Ethics and Compliance

In Nammo we aim to be recognized for our high ethical standards. Nammo’s Ethical Code of Conduct describes the Group’s business practices and the requirements regarding expected behavior related to corruption, conflicts of interest, harassment and discrimination. All employees and all third parties acting on behalf of Nammo shall follow these requirements.

We encourage all employees to SpeakUp and report any unethical behavior or misconduct that violates the company’s Ethical Code of Conduct. Any employee who refuse to act against the law or refuse to violate the company’s Ethical Code of Conduct, shall be supported and protected even where such actions result in a loss of business or another disadvantage to the company.

Nammo has a zero-tolerance policy on corruption and bribery and we believe the best mitigating factor to prevent the risk of corruption in the company is to organize regularly training sessions for both our employees and the third parties acting on behalf of the company.

In Nammo we have focused our training program on anti-bribery and corruption with three areas. These are e-learning, dilemma training and Proactive Fraud “red flag”training. You can read more about the diverse training programs under Training & Communication in the Compliance Program overview.

Management of Ethics

The Directive of Ethics in the Nammo Group Management System is organized under the Senior Vice President of Human Resources who has overall management responsibility for the training programs. The Chief Compliance Officer is assigned responsibility for assessing and monitoring the Anti-Bribery and Corruption program.

Every employee in Nammo must ensure that they are familiar with and perform their duties in accordance with the requirements set out in the Ethical Code of Conduct. The human resources manager in each country have the responsibility to follow up on a day-to-day basis with the legal entities.

The ethics and anti-corruption training program is part of the monthly compliance reporting to the Board of Directors. The management group is regularly informed of progress in the ethics and anti-corruption training program.

Nammo has not been subject to any investigations, fines or sanctions in 2019 relating to any ethical breach of laws and/or regulations.

Ethics & Integrity Council

In 2019 Nammo established an Ethics & Integrity Council which replaced the previous Ethics Committee. The new Council is represented by three members from the Corporate level of the Group (SVP HR, SVP Legal & Compliance, SVP Finance). They are nominated for a period of three years by the Management Group.

The mandate of the Council is to act as an independent Council across the organizational structure and the reporting lines of the Group. The Council hold an advisory role to the Chief Compliance Officer (CCO) in several areas. In particular when evaluating risk levels on incoming concerns to the new reporting channel SpeakUp, and to support the CCO in the establishment of an investigation response team. The Council make recommendations and improvements of the Ethical Code of Conduct to the CCO.

The Ethics & Integrity Council can report directly to the CEO or the Board of Directors if need be. The Board of Directors have the formal oversight function of the company’s anti-bribery and corruption program. This is an integrated part of the Group Compliance Program.