Conduct Policy for employees in the Governor’s area of responsibility
Adopted by the Governor on 25 June 2020, in force from 15 August 2020. Last amended 13 February 2023 with effect from 17 February 2023.
This Conduct Policy for employees within the Governor’s area of responsibility are a supplement to the Ethical Principles (laid down by the Executive Board on 19 October 2011, last amended on 20 December 2022).
1. Preface and purpose
As an employee of Norges Bank you are expected to have a high level of ethical awareness and integrity. You have an independent responsibility to contribute to safeguarding Norges Bank’s reputation. The ethical guidelines are comprehensive. As an employee you are responsible for understanding and following the guidelines. The compliance function can always be contacted with questions or if help is needed to understand the guidelines.
Norges Bank, as central bank and manager of the Government Pension Fund Global, is entrusted with considerable authority and trust. It is important to safeguard the Bank’s reputation and ensure 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.
The aim of this Conduct Policy is to create a common approach to ethical issues among all Norges Bank’s employees.
The purpose of this Conduct Policy 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. The regulations are also intended to safeguard Norges Bank’s reputation and maintain public trust in Norges Bank.
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 acts that even if lawful pose a reputational risk to the Bank.
Ethics are, however, 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 this Conduct Policy is to provide guidance in approaching such matters.
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 current 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, such as a bribe. The management of corruption risk must be an integral part of the business areas’ risk management frameworks.
“Financial instruments” is defined as in Section 2-2 (1), of the Securities Trading Act (see endnote[i]).
“Related party” is defined as in Section 2-5, No. 1, 2 and 4 of the Securities Trading Act (see endnote[ii]).
“Close personal relations” includes related parties and other near relatives or friends of the employee and any other personally associated parties that are apt to impair confidence in the employee’s impartiality.
"Financial sector undertakings” should be understood as in paragraph 2 of the 16 January 2020 Regulation no 53 on the implementation of duty of disclosure pursuant to Section 5-3 of the Central Bank Act (see endnote[iii])
“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 prices of related derivative financial instruments. The term is further defined in Article 7 of the Market Abuse Regulation (MAR).
“Business contacts” are external contacts with whom the Bank does business when carrying out its activities.
“Potential business contacts” are contractors that have been thoroughly assessed as likely service providers for Norges Bank.
Requirements applicable to “departmental directors” apply to directors of departments and directors who report directly to the Governor of Norges Bank.
This Conduct Policy applies to all permanent and temporary employees in the Governor’s area of responsibility. For the Governor and Deputy Governor, these rules apply to the extent they are suitable as a supplement to the Impartiality Rules laid down by the Ministry of Finance.
For part-time employees and the Bank’s subcontractors, the applicable parts of the ethical framework will be stipulated in the employment or service contract. The Conduct Policy should in particular be taken into account in connection with contracts for independent contractors and consultants and outsourcing of the Bank’s activities. Detailed guidelines on implementation of this paragraph will be laid down by the General Counsel.
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 a 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. The Bank does not accept any violation of human dignity in the workplace. Discrimination includes all non-objective differential treatment based on race, sex, age, disability, sexual orientation, religion, political opinion, national or ethnic origin or other similar conditions that are in breach of the principle of equality. Positive discrimination in order to promote equal opportunities and diversity may nonetheless be legal and justifiable in some cases.
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 this Conduct Policy or other legislation or rules etc. that apply to Norges Bank’s activities. Employees can seek advice from the compliance function. 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
As an employee of Norges Bank you are subject to a statutory duty of confidentiality and are required to prevent unauthorised persons from gaining access to confidential information.
Anyone performing services or work for Norges Bank 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
As an employee of Norges Bank you are subject to many internal rules regarding personal trading in financial instruments, foreign exchange products and fixed-rate products. These include rules on lock-in periods and reporting requirements. For some employees there are also limitations for which products that can be traded and when trades may be carried out. If you wish to engage in personal trading, you must become well acquainted with the relevant rules. You can always seek advice from the compliance function.
The term personal trading refers to trading conducted by employees for their own account or for the account of others, including related parties (see Section 3).
Employees may trade in financial instruments, foreign exchange products and fixed-rate products within the relevant laws and regulations and the restrictions and requirements laid down in internal governance documents.
When engaging in personal trading, employees must always endeavour to avoid harming the Bank’s reputation. Employees must exercise caution even if a transaction is not prohibited under these rules. This applies, for example, to trading in cryptocurrencies.
The personal trading rules apply even if trading takes place through a private limited company or other form of business organisation when the employee participates in investment decisions.
7.2 Lock-in period
Employees may not sell, redeem or refinance financial instruments, foreign exchange products or fixed-rate products (typically, fixed-rate deposits or loans) until twelve weeks have passed from the time of acquisition. The same lock-in period applies to transactions in exchange-traded funds (ETFs), exchange-traded notes (ETNs) and similar exchange-traded products (ETP).
The lock-in period does not apply to personal trading of assets under active management by a portfolio manager under contract where the employee is not involved in individual investment decisions. Nor is there a lock-in period for amending active management agreements. The prohibition on trading pursuant to the first and second paragraphs of Section 7.5 does not apply to active management agreements.
Some products include the option of determining the financial instruments to be traded under the agreement (for example unit-linked products as well as some active management agreements). If direct trading in an instrument would have been subject to a lock-in period, the same lock-in period will apply when the instrument is traded by decision of the employee as part of the contract (cf also Section 7.3 on the reporting obligation).
The lock-in period and reporting obligation do not apply to units in securities funds.
Non-Norwegian employees may have pension and savings agreements that include investments in financial instruments without this entailing a lock-in period or reporting obligation. A requirement is that the financial instruments in question are not in NOK.
Foreign exchange products refer to foreign currency loans. Foreign exchange products also include trades where the primary underlying purpose is currency or interest rate speculation. Typical examples of this are purchases of foreign exchange that are held as deposits and the like and are not intended to fund concrete purchases or “spent” in some other way.
The lock-in period for foreign exchange does not therefore apply to, for example, necessary conversion in connection with travel, studies abroad or relocation between countries using different currencies, buying or selling holiday homes or valuables abroad, online shopping in foreign currency, covering current payment obligations or investment returns in foreign currency. Such transactions are not considered to be trading in foreign exchange products. Nor is trading in currency-hedged securities funds considered trading in foreign exchange products.
Non-Norwegian employees may have loans and deposit accounts in their home country’s currency without being subject to the provisions on the lock-in period and the reporting obligation. For non-Norwegian employees at the Bank’s foreign offices, this applies correspondingly to loans and deposit accounts in the local currency.
Non-Norwegian employees at the Bank’s foreign offices may have fixed-rate loans and fixed-rate deposits in the domicile country of the foreign office without this being regarded as fixed-rate products, as long as the loan or deposit are not in NOK.
The compliance function may decide to grant exemptions from the rules on fixed-rate products and foreign exchange products where this may be regarded as unobjectionable.
In situations where the financial instrument or the same currency is acquired in more than one trade, the lock-in period applies separately for each acquisition. The lock-in period does not apply to personal trading conducted prior to the commencement of employment at Norges Bank.
7.3 Reporting obligation
When a trade is subject to a lock-in period (see Section 7.2), the acquisition or disposal must be immediately reported (at the latest before the end of two business days after completion of the transaction) to the compliance function. The compliance function obtains the necessary assessments from, and gives necessary information to, the employee’s immediate superior.
The reporting obligation applies upon completion of the transaction (trade date), not when the buy or sell order is submitted. The transaction is considered to be completed once a binding agreement is entered into, even if the transaction should be settled at a later date (value date). The trade shall be reported by the deadline even if not all documentation is available.
The same applies to the subscription of equities: the reporting obligation applies once there is a binding agreement, ie only when a decision has been made to allocate purchased equities. In connection with a subscription of equities it can be difficult in practice to report the allocation within two business days, and in such cases, the compliance function may approve reporting later where this is regarded as unobjectionable.
Reports must be submitted using the electronic notification system, with documentation of the transaction (for example the contract note) attached. If documentation is not available by the two-day reporting deadline, it may be attached later. If the electronic notification system is unavailable, the transaction shall be reported in the meantime to the compliance function, preferably by e-mail.
Agreements and amendments to active management agreements must be reported to the compliance function. Employees must also on the request of the compliance function provide supplementary information on asset holdings that are under active management.
For the Chief Compliance Officer, personal trading subject to a lock-in period requires the prior approval of the General Counsel.
7.4 Price-relevant information
An employee may not at any time purchase, establish, sell, submit trading orders, redeem or refinance financial instruments, foreign exchange products or fixed rate products if the employee has – or has access to – information that is not publicly available relating to circumstances that may affect the prices of the relevant instruments or products (cf Section 8 concerning inside information etc).
7.5 Special restrictions applying to Norges Bank’s executive management and employees who have access to inside information concerning a financial institution, the policy rate setting process etc.
The Governor, Deputy Governors and other employees who have access to inside information concerning the policy rate setting process or the process for setting the countercyclical capital buffer may not purchase, establish, sell, submit trading orders, redeem or refinance foreign exchange products, fixed rate products or financial instruments denominated in NOK during the 21 calendar days immediately preceding the date of publication of the policy rate decision. This quarantine period is extended until the decision on the countercyclical capital buffer is published in the instances where this occurs after the publication of a policy rate decision.
The members of the Norges Bank’s Central Bank executive group, other directors who report to the Governor and employees who may have access to confidential information concerning a financial institution are not permitted to acquire or dispose of Norwegian transferable securities that are issued by financial sector undertakings or derivatives of such securities. Trading in units in securities funds is permitted, provided financial sector securities funds hold a broadly diversified portfolio at the time of acquisition. The compliance function may issue an exemption for securities held by an employee when they take up a position to which the prohibition on trading applies.
The prohibition on trading in the first and second paragraph does not apply to transactions that do not involve an independent decision by the employee, such as in the case of inheritance, a gift, administration of an estate, stock redemptions in connection with write-downs, forced redemption, forced sales, involuntary conversion, bond redemption or similar. The same applies to corporate events such as mergers, demergers, stock splits and reverse stock splits, "forced" distribution of dividend shares and similar. Nor does the prohibition on trading prevent the normal exercise of any option or forward/futures contracts previously entered into upon the expiry of such contracts.
The compliance function can in special cases grant exemptions from the provisions in the first and second paragraph provided that such exemptions are not deemed inadvisable.
Departmental directors must at all times maintain a list of those units or employees and temporary staff to which the restrictions in the first and second paragraphs apply. If an employee is included in the list, departmental directors have a responsibility to notify the employee.
7.6 Employees with access to the management of financial instruments
The departmental director responsible for the management of the foreign exchange reserves must draw up a list of units or employees and temporary staff who in their work normally have access to, or whose work involves, the management of financial instruments or foreign exchange for NBCBO. If an employee or a temporary member of staff is included in the list, the departmental director also has a responsibility to notify the relevant employee or temporary member of staff. It is prohibited for persons on this list to:
- trade in derivatives or exchange-traded notes (ETNs).
- use counterparties in personal trading in financial instruments or foreign exchange products that regularly and on a significant scale provide services for NBCBO, unless trading takes place electronically and is based on standard terms and conditions. The departmental director responsible for the management of the foreign exchange reserves must ensure that a list of counterparties is drawn up.
Employees who in the performance of their duties manage portfolios or conduct transactions in financial instruments or otherwise take decisions concerning financial instruments are not permitted to conduct transactions for their own account in the same financial instruments specified in the management mandate.
Other employees who have – or have access to – information about Norges Bank’s decisions concerning trading in financial instruments are not permitted to conduct transactions for their own account in the same type of financial instrument until the information has been made publicly available.
7.7 Employees with access to NBIM’s investment activities
Employees in possession of insider information or other confidential company information regarding NBIM’s investment activities shall in all circumstances avoid using such information for personal trading or for providing investment advice to others or passing on such information to unauthorised persons (cf also Section 8).
The compliance function may lay down further guidelines.
8. Handling of inside information and other confidential company information
As an employee you must protect all market-sensitive information. The abuse of insider information constitutes a criminal offence.
Norges Bank’s activities involve processing market-sensitive information, such as information related to forthcoming policy rate decisions and auctions, decisions concerning the countercyclical capital buffer, confidential information concerning specific institutions, investment decisions or the like by NBIM, information relating to extraordinary measures for specific banks or market-oriented measures taken by the government or by Norges Bank during financial crises. Such market-sensitive information may have an impact on government bond markets (fixed income markets) or on securities markets in general.
When trading in financial instruments, employees must not misuse inside information or other confidential information they acquire knowledge of through their work for Norges Bank. Whoever is in possession of inside information must not:
- engage or attempt to engage in insider dealing
- 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.
9. Handling of conflicts of interest
Employees must inform their immediate superior as soon as possible if there is a risk of conflict of interest. You can also seek advice from the compliance function. The main rule is that Norges Bank must pre-approve paid work or paid positions outside the Bank. The same applies to unpaid secondary occupations or positions of trust that are of a more than modest scale.
9.1 General provisions concerning 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. Employees must not act in a manner that may be in conflict with the performance of their duties at Norges Bank. Employees must inform their immediate superior as soon as possible if there is a risk of conflict of interest, including conflicts of interest relating to external positions, ownership interests, close personal relations both within and outside the Bank and regarding potential conflicts of interest when transitioning to a new position etc. Potential conflicts of interest should be handled as early as possible before appointment or when appointment occurs, and in an ongoing manner should the risk of conflicts of interest later arise. In the event of specific conflict-of-interest issues, reporting to immediate superiors should be documented, for example as an email. Employees can also seek advice from the compliance function.
Employees of Norges Bank must not hold a position whereby they evaluate, approve, supervise or in any other way assess the work of close personal relations in or outside the Bank. An employee must not prepare, facilitate, supervise or in any other way process any matter in which the employee or a close personal relation of the employee has a direct or indirect economic or other personal interest. Similarly, an employee must not process any matter where there are any other circumstances that could impair confidence in the employee’s impartiality, cf Section 6 of the Public Administration Act concerning impartiality.
9.3 Relationship to financial institutions, business contacts, etc.
Employees may not receive remuneration from secondary occupations or serve on a board of directors, supervisory council or similar body:
- in financial sector undertakings, or
- for one of the Bank’s business contacts.
If persons or companies with whom the employee is associated seek a business connection with Norges Bank, the employee must not act in a manner that creates ambiguity as to who the employee is acting for or which interests he or she is safeguarding. Employees must not give undue emphasis to their employment at the Bank vis-à-vis private business contacts.
9.4 Secondary occupations
The provisions in this section do not apply to duties performed by the employee on behalf of or on assignment for Norges Bank.
Employees of Norges Bank must not engage in professional activities or accept any remuneration for secondary occupations or positions of trust other than from the Bank without the prior written approval of the departmental director. Even when they are unpaid, professional activities, secondary occupations and positions of trust that are of a more than modest scale require prior approval. Application for prior approval should be made using the electronic notification system.
For academic secondary occupations on a modest scale, such as lectures, participation in assessment committees, supervising students and marking examination papers, etc., it is sufficient for the employee to inform his or her immediate superior in writing in advance.
Employees are not required to submit advance information or seek prior approval in connection with assignments or positions of trust on a modest scale in a jointly owned property, housing cooperative, social associations, political activities, sports clubs or in connection with their children’s education, etc. If employees in such positions partake in investment decisions, the Bank’s rules for personal trading apply (cf Section 7.1 fourth paragraph).
9.5 Secondary occupations that may be prohibited, etc.
The departmental director may, on the basis of an assessment in the specific case, issue a decision prohibiting an employee from holding specific external positions of trust, secondary occupations or ownership interests, including unpaid positions that are, or may appear to be, in conflict with Norges Bank’s interests. This will apply if, for example, the activity could have a negative impact on the employee’s work at Norges Bank or impair the Bank’s reputation. Similarly, the departmental director may decide that the external activity must cease. The assessment shall be provided in writing and a copy of the decision must be sent to the compliance function as soon as possible.
9.6 Exemptions from prohibitions
The Governor may grant exemptions from the prohibitions in Section 9, provided they are not deemed to be inadvisable. Assessments shall give particular weight to the purpose of the policy (see Section 1).
10. Gifts and personal benefits from/to business contacts etc of Norges Bank
The main rule is that employees are not permitted to accept gifts or other benefits from external parties when performing work or service for Norges Bank.
10.1 Prohibition against accepting gifts etc. when on Bank business
Employees are not permitted, for themselves or for others, to accept gifts, discounts, commissions, gift cards, services or any other benefits from the Bank’s business contacts or from others when performing work or service for Norges Bank that may constitute a personal advantage for the employee or that could, or may be intended to, influence the employee’s performance of his or her duties. The following further guidelines apply:
a) The prohibition applies irrespective of whether a gift in such situations is customary in the milieu, country or culture in question. Invitations to participate in trips, sporting events, concerts etc. paid by parties other than Norges Bank are also considered gifts. See, however, Section 11 on invitations etc. that may be accepted.
Employees are allowed to accept typical advertising material of modest value (calendars, almanacs, pens, etc), as well as other items of modest value in connection with seminars or educational events. For these types of gifts, no reporting is required.
Gifts from other central banks, international organisations or other public authorities may be accepted if the gift has modest value and it would in the circumstances be considered inappropriate and unusual if the Bank’s representative did not accept the gift. The name of the recipient and of the giver and the nature of the gift, must be reported as soon as possible for approval via the electronic notification system to the departmental director and the compliance function. Gifts with an assumed value in excess of NOK 500 must become the property of the Bank and be turned over to the compliance function.
b) The prohibition also applies to duties performed outside Norges Bank, for example serving as a board member, when the duties are connected with the employee’s position at the Bank.
c) Employees may receive public awards or academic honours and decorations bestowed by universities, colleges, research funds, etc. The compensations are accrued to the employee, who themselves must ensure compliance with tax rules and other rules for such compensation.
d) Under the prohibition on gifts, bonus points and the like earned from official travel cannot be used for private purposes.
Subsection 10.1.1 also applies to gifts or other benefits given to close personal relations of the employee that may be connected with the employee’s position at Norges Bank. In the event, the employee must, as far as can reasonably be expected, endeavour to prevent the gift or benefit from being provided.
10.2 Gifts from Norges Bank to external parties
The main rule is that Norges Bank does not give gifts to business contacts or potential business contacts. If this would seem impolite for reasons of culture or custom in the country in question, a modest gift may be given. Under no circumstances are employees permitted to offer, or in any other way favour business contacts or potential business contacts of Norges Bank with gifts or 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 (cf also Section 10.3).
10.3 Corruption prohibition
Employees must not, for themselves or for others, request, receive or accept an offer of an improper advantage in connection with a position or an assignment. Similarly, employees must not provide or offer an improper advantage in connection with a position, office or assignment. The penalty for corruption, or aiding and abetting such an offence, is fines or imprisonment for a term not exceeding 3 years. Gross corruption, or aiding and abetting such an offence, is punishable by imprisonment for a term not exceeding 10 years.
Employees must not, for themselves or for others, request, receive or accept an offer of an improper advantage, such as a bribe, in order to influence the execution of a position, office or assignment. Employees must not provide or offer an improper advantage in order to influence the execution of a position, office or assignment.
Whether an advantage is or is considered improper will depend on an overall assessment. A number of factors may be of importance, such as:
- the value of the advantage
- whether the advantage is in breach of internal guidelines, cf for example Section 10.1.1 above
- the purpose of the advantage
- whether the advantage has been kept hidden
- the relationship between the giver/provider and the recipient
Norges Bank can also be held responsible in the event of corruption by third parties acting on behalf of Norges Bank.
10.4 Loans to and deposits from employees and related parties
Employees or related parties may have loans and deposits on ordinary market terms with a business connection of the Bank whose ordinary activities include lending and deposit taking.
A related party may have loans and deposits on employee terms from a lending and deposit-taking institution that is one of the Bank’s business contacts provided the loan has been granted in connection with the related party’s employment. Employees of Norges Bank may be co-signers for such loans or have such deposit accounts if they are a standardised part of a customer loyalty programme based on the related party’s employment.
Employees or related parties may have loans and other financial services through schemes negotiated by employee organisations and offered to their members.
The compliance function can decide on exemptions from the supplementary rules on gifts in Sections 10.1, 10.2 and on loans and deposits in Section 10.4 where this is not deemed inadvisable.
11. Acceptance of invitations etc.
As a main rule, Norges Bank covers all costs incurred by employees participating at external seminars, meetings and events.
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. incurred in the performance of professional duties for the Bank are as a rule covered by Norges Bank unless otherwise follows from common practice for representation in public contexts, common practice among central banks or international organisations, academic institutions etc.
In special cases, the departmental director can nonetheless grant prior approval for such expenses to be covered by the host organisation if it is deemed unobjectionable by the director to make an exception under the circumstances. In assessing this, particular emphasis shall be given to the purpose of the policy (see Section 1). A copy of the approval must be sent to the compliance function as soon as possible.
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. This provision also applies to meals offered by host organisations, sponsors etc. as part of a meeting or seminar. Participation in travels, meetings, seminars, etc. on official Bank business are not subject to the prior approval of the departmental director but must be agreed on in advance with the employee’s immediate superior and must be undertaken exclusively for the purpose of conducting Bank business (not wholly or partly for private purposes).
For travel expenses etc. related to external lectures, see Section 12.
12. Lectures and educational activities
With prior managerial approval, employees may give lectures etc on Norges Bank’s activities. Detailed rules on accepting compensation, claims for and reimbursement of related expenses apply.
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.
Employees are not permitted to accept compensation for external lectures directly linked to Norges Bank’s activities unless the total value of the compensation is less than NOK 500 and is customary for that type of lecture. Compensation in the form of cash or deposit money may nonetheless not be accepted.
Any compensation received must be reported as a gift via the electronic notification system (cf Section 10.1.1.a). The employee is responsible for ensuring compliance with tax rules and other rules for such compensation.
Norges Bank covers travel and subsistence expenses in connection with external lectures held by or with the contribution of the employee, unless otherwise follows from common practice for representation in public contexts, common practice among central banks or international organisations, academic institutions etc. 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 departmental director can provide prior written approval for additional expenses to be covered by the host organisation if it is deemed unobjectionable by the director to make an exception. A copy of the approval must be sent to the compliance function as soon as possible.
13. Duty of disclosure
Employees have a duty to inform their superiors or relevant control units of issues concerning compliance with this Conduct Policy or other relevant rules.
At the start of the employment relationship, the employee must inform the compliance function of secondary occupations and holdings of financial instruments (with a lock-in period), foreign exchange products and fixed-rate products.
In connection with monitoring and control in relation to the provisions in Section 7 and 9, employees are required, when requested to do so by the compliance function, to provide information about secondary occupations, holdings of financial instruments (with a lock-in period), foreign exchange products and fixed rate products or other factors.
In monitoring employee compliance with the rules, the compliance function may search for and use publicly available information such as data on the ownership of Norwegian equities and information on employee roles in the business sector.
14. Consequences of a failure to comply
Failure to comply with Conduct Policy is deemed to be a breach of the contract of employment. In serious cases, failure to comply may have consequences for the person’s employment or engagement with Norges Bank. Employees can always seek advice from the compliance function.
Failure to comply with this Conduct Policy 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.
Repeated violations of the Conduct Policy may be regarded as a serious violation even if the individual violation in isolation is not serious.
In the event of a violation of the Conduct Policy by an employee, the compliance function will notify the employee with a description and assessment of the violation by email copied to the employee’s line managers up to and including departmental director. The employee’s line managers will determine whether the violation will result in an official response.
All new and existing employees must on request sign a declaration confirming that he or she has read and understood the Conduct Policy for employees within the Governor’s area of responsibility and that he or she is aware of the consequences of violating these principles and rules.
The compliance function shall provide targeted and regular training on the ethical framework. The training is to be adapted to employee’s tasks and relevant conflicts of interest. Upon appointment, new employees are to receive appropriate training. As a minimum all employees are required to complete annual training and confirm that they are up-to-date on all reporting and that they have read and understood the Conduct Policy.
 See “Guidelines for whistleblowing within the Governor’s area of responsibility” (internal regulation).
 “Employees and temporary staff who, in their work, normally have access to or whose work involves management of financial instruments or foreign exchange for Norges Bank” are not permitted to trade in exchange-traded notes (ETNs) (cf. Section 7.6).
 Acquisition and disposal encompass more than purchase and sale, such as transactions in gifts, settlement of an estate or inheritance.
 It is important to note that units in securities funds are a financial instrument.
The prohibition on trading is not an impediment to trading during the “quarantine period” in units in securities funds where more than 95% of the fund is comprised of financial instruments in currencies other than NOK.
Nor is the prohibition on trading an impediment to pre-determined fixed payments through an existing savings instrument during the “quarantine period”.
 This includes access to Norges Bank’s settlement system (NBO) data.
 See note 3.
 Cf Section 2-4 (1) of the Securities Trading Act.
 The rule is intended to prevent trading in securities funds with a portfolio that is primarily limited to Norwegian securities in the financial sector. Thus, the rule is not an impediment to trading in units in securities funds with a “narrow” portfolio in another sector.
 Exemptions that are not deemed inadvisable pursuant to the first or second paragraph can include the sale of allocated subscription rights before the rights expire or become worthless, or the disposal of securities acquired through inheritance, as a gift, or in the administration of an estate, or Norwegian transferable securities that an employee holds upon commencement of employment at Norges Bank. Another example is the exercise of subscription rights assigned on the basis of existing holdings. The compliance function may obtain advice from departmental directors.
 See section 3.
 See Articles 10 and 14 of MAR.
 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.
 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 MAR, as implemented in Norwegian law.
 The Governor should report to the General Counsel or the Compliance function.
 See definition in Section 3. Possible risks of conflicts of interest relating to close personal relations may, for example pertain to relationships with individuals among suppliers or other third parties that have ongoing work with Norges Bank or directly with the employee. Another example is when employees become family members with or become close personal relations with another employee. See also Section 9.2 on impartiality.
 Employees must exercise sound judgement in considering conflicts of interest. As an aid, employees can ask themselves some control questions:
- Could this be perceived externally as personal advantage I receive because of my position?
- What does the other party wish to achieve?
- Is contact transparent?
- Would I experience discomfort if colleagues or superiors became aware of this?
- How would I react if my colleagues had done the same?
- How would this be presented by the media?
- How would this impact the Bank’s or my own reputation if it were to be discussed in the media?
 cf. the provisions concerning corruption in Sections 387 and 388 of the General Civil Penal Code
[i] “Financial instruments” mean:
- Transferable securities,
- Money market instruments,
- Units in collective investment undertakings,
- Options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates, yields or emission allowances, or other derivative instruments, financial indexes or financial measures which may be settled physically or in cash,
- Options, futures, swaps, forwards and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the option of either party other than by reason of default or other event leading to termination of the contract,
- Options, futures, swaps, forwards and any other derivative contracts relating to commodities that may be physically settled, provided they are traded on a regulated market, a multilateral trading facility or an organised trading facility, except for wholesale trades in energy products that are traded on an organised trading facility that must be physically settled,
- Options, futures, swaps, forwards and any other derivative contracts related to commodities, which have the same characteristics of other financial derivatives, which may be physically settled unless otherwise mentioned in no 6 and which are not for a commercial purpose,
- Derivatives for the transfer of credit risk,
- Financial contracts for difference,
- Options, futures, swaps and forward rate agreements and any other derivative contracts relating to climate variations, freight rates or inflation rates or other official economic statistics, which must be settled in cash or may be settled in cash at the option of either party other than by reason of default or other event resulting in termination of the contract, as well as any other derivative contracts relating to assets, rights, obligations, indexes and measures not otherwise mentioned in this section, which have the characteristics of other financial derivatives, having regard to whether, inter alia, they are traded on a regulated market, on a multilateral trading facility or an organised trading facility,
- Emission allowances under the Greenhouse Gas Emission Trading Act.
[ii] “Related party” of a person means:
- the spouse of such person or another person with whom the said person lives in a relationship akin to marriage,
- the under-age children of such person, as well as the under-age children of another person as mentioned in no 1 with whom the said person cohabits,
- an undertaking over which the said person or entity or any person or entity mentioned in nos. 1, 2 or 5 exercises such influence as mentioned in the Private Limited Companies Act section 1-3 subsection (2), the Public Limited Companies Act section 1-3 subsection (2) or the General and Limited Partnerships Act section 1-2 subsection (2).
[iii] Financial sector institutions or undertakings mean inter alia:
- Financial institutions under Section 1-3 of the Financial Institutions Act,
- Payment institutions under Section 2-10 of the Financial Institutions Act,
- Account information service providers under Section 2-10a of the Financial Institutions Act,
- Electronic money institutions under Section 2-11 of the Financial Institutions Act,
- Other companies, associations and foundations whose purpose is to extend or provide credit,
- Government lending institutions,
- Central securities depositories,
- Management companies under Section 1-2 (1) 2. of the Securities Funds Act,
- Investment firms,
- Central counterparties,
- Participants under Section 1-3 of the Payment Systems Act,
- Regulated trading venues etc and
- Branches in Norway of foreign institutions and undertakings etc as mentioned in a through l.