone must discriminate against or bullyother colleagues/employees, businesspartners, customers or other parties. Reportsof discrimination or bullying will betaken seriously.6.2. ConfidentialityEveryone is required to maintain confidentialitywith regard to knowledge acquiredabout the business or private interests ofcustomers, colleagues and other partiesin the course of work carried out forthe Group. This applies unless the lawor The Storebrand Group’s guidelines forwhistleblowing states otherwise. The dutyof confidentiality also covers informationabout the Group’s business operationsand other matters of an internal andconfidential nature. The duty of confidentialityapplies not only externally but alsobetween individual companies within theGroup. The duty of confidentiality alsoapplies to others within the same Groupwho do not require knowledge of suchconfidential information in their work.6.3. Relationships with businesspartnersNo one shall act in a way that may hinderimpartial conduct in relation to theGroup’s customers, suppliers, shareholdersor other parties connected with theGroup. Restraint must be demonstratedin private agreements and exchange ofbenefits with companies and individualswith whom individuals in the Group havebusiness contacts through their work. Furthermore,restraint must also be shownin business agreements with people withwhom there is a private relationship.If an employee has a private relationshipwith a business contact, this must be reportedto the employee’s line manager. Inorder to assess whether a relationship isof a private character, the employee mayask oneself as to what has been given ordone in order to deserve and retain thiscontact.6.4. Representation and arrangementsWe expect that employees who representor may be identified with the Group as aresult of their position behave in a mannerwhich inspires trust in the Group andin the employees themselves.Arrangements held under the auspicesof the Group must be characterised bymoderation and have relevant professionalcontent.If the arrangement involves travel andovernight accommodation for invitedexternal participants, this must be coveredby the person invited (either directly orthrough a participant’s fee). However, theGroup can cover the cost of accommodationfor those invited if the purpose ofthe arrangement is training.
6Employees who are invited to seminarsor similar events with suppliers or otherbusiness contacts will have their traveland accommodation costs covered by theGroup. If the purpose of the invitation istraining, however, accommodation costscan be covered by the business contact.See Guidelines for arrangements underthe auspices of the Storebrand Group formore information.6.5. Gifts and benefitsIn principle no one may accept benefitsincluding gifts and invitations, from theGroup’s business contacts if the benefitis based on his or her employment. Theemployees are permitted to receive benefitsof limited value, i.e. estimated valuedoes not exceed more than 500 NOK inNorway, 300 SEK in Sweden and 100 LTLin Lithuania. If the benefit exceeds thementioned amounts, the line managermust approve of the benefit, be transparentand the employee has to report thevalue according to applicable tax laws.Gifts given inside the Group are coveredby separate regulations in the staffmanual.Gifts given on behalf of the Group musthave a nominal value and must notexceed the value of what we are allowedto accept (see above). It must not bepossible to cast doubt on the Group’smotives and the recipients' integrity. Noone must give gifts or other benefits onbehalf of the Group with the purpose ofreceiving reciprocal benefits for their ownadvantage.See The Storebrand Group’s anti corruptionguidelines for more information.6.6. Close associatesClose associates 1) cannot occupy positionsin which one is the line managerof another or where the positions areotherwise incompatible. Wherever suchsituations occur, the close associates havea mutual responsibility of resolving thesituation without undue delay.6.7. EligibilityNo one may take part in processing ordecision making on a case where circumstancesexist which could weaken confidencein the impartiality of the individual.In such cases influence must not beexerted on others in the Group.Under no circumstances shall anyone discuss,decide or otherwise influence a casewhen the person concerned or a closeassociate has, either directly or indirectly,financial or other personal interests inthe case. If a line manager is not eligibleto deal with a case, it cannot normallybe decided by an immediate subordinateeither.A colleague must inform his/her line manageras soon as he/she becomes awarethat there may be a conflict of interest.The line manager must decide whetherother employees or the public could castdoubt on the eligibility of that employeeor his/her ethical integrity. If it is foundthat there is a conflict of interest then theemployee must not participate further inthe processing of the case.6.8. Secondary occupations andemployment by other companiesand organisationsNo employee may work, be a memberof the board, run, or have a significantinterest in businesses that operate in thesame field as one of the Group’s companiesor which have a business relationshipwith these without their employer’spermission.The employer must be consulted if an employeein a senior position in the Groupwants to run a private business or undertakepaid employment in their free time,apart from one-off jobs. Permission willbe granted, provided that such a secondaryoccupation/ work is compatible withthe employee’s satisfactory performanceof work for the Group.Secondary occupations which are sodemanding that they may affect theemployee’s work must be approved by theemployee’s line manager. Elected politicalposts, which are regulated by law, mustbe notified to the employee’s managerand must be organised in such a way thatthey cause the least possible disruptionto the Group.6.9. Inside informationInside information is information whichmay affect the price of securities andwhich is not publicly available or generallyknown in the market.No employees shall use or help others touse inside information about the Group orother companies as the basis for tradingin securities. This applies both privatelyand on behalf of the Group.See Rules for managing and reportinginside information in Storebrand ASA formore information.6.10. Information and IT systemsNo one shall actively search for informationabout other employees or customerson internal database systems or archivesunless this is necessary for his/her workfor the Group.6.11. Use of the Group’s equipmentand propertyNo one shall make unreasonable use ofthe Group’s data, IT equipment, materialsor other property for private purposes orfor activities that are not related to work.The use of computer games, gambling,pornography, racist material or otherapplications which may be regarded asoffensive is forbidden.6.12. Financial obligationsEmployees must ensure that their financialobligations to the Group are always inorder. If employees are subject to strongfinancial pressure this may be regardedas weakening the respect and impartialitywhich the Group strives to achieve.1) Close associates means spouses or partners and your own or your partner’s underage children. Close associates are also considered to include companies inwhich the employee or their close associates have decisive influence. Other specific circumstances may also be of such a nature that after a thorough assessmentthose concerned must be considered close associates.
7An employee who is aware that he orshe is unable to meet his or her financialobligations to the Group must inform hisor her line manager unless the financialsituation is of a temporary nature.6.13. Purchase of sexual servicesThe purchase of sexual services is forbiddenby Norwegian, Swedish and Lithuanianlaw. This also applies to employeestravelling abroad on business.7. WhistleblowingNotification or whistleblowing is to passinformation about a censurable or possiblecensurable incident to someonewho is in a position to initiate correctivemeasures. A censurable incident isan illegal, dangerous or any other act inbreach of company regulations. Anyonewho becomes aware of an incident/situationwhich appears to contravene rulesand guidelines which apply to the Group’soperations is encouraged to report this.Notification is good for each employee,for the company and the society as awhole because it offers an opportunity toimplement corrective action. A colleaguewilling to make a report is an importantresource to the Group.Each employee is encouraged to report onpossible censurable incidents but is notnormally obliged to do so. However, everyemployee has an obligation to report oncriminal activity and on incidents whichcould endanger life or health.There are several ways to make a report.In principle all employees can report,orally or in writing, to a line manager, tothe HR Manager, the Human ResourcesDirector, the employee representative orthe leader of the working environmentcommittee. In addition you can reportby using the Q&A-service for ethics- andcode of conduct-related questions on ourIntranet.If you prefer to report outside of theGroup administration, so-called whistleblowing,you can contact our partnerfor whistleblowing, an Oslo-based lawfirm. More information is available on theintranet.See The Storebrand Group’s guidelines onwhistleblowing for more information.8. Responsibility andfollow-upManagers at all levels have a specific responsibilityto ensure that their own andtheir subordinates’ behaviour is in linewith the rules. Managers are also responsiblefor reporting breaches of the ethicalrules to the HR manager, as well as submittingan annual report on compliance.Individuals must continuously evaluatetheir work in relation to the rules. If thereis any doubt about whether an action isethically defensible, the person concernedmust withdraw from the case, or raisethe issue with his or her line manager. Itis also possible to use the question-andanswerservice on the intranetThe ethical rules are based on the Group'score values, which are used in employeefollow-up. The HR manager has theoverall responsibility for the ethical rules.The HR manager is responsible for makingthe ethical rules accessible and ensuringtraining and awareness. Breaches of theGroup’s ethical rules will normally resultin the consequences set out in the tablebelow.SeriousnessNegligenceGross negligence / repeatedIntentional / repeated in-Breach ofinstances of negligencestances of gross negligence> > Internal rulesand guidelines> > Verbal warning> > Written warning> > Assess dismissal or retirement> > Legislation andregulations> > Written warning> > Assess reporting,dismissal or retirement> > Reporting, dismissal orretirementSanctions must follow the guidelines set out in the Norwegian Working Environment Act and applicable industrial agreements. TheGroup’s routines linked to the implementation of sanctions must be taken into consideration. All sanctions shall be assessed by the HRmanager before implementation.All responses and the processes followed must comply with the main principles in the Group’s staff manual, routines and the NorwegianWorking Environment Act.
19116c ENGELSK Grafisk senter 01/2013Storebrand ASAProfessor Kohtsvei 9, P.O. Box. 500, N-1327 Lysaker, NorwayTel: 08880, www.storebrand.no