Ethical principles

Conflicts of interest arise when a party has professional obligations or personal or financial interests that could affect their objectivity. Conflicts of interest may exist even if there is no partiality under the Norwegian Public Administration Act.

§ 6 of the Norwegian Public Administration Act regarding partiality applies to Eksfin’s employees. A public official is partial in the preparation of a basis for a decision or in making a decision in an administrative case when they or their family are a party in the case, when they represent a party in the case, or when they are a manager of, hold a senior position in, or are a member of the board or corporate assembly of a company that is a party in the case, unless it is wholly publicly owned. 

A public official is also partial when there are other particular circumstances that weaken confidence in their impartiality. Here, emphasis shall be placed on, for example, whether a decision on a case would entail a particular advantage, loss, or inconvenience for the official themselves or someone with whom they have a close personal connection. 

Eksfin’s employees:

– shall be impartial in all business activities and not give other companies, organisations, or individuals an undue advantage or disadvantage, 

– shall not be involved in relationships that could result in an actual or perceived conflict of interest with Eksfin’s interests or be detrimental to the general trust in Eksfin, or that may in any way have a negative impact on the official’s freedom of action or judgement,

– shall avoid situations where an actual or perceived conflict of interest may arise between their own personal and/or financial interests and Eksfin’s interests. Employees may never try to obtain benefits for themselves that are inappropriate or likely to harm Eksfin’s interests in any way.

– shall not participate in decisions where there is a personal interest in the case. This applies not only if the employee has a personal interest, whether financial or otherwise, in the case, but also where this is true of someone with whom they have a close relationship, such as a relative.

– shall not use their position to influence assessments in employment cases that could give rise to favouritism or other unreasonable discrimination,

– shall not work with or process cases where there are other circumstances that could undermine confidence in the employee’s own impartiality or the integrity of the work performed.

External engagements (other occupations/side assignments) include positions, roles, tasks, assignments, and memberships in or for other companies. External engagements that may conflict with Eksfin’s interests must be approved in advance by a senior manager. The CEO is to obtain consent from the board. External engagements that Eksfin’s employees undertake must not affect their ability to perform their role for Eksfin and must not be in conflict with Eksfin’s activities or interests.

The main rule is that employees should avoid accepting or offering gifts and other benefits, as this may mean that questions are raised with regard to the parties’ independence and integrity. Gifts or other favours to or from Ekfin’s customers or business associates must be in accordance with locally accepted good business practice and may be given or received only if they are modest in value. As a guide, gifts of less than NOK 500 are considered to be of modest value. However, a concrete assessment must always be made as to whether the gift or other type of benefit can be perceived as affecting the integrity and independence of the recipient, giver, or oneself. Monetary gifts must never be given or received. If an employee receives a gift or other type of benefit that conflicts or could conflict with Eksfin’s ethical principles, a superior manager or the compliance function must be informed immediately.

Eksfin may cover representation costs and employees can always participate in representation assignments such as meals, social events, and entertainment provided that this has a clear business or professional anchoring in the agency and that the assignment can be deemed reasonable. Travel and accommodation in connection with this type of representation shall always be paid for by Eksfin. The purpose of covering these costs must never unjustly influence or appear to influence the recipient. Costs associated with a spouse’s or cohabitant’s participation in representation assignments are not covered. Such costs must be covered privately.

There are separate guidelines for business trips in Eksfin, which are outlined in the section “Travel” in the Staff Handbook.. The procedure for booking a business trip must be seen in the context of these guidelines and of the state’s travel regulations.

Every employee, and anyone else who provides a service or does work for Eksfin, has a duty of confidentiality in respect of the information that they become aware of in connection with their service or work in respect of Eksfin’s business, employees, business associates, and/or partners.

We will not pass on confidential information to anyone who does not have a material interest in the case, and our business partners should feel confident that Eksfin complies with the rules on confidentiality in the Norwegian Public Administration Act. The duty of confidentiality also applies internally, i.e. in respect of colleagues to the extent that others do not need the information in connection with the performance of their work. The duty of confidentiality shall not prevent employees from informing their superiors of matters that are deemed to conflict with applicable laws and regulations.

All legal and regulatory provisions regarding confidentiality and privacy must be adhered to. It is the individual’s responsibility to ensure that sensitive information is stored in an appropriate manner. The duty of confidentiality also applies after the employment, service, assignment, or position of the person in question has ended. The duty of confidentiality is regulated in the contract of employment and declaration of confidentiality. Information may not be used for one’s own business or in service or work for others.

Personal data concerning employees in the agency, including temporary employees, hired-in staff, board members, and others working for Eksfin or acting on Eksfin’s behalf, in addition to customers, partners, consultants, or others, must be handled in accordance with fundamental privacy considerations and in line with current regulations and internal objectives regarding the handling of personal data so that privacy, confidentiality, and sufficient quality of personal data are all taken into consideration. The procedure for handling personal data in Eksfin provides more detailed rules for this.

All employees must ensure that confidential or sensitive information about customers or Eksfin’s internal affairs is protected by way of proper storage and that written and electronic data is stored securely. The securing of information, archives, and assets belonging to Eksfin and Eksfin’s customers and other business associates is everyone’s responsibility.

Eksfin provides resources and systems to be used to conduct the agency’s day-to-day work. These include materials, technology, procedures, and systems. Eksfin’s employees must protect Eksfin’s property and assets against loss, damage, and misuse. Information produced and stored on Eksfin’s IT systems is, in principle, considered to be Eksfin’s property. Eksfin’s employees are responsible for taking proper care of electronic files and archives.

Private use is permitted only for the handling of ordinary information to a limited extent. Information that may be considered illegal or offensive or which could pose a threat to Eksfin’s systems must not be handled, downloaded, stored, or disseminated under any circumstances.

Inside information is data that is not publicly available or generally known in the market that could be used to substantially influence the price of financial instruments. Inside information must be handled with special care, and the number of people who receive inside information must be as limited as possible. The procedure for handling inside information in Eksfin provides more detailed rules on how employees and others should act when receiving inside information.

Securities must not be traded if this is incompatible with the interests that the employee and board members must safeguard in their work for Eksfin or Eksfin’s business associates, or where such trading may damage public trust in Eksfin. All employees must register their ownership of securities when they start their employment. Employees are responsible for ensuring that the information recorded is up to date at all times. The procedure for employees’ trading in securities describes, among other things, the procedure for reporting own trading. Eksfin shall have a separate procedure for board members.

Eksfin’s employees have a duty to comply with the principles regarding transparency in their work, while also complying with confidentiality requirements. The public has a right of access to Eksfin’s charges log so as to gain insight into the state’s activities. Documents in Eksfin’s loan and guarantee cases are, however, exempt from public access in accordance with § 9, new sixth paragraph of the Norwegian Freedom of Information Regulations. When access is requested to documents that can be legally exempted from public access, it must nevertheless always be considered whether the document can be made public in whole or in part if the information is not subject to a duty of confidentiality.

Eksfin has a duty to disclose information, and Eksfin’s employees must always provide correct and sufficient information, whether this is to other authorities, companies, organisations, or citizens. The most important legal provisions here are the rules on the public’s right of access and open government pursuant to the Norwegian Freedom of Information Act.

Transparency is also a basic prerequisite for internal collaboration within Eksfin and for Eksfin’s reputation. Eksfin’s employees must always provide correct and complete information to their political and administrative superiors.

The CEO, or the person they appoint, is in charge of all contact with the media.

Eksfin wants to encourage open and improvement-oriented dialogue on responsible behaviour. Eksfin’s employees must immediately report any criticisable situations, situations that involve questionable ethics, or situations that breach Eksfin’s ethical principles. Attempts should be made to address the situation internally before blowing the whistle. Employees must be able to blow the whistle anonymously via an external party. Employees and third parties that report possible violations in good faith shall be protected from sanctions.

Eksfin’s employees must always act in accordance with laws and good business ethics and ensure an adequate standard in the handling of cases, and must not discriminate between suppliers and business partners by taking extraneous or arbitrary considerations into account. Compliance with current legislation for public procurement and sales is important for ensuring good business practice.

Eksfin expects all employees to contribute to and uphold good internal co-operation at Eksfin. Eksfin encourages all employees to have open dialogue with their colleagues and ask for help when necessary.

Eksfin shall work actively to promote equality and offer equal opportunities and rights for all. The agency must have a dynamic, attractive, and innovative corporate culture that transcends demographic, ethnic, and individual differences. All employees must respect other people’s dignity, privacy, and rights. Eksfin’s employees shall not contribute to, practise, or experience negative discrimination on the basis of personal circumstances, age, gender, or cultural, religious, or geographical background It is further emphasised that no form of psychological, sexual, or other harassment is tolerated.