Introduction
The Brunstad Foundation will conduct its business through ethical, responsible and sound business practices, where applicable laws and regulations are complied with. To achieve this goal, all board members, employees and hired persons must make a concerted effort.
Our code of ethics applies to all our businesses spread throughout the world. They apply to all employees and board members, including those in subsidiaries of the Foundation. They also apply to hired persons and others acting on behalf of and representing the Brunstad Foundation. Leaders who engage such people are responsible for assessing their suitability, and when deemed necessary for informing them regarding the code of ethics.
The code of ethics provides the framework for responsible behavior within the Group, yet they are not exhaustive in terms of what is generally regarded as ethical and good conduct. It is a managerial responsibility to raise employees’ awareness regarding the importance of ethical choices and to give guidance in specific situations. It is the individual employee’s responsibility to acquaint themselves with our code of ethics so that each one conducts themselves in accordance with these.
Responsible Behavior
Our managers and employees must comply with public legislation and international requirements in their work for the Brunstad Foundation
The Brunstad Foundation’s leaders and employees should always comply with applicable laws and regulations, as well as the Foundation’s internal guidelines. Our internal guidelines may well be stricter than public laws and regulations in the countries we have our business but should nonetheless always be followed.
Our Employees have Integrity
Our employees behave in the correct manner, even in private. In all our work, together with other employees, suppliers and other community participants, we consider it to be important to be reliable, trustworthy and honest.
Employees who are placed in a situation that is or may be perceived to be challenging, must seek advice from their superiors so that the case can be handled correctly.
Our employees work for the Group’s best and must be loyal to the Brunstad Foundation
Our employees use their best judgment to promote the Brunstad Foundation’s values. We always safeguard the interests of the Brunstad Foundation and keep our focus on contributing to improvements in the work. Our loyalty is centered on the Brunstad Foundation’s best and will prioritize the Foundation’s legitimate interests above our own and others’ interests.
Our employees should be aware that associations can be made with the Foundation through their behavior in private contexts. Being loyal to Brunstad Foundation also involves safeguarding the reputation of the Foundation through our behavior privately and professionally.
Our employees have respect and care for people, property and the environment
We work for a corporate culture in the Brunstad Foundation where consideration and respect for people, the environment and our properties are in focus. Our behavior – both privately and professionally – must promote trust in our collaboration with colleagues, customers, suppliers and other business associates as well as the authorities.
samarbeide med kolleger, kunder, leverandører og andre forretningsforbindelser samt overfor myndighetene.
Our principles of behavior
Protect the Brunstad Foundation’s properties, assets and reputation
Our employees may not participate in activities or conduct that could damage the Brunstad Foundation’s reputation.
We should act responsibly so that we protect the Foundation’s assets against damage, theft, abuse, or anything else that destroys them. This applies to both tangible assets such as buildings, machinery and equipment, and to other assets. Our employees also protect information, ideas and other intellectual property rights such as patents, designs, trademarks, recipes and other knowledge.
The Brunstad Foundation’s assets may not be used by the employees for their own or others’ private purposes, except in cases where prior approval has been granted by a superior who is authorized to give such permission.
Our employees will handle information about the Brunstad Foundation with caution and confidentiality.
We build our trust with customers, business associates, colleagues and society in general by sharing our perspectives. This should be done without harming our own business and reputation by communicating confidential information, information that is not or should not be known to the public.
This applies to information such as business plans, budgets, customer information and the like. Our employees will never give such information to persons outside the company, unless this serves the Foundation / the company’s interests and is agreed upon with the person who may grant such permission. By statutory duty of disclosure, the responsible manager in the relevant area shall provide the information.
The individual employee is obliged to follow this confidentiality agreement also after termination of employment or cooperation.
Anti-Corruption
Our employees shall under no circumstances participate in bribery or corruption of any kind. This applies in all parts of our business, regardless of where it is located in the world.
Courtesy gifts can be exchanged, provided they have a minimal economic value. They must be fitting to the circumstances and occur exceptionally. Such gifts should be addressed to the recipient’s official work address so that no grounds for suspicion should arise that the recipient will keep this hidden from his superior.
Employees shall never claim, offer, receive or give cash or gifts that are likely to affect a decision or as a consideration for a service.
Reasonable and appropriate arrangements for customers or employers for business purposes are acceptable. The guest’s employer shall be granted an explicit opportunity to pay travel and stay for his participating employees. The same principle applies if our employees participate in such events organized by others.
Employees offered gifts and services other than courtesy gifts shall notify their immediate superior, who decides whether the gift must be returned.
No employee shall receive, offer, or seek to gain benefits for himself or anyone else that may harm the interests of the Brunstad Foundation.
Conflicts of interest
Employees are responsible for handling conflicts of interest properly and they must be loyal to the Brunstad Foundation.
All employees should avoid influencing or participating in decisions that may lead to an actual conflict of interest. The same applies for what can be perceived by others as a conflict of interest. This is especially true in cases where the employee or close relative to this person has a personal interest of a financial nature, or other personal interests.
Any assignments outside the Brunstad Foundation must be cleared by employees with their immediate superior. Such assignments must not be in competition with or contrary to the interests of the Brunstad Foundation.
Employees who become aware of conflicts of interest should inform their immediate superior about this as quickly as possible.
Money laundering
Brunstad Foundation’s employees must not under any circumstances participate in any form of money laundering.
Money Laundering means arrangements that are implemented to ensure that profits from a criminal offense become integrated into the legal economy. If an employee becomes aware of transactions that indicate that money laundering is occurring or has occurred, then he or she must report his concern to Brunstad Foundation’s Compliance Function as soon as possible.
This also applies to activities that aim to avoid the discovery of unauthorized or unlawful evasion of taxes, duties or other charges.
Health, Safety and Environment (HSE)
All our employees must take their responsibilities in relation to HSE seriously, thus contributing to the Brunstad Foundation’s vision of zero work related injuries.
It is expected that all employees at all times comply with HSE rules in their organization and demonstrate good discretion in relation to all work operations. All employees shall report nonconformities and violations of the Brunstad Foundation’s or the individual company’s rules for HSE, either through the company’s deviation system or to their immediate manager.
Discrimination and harassment
All employees should experience that the Brunstad Foundation is a workplace where everyone is respected for who they are. Behavior that can be perceived as discriminatory or harassing, including sexual harassment, is incompatible with the Brunstad Foundation’s values and is not accepted.
No discrimination based on, for example, gender, sexual orientation, age, disability, nationality, ethnicity or political or religious beliefs shall take place. All employees must be aware of cultural differences and treat colleagues, business associates and others with respect.
Written Agreements
All Brunstad Foundation’s agreements must be entered into and / or documented in writing and filed appropriately. This applies to all agreements with employees, suppliers, customers and other business associates
Agreements without economic value should also be documented in writing to prevent suspicion of unethical behavior and to help in understanding relationships and situations in retrospect.
Accounting
The Brunstad Foundation’s accounts must always be correct and reliable.
The Brunstad Foundation’s accounts are crucial for the management of the Group’s operations. Employees who participate in financial transactions or posting of accounts shall ensure that all transactions are documented and recorded in accordance with current law and generally accepted accounting principles.
Brunstad Foundation does not accept misleading or improper accounting.
Healthy Competition
Brunstad Foundation’s companies will always compete in the market in accordance with applicable competition and market legislation and respect these provisions. Managers and employees involved in marketing, sales, procurement or logistics should familiarize themselves with and comply with applicable laws and internal guidelines.
Drugs and alcohol
Employees shall not work in a state where they are affected by drugs or alcohol.
Brunstad Foundation does not accept the use of drugs in connection with work and services.
In connection with representation or corporate events, moderate quantities of alcohol may be served. This shall never be combined with illegal driving or other work incompatible with alcohol intake.
Completion
The obligation to Comply with the Regulations
It is a managerial responsibility to clarify the Brunstad Foundation’s ethical expectations and the individual employee’s responsibility to fully understand and comply with the requirements of our ethical guidelines. The requirements also apply where breaches of the principles may be perceived to be in accordance with the Brunstad Foundation’s interest. It is not in the Foundation’s interest to violate the requirements of the ethical guidelines to achieve short-term or other benefits for the Foundation. In all such cases, our employees must not encourage others or themselves to act in violation of the guidelines. In cases where the employee is unsure whether an event or activity is a violation of the policy, he or she should as far as possible, clarify this in advance with the immediate superior.
The Brunstad Foundation can implement internal disciplinary measures to employees in case of violation of the guidelines, including termination and the bringing of charges.
Whoever has HR responsibility in each organization must prepare relevant support material for training and awareness in their business.
Notification
Employees who become aware of censurable situations, such as an illegal act or violation of the principles of our code of ethics, should notify this in accordance with the notification procedures.
Implementation and follow-up
It is the Managing Director / General Manager of each company who is responsible for implementing the ethical guidelines and ensuring that all employees are introduced to them and receive adequate information. Managers at all levels are responsible for contributing to the ethical guidelines becoming a relevant and integral part of the Foundation’s strategic assessments, decision-making processes, activities and evaluations. The individual manager is responsible for ensuring that the guidelines are known and followed within his own area of responsibility and should lead with a good example. The company’s employment contracts and personnel manual should always refer to these guidelines.
Employees must comply with the guidelines and participate in the training offered by the Brunstad Foundation or the individual company. The Managing Director / General Manager must report annually to the Board of the individual company regarding activities related to promoting ethical awareness and behavior.
The Brunstad Foundation’s Compliance Function is responsible for updating the ethical guidelines.
All Brunstad Foundation employees are responsible for addressing ethical issues that need clarification.
Adopted by the Brunstad Foundation Board, March 8, 2018.