Conduct of Business Code for Providers of goods and services

Issued 12 October 2016
Revised 23 October 2019

This code applies to all providers, except for those who have access to Norges Bank Investment Management’s systems, premises or certain investment-related information.

Background

Norges Bank is the Central Bank of Norway, established in 1816.

Norges Bank Investment Management is part of Norges Bank and manages the Government Pension Fund Global.

Being entrusted with considerable authority and confidence, it is important to safeguard the reputation of Norges Bank and Norges Bank Investment Management. We take our responsibility seriously and are committed to conducting business with a high level of ethical standards and in compliance with applicable laws and regulations. Providers of goods and services (“Providers”) are expected to meet the same high standards.

Scope

This Code sets out the expectations towards all our Providers in relation to responsible business conduct.

This Code does not however apply for Providers who have access to systems, premises or certain investment related information. A separate Conduct of Business Code applies for such Providers.

Additional requirements apply where set out in the contract with the relevant Provider.

Overarching expectations

Providers are in their performance of services expected to:

• Comply with applicable laws and regulations.
• Meet the expectations set out in this Code.
• Safeguard Norges Bank’s reputation through a high level of ethical awareness and integrity.
• Reflect the expectations in this Code in contracts with their own suppliers who are directly involved on our accounts, (“Sub-Contractors”).
• Have appropriate policies and procedures (including awareness training) and internal controls to address compliance with this Code.
• Self-monitor (including monitoring of Sub-Contractors’) compliance with the Code.

Human rights, labour standards and discrimination

Providers are in their performance of services expected to:

• Respect human rights.
• Comply with internationally recognised conventions, such as the United Nation and International Labour Organization conventions on human rights and labour rights.
• Take reasonable and appropriate actions to ensure that their personnel who act on behalf of, or are contracted to work for Norges Bank Investment Management, treat their colleagues and other personnel with respect, and avoid any form of discrimination, harassment or bullying.

Environmental

Norges Bank Investment Management seeks to conduct its business in a manner where appropriate attention is paid to environmental issues. Providers are expected to promote environmental business practices in a manner that is appropriate to their business in relation with their work.

Bribery, corruption, fraud, money laundering and other prohibited business practices

Norges Bank Investment Management does not tolerate any form of bribery, corruption, fraud or any other prohibited business practice.

The Provider is expected not to:

• Offer or give an undue advantage, favour or improper payment to any public official or other third party, neither directly nor through an intermediary.
• Offer representatives of Norges Bank Investment Management or their close associates, any bribe, entertainment or gift in order to influence how they perform their professional duties.
• Demand or accept bribes or other improper payment in order to act or refrain from doing what is part of the Provider’s normal duties.
• Be involved in an arrangement or transaction that relates to fraud or other prohibited practices.
• Receive, or be involved in any arrangement or transaction that relates to assets that may be the proceeds of crime (money laundering) or financing of terrorism.

Providers are expected to take appropriate actions to identify and assess the integrity of the Provider’s business relationships.

Conflicts of interest

Providers are expected to refrain from actions that are liable to generate, or may be perceived to generate, a direct or indirect conflict of interest between their own interests (including those of their employees) and the interests they are to safeguard when performing under the contract.

Providers shall notify any potential conflicts of interest.

Gifts

Providers and their employees are expected not to  offer gifts, directly or indirectly, to employees of Norges Bank Investment Management or anyone closely related to them, except for promotional items of minimal value bearing a company logo customarily offered as part of business meetings and materials received as part of a seminar or educational event.

Inside information

Providers or their employees who in their work for Norges Bank Investment Management receive knowledge of inside information or other sensitive information shall not misuse such information, disclose it to others, or trade or recommend others to trade on it.  The unauthorised use of such information could result in a violation of insider trading laws.

Inside information, also known as material, non-public information in some jurisdictions, generally means information that is not known to the public, but if it were, would likely affect the market price of a company’s securities or financial instruments or be considered important to a reasonable investor in making an investment decision.

Confidentiality and media contact

Anyone who works or performs a service for Norges Bank Investment Management has, pursuant to the Norges Bank Act section 12, a duty to prevent others from gaining access to, or knowledge of, any matter that they may become aware of in the performance of their duties or service regarding the business affairs of Norges Bank Investment Management or of other parties, or of the private circumstances of any person.

The duty of confidentiality remains in force after the completion of the assignment or service contract, and violation is subject to a penalty.

The Provider is expected to not announce the existence of the contract with Norges Bank, its subject matter or refer to or use the name of Norges Bank Investment Management or Norges Bank in any marketing or other promotional communication, whether to the public or to a person, unless approved by Norges Bank Investment Management.

All questions the Provider receives from the media or other external parties regarding Norges Bank Investment Management must be directed to the Communications and External Relations group.

Email: press@nbim.no

Security

Norges Bank Investment Management supports an information security programme and practice that meets recognized industry standards for information protection and IT security, and expects its Providers to do the same.

Providers are expected to manage information and IT security risks, implement reasonable and appropriate security measures, and be able to demonstrate security controls are in place to ensure client information is protected from unauthorized disclosure, access, use or modification, and that security incidents are detected and responded to appropriately.

In addition, Providers shall follow any security requirements specified in contractual agreements with Norges Bank Investment Management.

All questions or security concerns affecting Norges Bank Investment Management shall be directed to the Security group.

Email: security@nbim.no

Notifications to Norges Bank Investment Management

Providers and their employees are encouraged to notify, insofar as allowed under applicable laws, any suspected or actual breaches of the expectations of the Code or any other suspicions of illegal activities or other forms of wrongdoing in workplace, at NBIMEthicsline@nbim.no