Compliance

The defense and aerospace industry is highly regulated by the national authorities in the countries where it operates. In addition to national regulations, the industry must also comply with a wide range of requirements within quality, supply chain, security and military standards, as well as other requirements introduced by industrial or governmental customers. For the company to be compliant with these requirements, all employees must follow the established routines, systems and standards.

In 2016, the decision was made to establish a chief compliance position at Nammo management group level. The main purpose of the compliance function at Nammo is to assess risk across the business, develop training and internal communications strategies, evaluate data and conduct critical investigations in close cooperation with legal counsel when necessary.

Other assignments include internal review of legal entities and risk monitoring, as well as working on influencing organizational culture and behavior and clearly communicating the vision, mission and strategy of the ethics and compliance program. Compliance is of utmost importance to Nammo. All our entities must be in compliance with national laws and regulations if they are to be allowed to operate, and thereby fulfill their business purpose.

Our focus on compliance is now increasing even further, as external requirements continue to grow. To successfully address this challenge, we continue to improve our skills by taking advantage of ongoing education opportunities, with Nammo compliance professionals attending training programs both in the US and in Europe.

Compliance also provides a competitive advantage; if we are not compliant, we risk our reputation and make ourselves vulnerable to severe economic consequences. As such, ensuring compliance in all areas is one of our highest priorities.

n 2016, the decision was made to add new competence to the Nammo management group level by establishing a Chief Compliance position. After 15 years with responsibility as head of communications of which eight years as a member of the management team, the time had come for Sissel Solum to take on new challenges. She is our Senior Vice President Compliance.

"I was thrilled to take on a new responsibility from scratch and motivated by the opportunity to define compliance at Group level in Nammo. At the same time, I was confident that my broad knowledge of the defense industry business in general and the Nammo Group and our employees in particular, would be an advantage in this new position," Sissel states.

Compliance officers today are assuming a much more strategic role when it comes to helping organizations manage compliance and reputational risk. Similar to the position in communications, the compliance officer needs both an understanding of the full range of reputational risks, as well as an instinct for what can go wrong and how their organization can prepare.

Compliance at the top of the agenda

"Compliance is a high priority at Nammo. All our entities must be compliant with national laws and regulations in order to be allowed to perform our business. The aerospace and defense industry is highly regulated by each country’s national authority. In addition to national regulations, the industry must comply with several numbers of quality, supply chain and security standards, military standards and other requirements set forth by an industrial or governmental customer," Sissel continues.

"Internally, all employees need to follow the established routines, systems and standards. Compliance has gained increased importance in parallel with the increased level of external requirements to our company. The risk of employees breaching our systems or routines can lead to loss of contracts, as a breach of our ethical standards can have a serious impact on our reputation."

Compliance ambitions and targets

"The main ambition of the compliance role is to assess risks from across the business, develop relevant training and communication strategies, evaluate data, and conduct sometimes critical investigations in close cooperation with legal counsel. Assignments also include internal reviews of legal entities and risk monitoring as well as working on influencing the organizational culture and behavior, and clearly communicating the vision, mission, and strategy of the ethics and compliance program.

My key ambition for 2018 will be to assess the compliance maturity of the Group and prioritize the identified risk areas and develop an improvement and implementation plan according to the findings. In parallel we will continue to monitor and follow up actions and internal training within ethics and export control."

Nammo from an employee perspective

"I have spent 16 years in the Nammo Group and I am still learning something new every day," says Sissel.

"The company is an excellent place to work for those who are interested in global industry, politics and technology. It is an exciting international Group where we regularly get the opportunity to meet colleagues from other countries and cultures as well as customers and suppliers from all over the world.

I am surrounded by competent and professional people who motivate each other and always seek the best solutions together.

Nammo is a company open to supporting its employees seeking complementary education. Knowledge is everything! Nammo stays true to its vision and values. The freedom of action and responsibilities given to its managers are quite broad. You easily get the feeling that it is the people who define the company and its culture. With our flat Nordic management structure, every voice can be heard if you speak loud enough."

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In June 2017, Nammo cohosted the second annual FAR/DFARS seminar in Oslo for Norwegian industry. Along with the FSi (Norwegian Defence and Security Industries), NADIC (Norwegian-American Defense and Homeland Security Industry Council) and the Kongsberg Group, Nammo planned the seminar to highlight the latest information about contracting with the United States government.

FAR, the Federal Acquisition Regulations, are the US government’s acquisition regulations that are required of companies doing business with the US government. The DFARS, the Defense Federal Acquisition Regulations Supplement (DFARS), are the specific set of regulations for companies in the defense industry, in support of the contracts issued by the US Department of Defense (US DOD).

In 2016, at the first Norwegian Industry seminar on FAR/DFARS, there were 106 industry attendees from Norway, Sweden and Finland. For the 2017 seminar, there were 145 industry attendees from the Nordic countries. The seminar included a keynote speech by Stephen Knight from Smith Pachter McWhorter PLC in Virginia and additional expert sessions conducted by representatives from Norwegian industry.

For companies to enter the competition to be awarded US DOD contracts, it is important to meet the technological requirements, and it is also important to meet the specific contractual requirements related to contract management including: pricing of commodities, transport of commodities, safety during the contractual period, and supply chain management.

Nammo companies are subject to frequent audits by the DCMA and the DCAA during the lifecycle of the US DOD contracts. The annual FAR/DFARS seminar provides industry representatives with current updates to the FAR/DFARS and the practical operational know-how to successfully implement compliant routines. With the latest FAR/DFARS competence, Nammo continues to be competitive in the US marketplace and successfully secures and manages US-government-funded contracts at Nammo sites inside and outside the continental US.

Nammo simultaneously orchestrated a proactive and non-reactive compliance program to respond to the changing landscape, and implemented a company-wide Lean and Six Sigma program involving all six business units.

Nammo’s ambition was to position itself among the best; number one in the business segment. By continuously reinvesting in development and technology, Nammo secures both sustainability and profitability and paves the way for increased focus on internal processes, including successfully meeting the requirements of the changing landscape.

In March of 2017, the Board of Directors for the FSi (Norwegian Defence and Security Industries) decided to establish an export control committee with the intent to strengthen the close coordination of export control compliance within the defense and security industries in Norway.

The committee, today known as the FSi EKU (eksportkontrollutvalg), brought together and formalized an industry workgroup dedicated to building the competence required for industry to successfully navigate the governmental and non-governmental laws, regulations and requirements influencing export control of technologies, including: materials, data and services.

FSi EKU has representatives from eight Norwegian industries, and the chair for 2017-2018 is Nammo Raufoss AS.

In 2017, FSi EKU worked with the Norwegian Ministry of Foreign Affairs to provide input to the electronic licensing system used by the Norwegian industry to file for export licenses. The aim of this interactive process is to develop a system that enables both the Norwegian government and the industry to license and track technologies in a more efficient and yet comprehensive manner.

In 2018, the continuation of building competency to comply with the changing landscape will take place at each Nammo site and will be complemented by external training in meeting rooms, classrooms and in the field with business partners. The outcome will be sustainable supply chains from Nammo’s suppliers to Nammo’s customers and will include risk reduction throughout the business transactions and a measurable increase in the selection of Nammo as a supplier of choice. Examples include:

The US government requires that all companies manufacturing products for the US Department of Defense comply with US Site Safety requirements if energetic materials are handled in the manufacturing process. This substantial requirement for Nammo sites and Nammo’s supply chain of energetic materials involves training and site planning. To fulfil this requirement for sites outside of the US, Nammo Raufoss has hired a project manager with the delegated task of managing the requirement in order to reduce duplication, increase competency and to work with the Nammo sites in Europe as well as the supply chain and implement training and comprehensive project management.

In June, training courses on the changing landscape of US export regulations will be held at Nammo sites across Europe. The courses are a part of the continuing education for Nammo sites in order to maintain a high degree of export compliance expertise and thereby ensure the integrity of the export of Nammo goods and services globally.

A Six Sigma project with representatives from compliance, the Small and Medium Caliber Ammunition Business Unit and the Aerospace Propulsion & Space Business Unit is working to map the US government requirements that flow to Nammo in requests for proposals and contracts.

The project is identifying how to manage the requirements internally at Nammo sites, particularly the sites outside of the continental United States, and how to flow the requirements into the supply chain as required by the US Federal Acquisition Regulations (FAR). The outcome from this project will be shared with other Nammo sites in peer-to-peer training conducted by Nammo staff.

After an internal risk evaluation, we have selected four focus areas for the first 18 months:

  1. Increase and broaden training of ethics and anti-corruption
  2. Continue to strengthen our third-party due diligence
  3. Continue to follow up internal risk evaluation of export control and perform regulatory export compliance training.
  4. Support legal entities with best practice procedures for Governmental audits.

Nammo has worked to develop close collaboration with industry partners, customers and suppliers to build a strong and compliant environment for trade in the defense industry. This is added value for Nammo because it builds trust across the supply chain, from the end user to Nammo. This is beneficial for all parties because we are able to build our understanding of government and customer requirements throughout the supply chain, and reducing Nammo’s risk.

2017 saw major shifts in the global geo-political landscape with the continued discussions on Brexit, the new administration in Washington DC and the changing laws and regulations due to mass migration. As a result, the laws and regulations governing compliance had some dramatic shifts both in new requirements and in increased enforcement. This has had a particular impact on export control, sourcing of materials in the supply chain, governmental budgets for defense procurement, prosecution of industry violations related to business ethics. Moreover, due to the fallout from global data hacking scandals, the defense industry must now comply with heightened cyber security requirements.

To successfully compete in the changing landscape, it is important for Nammo to understand the requirements and to adapt to meet these requirements internally and externally with business transactions. The adaptive changes for Nammo internally included recruiting new staff and new work teams and increasing competence throughout the Nammo Group using internal training, external training and e-learning training modules.

We require our suppliers to be compliant with our supplier conduct principles and the Nammo ethical code of conduct. The principles are founded on the UN Global Compact's ten principles, as well as our company values.

The objective of these principles is to state our requirements for best business practices and personal conduct in the entire Nammo supply chain and for Nammo’s business partners.

Nammo mainly buys from European countries and North America, where the risk of violation of human rights and other regulations is low. Nammo supports the 10 principles of the UN Global Compact and therefore focus on suppliers who can follow these principles.

As Nammo's main activity is industrial production, most suppliers provide raw materials for our products and machining equipment. Local suppliers are to be used if competitive and, as an example, Nammo Raufoss makes purchases worth more than NOK 100 million locally every year. When it comes to services, most of these are provided by national suppliers in areas where we have operations.

It is vitally important to secure long-term agreements for deliveries from suppliers of critical components or materials.

Read Nammo Supplier Conduct Principles.

We aim to conduct the best ethical practices and leverage Nammo's position with our global supply base in order to yield best value for all Nammo business units.

We have an open dialogue with our suppliers. Nammo’s procurement council hosts annually a USA supplier conference for updates, compliance and exchange of information. An annual survey is also distributed to our most critical and valuable suppliers, with a focus on requirements for organization, products, materials and updates of certificates, such as ISO.  The survey covers areas like processes, sub-contractors, range of products and services and environmental measures and results in connection to processes, products, improvements, product planning, performance and training of staff. Other areas covered are quality systems, audits, documentary verification of products, inspections, calibration, REACH, risk analysis, use of conflict minerals, existence of Business Continuity Plan and Disaster Recovery Plan and credit rating.

Our strategic supplier list is regularly maintained. We actively research new opportunities to secure strategic materials and components, including identifying new suppliers. Strategic suppliers are evaluated for the short and long term, depending on the availability of materials.


 

Nammo promotes compliance with the International Traffic in Arms Regulations (ITAR), the Federal Acquisition Regulations (FAR) and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) and the export regulations in all countries where we are domiciled and conduct business.

We are committed to implementing procedures that comply with ITAR and other regulations that control the transfer of sensitive technologies. This creates a culture of compliance, which extends to Nammo’s suppliers, partners and customers throughout all business activities, including product development, procurement, sales and marketing.

ITAR and the Export Administration Regulations (EAR) are export control regulations run by different departments of the US government; both designed to help ensure that sensitive technologies do not fall into the wrong hands. An export license is a general term for both ITAR and EAR-controlled items where the US government has granted permission to transport or sell controlled items to foreign countries or parties.

The Defense Federal Acquisition Regulation Supplement (DFARS) is the principal set of rules in the Federal Acquisition Regulation System (FAR) that controls the acquisition of defense related goods and services. The FAR system itself governs the acquisition process by which executive agencies of the United States federal government acquire (i.e., purchase or lease) goods and services by contract with appropriated funds.

Nammo is committed to complying with the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation. This is an EU regulation concerning chemicals and products manufactured, produced, imported or used in the EU-EEA area. Nammo also complies with additional EU Directives that control many aspects of business trade including; exports, workplace safety, handling of goods and transit of goods. 

A Lean project at Nammo Lapua Vihtavuori focused on reconfiguring the layout of production for greater efficiency and reducing unnecessary documentation accompanying the production process. The training outcome was such a success that the site, along with colleagues from other Nammo sites in Finland, plan to implement a Lean project in 2018 to create an internal improvement team with planning and executive capabilities.

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