At NPA Nordiskt Papper, we unequivocally condemn corruption and bribery in all their forms. We refuse to engage in such practices, irrespective of local customs or prevailing norms. Our stance on corruption is resolute: the offer, payment, authorization, solicitation, or acceptance of bribes and other illicit advantages is categorically unacceptable.
This Anti-Corruption and Bribery Policy articulates NPA’s strategy for combating bribery and other corrupt activities. It delineates our commitment to fostering a culture of integrity, transparency, and ethical conduct across all levels of the organization.
WHO DOES THIS APPLY TO?
This policy applies universally to every individual associated with NPA, irrespective of their hierarchical position or role within the organization. Compliance with this policy is mandatory for all personnel, and failure to adhere to its principles may result in termination contractual relationships.
WHAT IS OUR COMMITMENT?
We categorically reject any form of bribery, whether directed towards public officials or private individuals. NPA strictly prohibits the offering, provision, or authorization of any type of bribe, including facilitation payments, whether conducted directly or indirectly. Similarly, we do not entertain requests for or accept bribes, regardless of their nature or origin.
Bribery can manifest in various forms, spanning monetary and non-monetary, tangible and intangible assets. These may include but are not limited to: monetary transactions, gifts, entertainment, preferential discounts or loans, rebates, overpayments, utilization of assets at preferential rates, sponsorships, charitable contributions, political donations, offers of employment or internships, and the provision of information or assistance.
To mitigate the risk of bribery and corruption, NPA has instituted a comprehensive framework of procedures and controls. These encompass our interactions with public officials, protocols surrounding gifts and entertainment, engagements with business partners, oversight of sponsorships and donations, management of political contributions, and stringent record-keeping practices. Furthermore, we maintain a vigilant stance, continuously monitoring for indicators of corruption and bribery, promptly reporting any suspicions to our Compliance department for thorough investigation and resolution.
PUBLIC OFFICIALS
Engaging with public officials inherently elevates the potential for corruption or the perception thereof. Therefore, we exercise heightened caution in all interactions involving public officials, including communication, the exchange of gifts and entertainment, and the provision of assistance.
FACILITATION PAYMENTS
In specific regions, public officials may seek minor payments, commonly referred to as facilitation payments, to hasten or guarantee the execution of routine governmental tasks. These tasks may include issuing permits, licenses, or official documents; processing visas; facilitating customs clearances; providing police services; delivering utility provisions; or managing cargo logistics. It’s essential to recognize that facilitation payments constitute a type of bribery.
At NPA, we strictly prohibit the initiation or approval of facilitation payments. Should any request for such payments arise, individuals must refrain from making the payment and promptly notify our Compliance department for appropriate action.
GIFTS AND ENTERTAINMENT
Properly managing the exchange of gifts and entertainment is crucial to mitigating the potential risks associated with bribery or corruption, whether real or perceived. At NPA, we adhere to stringent guidelines regarding the giving and acceptance of gifts and entertainment:
- Gifts and entertainment are only exchanged when they are offered in good faith, on an occasional basis, and are deemed reasonable and appropriate within the context of normal business courtesy.
- Transparency is paramount in all transactions involving gifts and entertainment.
Conversely, we refrain from giving or accepting gifts and entertainment under the following circumstances:
- When there is any intention or likelihood of influencing decision-making or other conduct.
- When there is an intention to gain an improper or undue advantage.
- When the gift or entertainment could reasonably be construed as a form of bribery.
In the form of cash, including prepaid cards or gift cards that can be exchanged for cash.
SPONSORSHIPS, CHARITABLE CONTRIBUTIONS, AND COMMUNITY INVESTMENTS
We are never utilized as a means to camouflage bribery or to secure an illegitimate business advantage at NPA. Prior to engaging in any sponsorship, community investment, or charitable contribution, we diligently conduct risk-based due diligence to assess potential risks. We also uphold vigilant monitoring practices to ensure the proper and legitimate use of our funds or resources whenever necessary.
POLITICAL CONTRIBUTIONS
We uphold the integrity of the political process by refraining from seeking to influence it through improper or corrupt methods at NPA. As a proactive measure to mitigate this risk, we abstain from contributing any funds or resources to political campaigns, parties, candidates, or affiliated organizations.
BUSINESS PARTNERS
We hold our business partners to the same high standards of ethical conduct and responsibility that we uphold at NPA. Under no circumstances do we authorize any business partner to engage in bribery or corruption on our behalf.
To ensure transparency and accountability in our partnerships, we implement a risk-based Know Your Counterparty program, meticulously identifying and evaluating our business partners.
To effectively manage the risks associated with bribery and corruption linked to our business partners, we employ a range of robust controls and processes. These measures include screening, due diligence, and ongoing monitoring, all conducted through a risk-based lens.
For high-risk business partners, such as business developers, joint venture partners, lobbyists, consultants, or advisors engaged in interactions with public officials on our behalf, we institute additional safeguards. Before entering into such partnerships, we conduct comprehensive risk-based assessments to identify, evaluate, and mitigate any corruption risks associated with these engagements. Furthermore, we implement ongoing monitoring and conduct regular reviews of our high-risk business partner relationships to ensure continued compliance with our ethical standards.
ACCURATE RECORD KEEPING
We uphold meticulous standards in recording all transactions within NPA’s books and records, ensuring strict adherence to our established procedures. Our records accurately reflect the nature and substance of each transaction.
SPEAKING OPENLY
Each individual within NPA holds the responsibility for upholding their commitments. We encourage our employees and contractors to foster a culture of transparency by openly addressing any concerns they may have regarding potential breaches of the Code of Conduct and related policies. These concerns should be raised with their manager, supervisor, or through other designated reporting channels, including our Raising Concerns platform, which is accessible to both internal and external stakeholders.
At NPA, we take all concerns seriously and ensure they are addressed promptly. We maintain a zero-tolerance policy towards any form of retaliation against individuals who speak out about behavior they believe to be unethical, illegal, or inconsistent with our Code of Conduct and policies. This protection extends to those who report concerns, provided the report is made in good faith and without knowingly providing false information.
CONSEQUENCES
Our policies support our Code of Ethics and Code of Conduct and reflect what is important to us. We take breaches of our policies seriously. Depending on the severity of the breach, consequences may range from a warning to termination of employment
“Integrity Illuminates: Embrace Transparency, Reject Corruption.”
