Ethics & anti-corruption

Nammo has a zero-tolerance policy on corruption and bribery. 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.

In 2017, Nammo has sustained its strong focus on providing training within ethics and anti-corruption.

Our anti-corruption manual

The 100-Day Program

Newly acquired companies shall all follow a 100-Day Program, which is an introduction program to Nammo’s company culture, the ethical code of conduct and an interactive work-shop training with a set of different ethical dilemmas to be discussed and presented. This is part of our general risk assessment when acquiring new companies.

The training shall be accomplished within the first 100 days after the acquisition. In the fourth quarter of 2016, Nammo acquired Berger Bullet, today Capstone Precision Group. The Ethics and Culture training of the 100-Day Program for the employees of Berger Bullets was completed in January 2017.

By the end of June 2017, Nammo had acquired two more companies in the United Kingdom and one company in Ireland, all originally from the previous Moog Inc. The management and key personnel in these three companies completed the 100-Day Program of Ethics and Culture training in August.

Simultaneous with the 100-Day Program, anti-corruption training has been held for other legal entities.

Training in proactive fraud detection and anti-corruption

This is a tailor-made training program for management and key personnel at the legal entities with the objective to reinforce the importance of raising awareness of the effects and costs of fraud and corruption.

The program increases the employees’ knowledge of where the risks and costs of fraud and corruption are most significant in the Group and they learn the power of techniques that can be used to detect red flags at an early stage. They also discuss how to implement these techniques as well as follow up on red flags.

One of the key messages in the workshop is “don’t wait for the whistleblower”. We want to encourage our employees to be able to spot indications of potential wrongdoings in the course of their work and raise them through appropriate channels.

The training in proactive fraud detection and anti-corruption has been performed at seven Nammo entities until now, the last two on the US East Coast in 2017. The target group is all employees involved in the business from sales and marketing to finance, contracting and supply chain.

The overall ethics and anti-corruption program in Nammo is part of the Group’s corporate responsibility. The Ethics Directive 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 new position of Senior Vice President Compliance is assigned responsibility for assessing and monitoring the 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 in each country are allocated day-to-day responsibility within the legal entities.

Nammo has not been subject to any investigations, fines or sanctions in 2017 relating to any ethical breach of laws and/or regulations.

The ethics and anti-corruption training program and plans have been presented to the entire Board of Directors. The management group is regularly informed of progress in the ethics and anti-corruption training program.

Ethical committee

Nammo has an ethical committee consisting of three representatives from the Nammo Group. They are elected for a period of two years by the management group and report to the CEO. Incidents and concerns can be reported by email to the committee at ethics@nammo.com. In June 2017, new members were elected to the ethics committee and the mandate for the committee was both modified and updated.

The number one priority of the ethics committee is to handle any breach of the ethical code of conduct submitted internally and/or externally. The committee has quarterly meetings and can seek external legal advice if needed.

There were no cases of ethical breach submitted to the committee in 2017.

Objectives within ethics for 2018

Training and communication

There will be three types of training in 2018

  • E-learning exercises
  • Dilemma training
  • Proactive fraud and anti-corruption training

Whistleblowing

The employees in Nammo have different channels to use when they want to speak out. They can use the line organization, the human resources department, the organization of the employee representatives or they can use the ethical committee via email ethics@nammo.com.

Communication between the different channels with regard to raising concerns is part of Nammo’s improvement work for 2018.

The tone at the top

The tone at the top is of utmost importance in our daily work in building a strong ethical culture. Over the past years, the CEO has shown true leadership, ensuring that the tone at the top sets guiding values and underlines our zero tolerance for corruption. In 2018, the tone at the top shall be adopted by all management groups in Nammo. Every manager in Nammo shall participate in building a strong and ethical anti-corruption culture.