Preface by the Executive Board

Norges Bank, as central bank and manager of the Government Pension Fund Global, has been given considerable authority and trust. It is important to safeguard Norges Bank’s reputation by promoting a high level of ethical awareness and integrity among Norges Bank’s employees.

Norges Bank performs important public tasks and manages substantial assets on behalf of the nation. The Bank makes decisions that are of considerable importance for the business sector and private households, and manages confidential information that could have an impact on market conditions. Large sums of money are involved in the Bank’s purchases of goods and services.

All employees have an independent responsibility to contribute to safeguarding Norges Bank’s reputation. This means that employees are required to act in an ethically responsible manner and are prohibited from engaging in illegal acts, such as corruption, fraud, embezzlement, etc., and other forms of dereliction of duty that could undermine Norges Bank’s reputation. Employees must also refrain from engaging in acts, even though they are lawful, if the employee should have understood that such acts may damage the Bank’s reputation.

At the same time, ethics are more than prescriptions and prohibitions set out in laws and regulations. Ethics are also a matter of attitudes and the choices we make. It is neither possible nor desirable to regulate all the issues that could conceivably arise. The aim of these Ethical Principles is to provide guidance in approaching such matters.

1     Purpose

The purpose of these Ethical Principles is to ensure that all employees perform their duties in a professional and independent manner and act with loyalty to Norges Bank as their employer. These Ethical Principles are also to safeguard Norges Bank’s reputation and maintain public trust in the Bank. The aim of the Ethical Principles is to create a common approach to ethical matters among all Norges Bank’s employees and to provide a basis for more detailed rules and procedures.

2    Business conduct

Norges Bank must maintain a high level of ethical standards in the conduct of its activities, respect human rights, act in a socially responsible manner and comply with applicable laws and regulations.

Norges Bank does not accept any form of corruption, whether involving employees, the Bank’s contractors or other contractual or third parties. Corruption erodes ethical and moral values and is a threat to the rule of law, fundamental human rights and democracy. Furthermore, corruption creates discrimination, is an impediment to social justice and undermines fair competition.

The risk of corruption in Norges Bank is primarily associated with a person using their position at the Bank as an employee, external consultant, contractor or subcontractor, to require, receive or accept undue advantage. The management of corruption risk must be an integral part of the business areas’ risk management frameworks.

Each of the Bank’s business areas must establish an anti-corruption programme that includes work with the Bank’s contractors and other contractual or third parties. The main elements of the anti-corruption programmes must be published.  

3     Authority to lay down further rules etc

The Governor of Norges Bank and the CEO of NBIM determine further rules for their respective areas of responsibility. The further rules may vary across the Bank's organisational units when their functions so require. All further rules shall also apply to the Governor, Deputy Governors and CEO of NBIM, unless otherwise pursuant to other rules or guidelines laid down by the Executive Board or the Ministry of Finance or pursuant to legislation.

Internal rules that are laid down to implement statutory provisions or regulatory provisions laid down pursuant to legislation may not limit the statutory or regulatory provisions. However, further restrictions for employees may be laid down.

4     Scope

These Ethical Principles apply to all permanent and temporary employees of Norges Bank, and the Bank must seek to extend their applicability to the employees of its wholly-owned subsidiaries.

For non-employees who perform services for Norges Bank, these Ethical Principles apply to the extent compliance with the Principles is included as a requirement in the contract governing their engagement. Further rules must be laid down specifying when such a requirement should be included in the contract.

5    General principles

All employees have a responsibility to act in an ethically responsible manner and have a high level of ethical awareness.

Employees have a duty of loyalty towards Norges Bank and the decisions taken by the Bank.

Employees must perform their work tasks with high level of integrity and seek to maintain high professional standards.

Employees must use Norges Bank's resources in a prudent and efficient manner.

Norges Bank does not accept any form of discrimination, harassment or bullying of its own employees or others involved in Norges Bank’s activities.

Employees are encouraged to promote an atmosphere of openness and good communication at Norges Bank. Employees are encouraged to report any circumstances that may constitute a breach of these Ethical Principles or other legislation or rules etc that pertain to Norges Banks activities. Should the employee not wish to report such circumstances to his/her immediate superior or to the superior above, reporting may be made through alternative internal notification channels (whistleblowing).

6    Duty of confidentiality

Anyone performing services or work for Norges shall be obliged to prevent unauthorised persons from gaining access to or knowledge of any information that comes to his or her knowledge in the performance of his or her duties with regard to the business affairs of the Bank or others or the personal affairs of anyone (cf. Section 5-2 of the Central Bank Act).

7     Personal trading

Employees of Norges Bank may, for the purpose of managing their private assets or savings, carry out trades in shares, bonds, units in securities funds and other financial instruments. Such management must be carried out in compliance with applicable laws, regulations and the internal rules of the Bank.

For the CEO of NBIM and the Chief Compliance Officers in the Governor’s area of responsibility and in NBIM, personal trading that is subject to pre-approval and/or a lock-in period must be pre-approved by General Counsel (cf. third paragraph).

The Governor and the CEO of NBIM must, for their respective business areas, lay down further rules and other restrictions on personal trading, including with regard to pre-approval lock-in periods and reporting, if applicable. In addition to personal trading in financial instruments, the rules shall also wherever relevant apply to currency, deposits, loans and other fixed-rate products. The purpose is to protect Norges Bank’s reputation, prevent conflicts of interest and avoid suspicion that employees are engaging in personal trading on the basis of confidential information (cf. Section 8 of these Principles).

The further rules may differentiate between employee categories. Employees who in their work normally have insight into or whose work involves management of financial instruments or investments for Norges Bank shall be subject to specific rules on personal trading that are adapted to this activity. Specific restrictions on personal trading shall also be laid down for employees within the Governor’s area of responsibility who may have access to confidential information on one or more financial institutions, access to information about investment management at NBIM and for employees with access to the interest rate-setting process or the process for preparing advice on the countercyclical capital buffer.

The compliance functions are responsible for monitoring compliance with the further rules on personal trading.

8     Handling of inside information and other confidential company information

When trading in financial instruments, employees of Norges Bank must not misuse inside information[1] or other confidential information they acquire knowledge of through their work for Norges Bank. Whoever is in possession of inside information must not[2]:

• engage or attempt to engage in insider dealing[3],
• recommend that another person engage in insider dealing or induce another person to engage in insider dealings, or
• unlawfully disclose inside information, ie not as a part of the normal exercise of an employment, a profession or duties.

The abuse of inside information constitutes a criminal offence[4].

The Governor and the CEO of NBIM may lay down internal rules and procedures for their respective business areas for the handling of inside information, other confidential information and the establishment of information barriers.

9     Handling of conflicts of interest

Employees must not engage in any actions that may create, or may appear to create, a direct or indirect conflict of interest between the employees' private interests and the interests they are to protect as employees of Norges Bank.

In their work, employees must avoid relationships of dependence on or closeness to persons, enterprises or institutions outside Norges Bank if the nature of the relationship is such that it could compromise trust in Norges Bank's independence and authority.

Employees may not hold external positions of trust, secondary occupations or ownership interests that are, or may appear to be, in conflict with the interests the employee is to protect as an employee of Norges Bank. Any professional activities outside Norges Bank must be reported to the relevant line manager. Professional activities, secondary occupations or positions of trust on a more than modest scale require prior approval. For the CEO of NBIM, all such positions, ownership interests etc and all occupational activities outside of Norges Bank must have the prior approval of the Governor.

Employees are obliged to obtain actual information about their own and related parties’ circumstances that is necessary to assess their own impartiality. This applies in particular to any ownership interests or other financial circumstances of a spouse or another person with whom one lives in a relationship akin to marriage.

External positions of trust or secondary occupations are not permitted in companies within the financial sector[5] or in companies that are the Bank’s business contacts. "Business contacts" is defined as external contacts with whom the Bank does business when carrying out its activities.

Further rules regarding external positions, ownership interests and other activities outside Norges Bank are laid down by the Governor and the CEO of NBIM for their respective areas. The further rules shall include provisions for handling potential conflicts of interest related to employees’ close personal relationships both inside and outside the Bank and when transitioning to new positions.

The Governor and the CEO of NBIM may grant exemptions for their respective areas from the prohibitions contained in this section and in the further rules laid down, provided that such exemptions are not deemed to be inadvisable. In assessing this, particular emphasis shall be given to the purpose of these Ethical Principles (see Preface by the Executive Board and Section 1 above).

10     Gifts and personal benefits from/to business contacts etc of Norges Bank

Employees must not accept gifts or personal benefits, for themselves or for others, from the Bank’s business contacts or from others when performing work or service for Norges Bank. "Business contacts" is defined as external contacts with whom the Bank does business when carrying out its activities.

Further rules and procedures must be laid down defining gifts and personal benefits, potential business contacts, any exemptions from the prohibition and regarding the registering of any gifts or personal benefits that have been received.

In general, gifts must not be given to Norges Bank’s business contacts or to potential business contacts.

Under no circumstances are employees permitted to offer, or in any other way favour, business contacts or potential business contacts of Norges Bank with any kind of improper benefit in order to obtain (including where the action may appear to be an attempt to obtain) contracts or personal benefits.

The prohibitions in this section apply irrespective of the financial value of the benefit and even if the giving of the benefit is deemed customary in the relevant social setting, country or culture.

11     Acceptance of invitations

Employees may, as part of Norges Bank's activities, participate at external seminars, meetings and events that are relevant for Norges Bank's business and where participation is in the interests of Norges Bank.

Costs related to travel, meetings, seminars etc. will, as a main rule, be covered by Norges Bank. The manager of the relevant organisational unit may only grant exemptions where this is deemed unobjectionable, for example, if this follows from common practice for representation in public contexts, common practice among central banks or international organisations, academic institutions etc. In assessing this, particular emphasis shall be given to the purpose of these Ethical Principles (see Preface by the Executive Board and Section 1 above).

Further rules shall be laid down regarding how this principle will operate in practice for different types of events. See Section 12 below.

For the Governor, Deputy Governors and CEO of NBIM there shall be procedures that ensure sufficient independence in the control of coverage of travel expenses.

Employees may accept meal invitations from Norges Bank's business contacts or potential business contacts only if the meal naturally forms part of a meeting or other type of event that is connected to an engagement for Norges Bank, or where the purpose is clearly not to obtain a contract with or special benefits from Norges Bank.

12     Lectures and educational activities

Educational activities that fall within the scope of Norges Bank's business form a part of Norges Bank's mission. Employees may participate and represent Norges Bank in external gatherings and contribute by giving lectures etc., where such participation is consistent with the ongoing activities of Norges Bank and where it is deemed appropriate in light of Norges Bank's business and interests. Such participation requires the prior approval of the head of the relevant organisational unit.

Norges Bank covers travel and subsistence expenses in connection with external lectures held by or with the contribution of the employee unless otherwise pursuant to exceptions in Section 11, second paragraph above. The host organisation may also otherwise cover seminar fees etc. and meals included in the seminar fee when the lecture is part of the seminar. In special cases, the manager of the relevant organisational unit can provide prior written approval for additional expenses to be covered by the host organisation if it is deemed unobjectionable. Section 11, fourth paragraph, applies correspondingly.

Further rules on remuneration for lectures etc. must be laid down.

13     Duty of disclosure

Employees have a duty to inform their superiors or relevant control units of issues concerning compliance with these Principles or other relevant rules.

14     Consequences of a failure to comply

Failure to comply with these Principles is deemed to be a breach of the contract of employment and may be reported to the relevant authorities. In serious cases, failure to comply may have consequences for the person's employment or engagement with Norges Bank.

15     Reporting

Norges Bank must lay down procedures relating to internal reporting of compliance and non-compliance with these Principles and rules laid down pursuant to the Principles. At least once a year, the Executive Board must receive reports on non-compliance with the ethical rules and principles and follow-up status reports.

16     Entry into force

For the Governor’s area of responsibility, these Ethical Principles enter into force at the same time the further rules laid down by the Governor of Norges Bank enter into force.

For NBIM, these Ethical Principles enter into force at the same time the further rules laid down by the CEO of NBIM enter into force.

 

[1] Inside information is information of a precise nature, which has not been made public, relating, directly or indirectly, to one or more issuers or to one or more financial instruments, and which, if it were made public, would be likely to have a significant effect on the prices of those financial instruments or on the price of related derivative financial instruments. The term is further defined in Article 7 of the Market Abuse Regulation (MAR).

[2] See Articles 10 and 14 of MAR.

[3] Insider dealing arises where a person possesses inside information and uses that information by acquiring or disposing of, for its own account or for the account of a third party, directly or indirectly, financial instruments to which that information relates. See Article 8 of MAR.

[4] The formal statutory basis in Norway on the misuse of inside information and other rules of conduct relating to financial instruments is the Securities Trading Act and the Market Abuse Regulation, which has been implemented in Norwegian law.

[5] See Section 2, second paragraph, of the Regulation on the implementation of the duty of disclosure pursuant to Section 5-3 of the Central Bank Act.