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Code of Conduct

As a group, Aneo cannot do right or wrong. It is WE, the employees of Aneo, and the sum of our actions that determine whether the Aneo acts lawfully and ethically as a group.

That’s why each and every one of us has a personal responsibility to act in accordance with the group’s rules on ethics and corporate social responsibility, as formulated in this document. These rules reflect our values – OPEN-COURAGEOUS-RESPONSIBLE – and our common cultural platform.

Aneo’s rules on of ethics and corporate social responsibility, contained in its Code of Conduct, apply to anyone who works at Aneo or otherwise represents Aneo, i.e., all employees, temporary workers, members of the board of directors, consultants and others engaged to represent the group. The Code of Conduct automatically applies to all Aneo’s wholly-owned subsidiaries. In partly-owned companies, they apply if they have been approved by the company’s board of directors.

The Code of Conduct is binding and there is no procedure for deviating from its stipulations. Violation of the rules may have consequences for your employment or commitment to Aneo, and may ultimately also entail a risk of civil liability and a police report/penalty.

Duty to comply with external and internal regulations

At Aneo, we must always comply with the laws and regulations that apply to our business.

This means that you have a responsibility to comply with the laws and regulations that apply to your work tasks and behaviour when you are at work or otherwise acting as a representative of Aneo. It also means that you must stay informed about the laws and regulations that apply to your field and seek advice from your manager or the Legal Department when in doubt. Licences and other public permits are equated with laws/regulations, and the obligations they entail must also always be followed.

At Aneo, WE must always act in accordance with applicable governing documents

Just as with external laws and regulations, you must familiarise yourself with the internal governing documents that apply to you and ensure that you comply with their stipulations.

Aneo managers have a special responsibility

Managers at all levels of Aneo have a special responsibility to know the rules that apply, to guide their employees, to monitor compliance within their organisation, to respond to infringements, and to lead by example.

Duty to act in an ethically responsible manner 

At Aneo, WE must always act in a professional, commercially viable, honest, and ethical way.

Certain actions may be permissible according to both external and internal rules, but may nevertheless be ethically questionable or indefensible. In such cases, you have a duty to stop and clarify whether what you intend to do is in line with Aneo’s values and this Code of Conduct.

Ethical grey areas can threaten the reputation of Aneo or the employee themselves. They may also entail a risk that could we fail to treat affected parties with due respect, consideration or care.

It is therefore important that you stop and discuss the issue with your manager if you are in doubt. You can also seek advice from the Legal Department.

Duty to act in a socially responsible way

At Aneo, WE take responsibility for ensuring sustainable value creation for our owners, the local communities in which we operate, our employees, and society at large.

WE, the employees of Aneo, are guided by honesty, business acumen, and due regard for our partners, suppliers, customers and our surroundings in general.

WE take responsibility for the social consequences of our operations, both in terms of environmental impact, working conditions and social conditions.

This responsibility spans our entire value chain, from purchasing and investment to our sales activities with regards to consumers and businesses.

WE must always seek to ensure that any negative consequences of our business are limited to an acceptable minimum and that we implement remedial measures where required.

WE must always respect the UN’s Universal Declaration of Human Rights and the fundamental rights of our employees as expressed through ILO conventions, the Working Environment Act, and collective agreements. WE reject social dumping and must ensure that both all Aneo’s employees and those of our suppliers have decent working conditions. WE must work proactively to ensure diversity in our operations and never discriminate against anyone on the basis of gender, sexual orientation, ethnic or cultural background, political views, disability or age.

WE reject prostitution.

As an employee or representative of Aneo, you must never purchase sexual services while at work, on assignment, or travelling on behalf of Aneo.

Rules of personal conduct

WE, the employees of Aneo, are consistently loyal and professional, without allowing personal interests to guide our actions.

As an employee or representative of Aneo, you are obliged to be loyal to Aneo. This includes following orders from your superiors, observing your duty of confidentiality regarding trade secrets and other matters you know or understand to be confidential, respecting decisions, and otherwise refraining from doing anything that might conflict with the interests of the group.

Your decisions and actions on behalf of Aneo must be commercially justified and be influenced neither by your own personal interests in the matter, nor by those of people close to you. If a situation arises in which you or someone close to you has a personal interest in the outcome of a decision or action (a conflict of interest), you must notify your manager, refrain from further involvement in the process/decision in question, and allow someone else to take your place. You must also do this if the specific circumstances could create the impression that you or a close associate have a personal interest in the outcome of a matter. As an employee or representative of Aneo, you must not partake in events, hospitality, or travel that are not closely related to Aneo’s business, run contrary to good business practice, or which are unjustifiably expensive. Likewise, you must not invite others to do so.

You must always obtain your manager’s approval before inviting anyone to partake in an event, travel, or hospitality at Aneo’s expense and before partaking in an event, travel, or hospitality paid for by anyone other than Aneo.

As an employee or representative of Aneo, you must never give or receive gifts that are contrary to good business practice or that are unjustifiably expensive. As a rule of thumb, gift should be worth no more than NOK 300.

You must always obtain your manager’s approval before giving or receiving a gift in your capacity as an Aneo employee or representative, regardless of the value of the gift. Be aware that in certain cases, discounts and other financial benefits can be just as problematic as gifts. Contact the Legal Department if you have any doubts.

If you are involved in a negotiation, investment or procurement process, or are in a position to influence the outcome of such a process, you must never receive or give gifts, favours, travel or hospitality – of any value – if such a process is imminent or ongoing. Travel, hospitality, etc. in connection with a negotiation, project or investment must always be paid for by Aneo itself.

You must never offer a contractual counterparty, public employee or others anything of economic value, or any other improper advantage in order to influence an issue to your own benefit or that of TrønderEnergi. Nor may you elicit or assist in such actions. You must also never receive or invite the opportunity for yourself or a close associate to receive a bribe or improper advantage in exchange for influencing the outcome of a case for the giver’s benefit.

Aneo is a drug-free workplace. You must never consume alcohol or drugs or be under their influence while working for Aneo. When representing Aneo at social events, it is permissible to enjoy alcohol if this is customary and your alcohol consumption is restrained.

Reporting and notification

At Aneo, WE take responsibility for reporting censurable conditions and violations of internal and external rules.

Aneo wishes to correct any situation that involves a breach of external or internal rules. All employees and representatives of Aneo are therefore encouraged to speak up if censurable conditions and breaches of internal and external rules are observed. The same applies if you are concerned – but not certain – that something censurable or illegal could be going on.

Managers always have a duty to report censurable conditions and violations of internal and external rules. Such notifications should normally be addressed to your immediate superior, or alternatively to the Legal Department.

Pursuant to the Working Environment Act, all employees are obliged to report conditions that entail a risk to life and health, as well as certain criminal offences. This means that such circumstances must always be reported.

Concerns about censurable conditions and rule violations should generally be raised with your manager. If you are not comfortable raising the matter with your manager, you can contact your manager’s manager, or the Legal Department. If you are not comfortable raising the matter with any of these parties, you can notify the Chair of the Board of Directors.

Anyone who reports censurable conditions has special protection under the Working Environment Act, and should be able to be confident that the notification will not lead to retaliation from the employer or the person to whom the notification relates. Aneo must have procedures in place to ensure that retaliation does not occur and that notifiers are given the protection to which they are legally entitled.


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