Nordic Semiconductor’s Anti-corruption Policy
"Nordic Semiconductor is firmly committed to conduct business with high ethical business practices, without any form of bribery or corruption involved in the execution of any of our business activities. Nordic Semiconductor has adopted an anti-corruption program with the purpose of preventing, detecting and addressing bribery and corruption throughout our business activities wherever we operate."
Our Anti-Corruption policy applies to all persons and entities working for or on behalf of Nordic Semiconductor.
Our anti-corruption program
The Anti-Corruption program of Nordic Semiconductor is rooted in our Anti-Corruption policy and based on principles drawn from the United States Foreign Corrupt Practices Act, the United Kingdom Bribery Act and other relevant national legislations in addition to the standard ISO 37001 for anti-bribery management systems.
The main measures of our program are outlined below:
Commitment at all levels
At Nordic Semiconductor, we have a zero tolerance for any corruption and bribery and are committed to comply with all applicable laws and regulations and to act professionally and with integrity in all our business activities. To support the organization to meet legal requirements, internal policies, and procedures as well as stakeholder expectations, Nordic Semiconductor has a corporate compliance framework. Our Anti-Corruption program is part of this overall framework.
The Board of Directors of Nordic Semiconductor, through the Board Audit Committee, provides the ultimate oversight of the overall compliance framework of Nordic Semiconductor, including its programs.
The Executive Management Team of Nordic Semiconductor is committed to the overall compliance framework and approves the Anti-Corruption policy.
The overall corporate compliance framework and the Anti-Corruption program is managed by the Group Compliance Officer of Nordic Semiconductor ASA, and responsible for maintaining the program, including providing relevant advice and awareness training and communication to the organization. The Group Compliance Officer meets with the Board Audit Committee as well as the Nordic Semiconductor Executive Management Team on a regular basis to report and discuss the efficiency of its programs.
Managers of Nordic Semiconductors are responsible for demonstrating commitment to the overall compliance framework, including the Anti-Corruption program, in the execution of business on a daily basis.
Employees of Nordic Semiconductor are responsible for understanding how relevant policies and procedures relate to their daily work and comply with them.
Risk assessments
Corruption risks are part of the risks which is continually monitored and evaluated as part of the Nordic Semiconductor corporate level risk management process to ensure the identification and execution of relevant actions as well as a fit-for-purpose Anti-Corruption program.
Relevant policies & procedures
In addition to our Anti-Corruption policy, we have more practical procedures to support employees in identifying and managing particular risk areas such as: conflict of interest, gifts & hospitality as well as donations, social investments & political contributions.
Internal controls
To mitigate corruption and bribery risks, Nordic Semiconductor aims to implement relevant internal controls such as ensuring segregation of duties as well as clear delegation of authority in relevant processes in addition to have proper governance for financial accounts and documentation.
Due diligence of business partners
Nordic Semiconductor perform due diligence of relevant business partners to enable identification and mitigation of corruption and bribery risks related to third parties.
Communication & Training
We believe that clear guidelines and targeted training will enable our employees to make sound ethical decisions. We therefore aim to provide a variety of risk-based trainings on a regular basis to employees across our organization.
Management of incidents
Nordic Semiconductor encourage a transparent dialogue in the organization for solving dilemmas that may occur in the execution of business with support of managers as well as supporting functions. However, to facilitate reporting of potentially illegal and/or unethical acts, such as fraud, bribes or other types of corruption, we have established a Whistleblower system for the receipt, follow-up and investigations of whistleblower reports.
We have a zero tolerance for any retaliation against whistleblowers for raising a genuine concern and in a proper manner provides information about potential conditions or misconducts that may be a breach of applicable legislation or internal policies or procedures.
Monitoring
The adequacy and efficiency of our Anti-Corruption program is part regular follow-up of the overall compliance framework and annual wheel of the Board Audit Committee, and the regular Management Review of the Executive Management Team of Nordic Semiconductor.
We are dedicated to a culture of integrity to ensure that our success comes from ethically sound business decisions throughout our organization. As of 2022, we aim to measure employee perception of internal culture of integrity through regular surveys.
Collective actions
Although our own actions are critical, we believe that collective actions are required in the fight against corruption. Being part of collective actions is a very important part of our Anti-Corruption Program; these are some of the initiatives we are committed to:
Responsible Business Alliance (RBA)
Responsible Business Alliance (RBA) is the world’s largest industry coalition dedicated to corporate social responsibility in global supply chains. Nordic Semiconductor ASA is a member of RBA and has since 2007 followed the RBA Code of Conduct. For more information on the RBA and its work, visit www.responsiblebusiness.org
UN Global Compact
Nordic Semiconductor has committed to the UN Global Compact Ten Principles since 2016. By incorporating the Ten Principles of the UN Global Compact into Nordic Semiconductor’s strategies, policies and procedures, we have ensured that the foundation is in place for sustainable business operations and long-term success. For more information on the Ten Principles and UN Global Compacts work, visit www.unglobalcompact.org
