Company Stresses Importance of Compliance with Financial Crime Policy

Norwegian has emphasized the need for employees to adhere to its Financial Crime policy, aimed at preventing and detecting financial crimes such as bribery, money laundering, and violations of international sanctions.

Code of Conduct

The company’s Code of Conduct outlines strict guidelines for employees on how to conduct themselves when dealing with business partners, customers, suppliers, and competitors. The code prohibits:

• Acceptance or offering of illegal or inappropriate gifts
• Any form of corrupt payment

Due Diligence

Norwegian emphasizes the importance of conducting due diligence on all business partners, including:

• Screening for sanctions
• Ownership structure
• Adverse media
• Reporting any knowledge or suspicion of money laundering promptly

Conflict of Interest Policy

The company has implemented a Conflict of Interest policy to ensure that employees prioritize the company’s interests over personal gain. Employees are required to disclose:

• Any potential conflicts of interest
• Obtain pre-approval from their manager for any directorships or assignments outside the company

Prohibition on Anti-Competitive Conduct

Norwegian prohibits employees from participating in or contributing to:

• Violations of general or specific competition regulations
• Illegal cooperation on pricing, illicit market sharing, or other actions contravening relevant competition laws

Accurate Financial Reporting

The company is committed to providing accurate and timely financial reporting. This includes:

• Ensuring that all accounting and financial information is accurately registered and presented in accordance with laws, regulations, and relevant accounting standards
• Providing accurate disclosure information to the financial market in a fair and transparent manner

Privacy and Data Protection

In addition to its Financial Crime policy, Norwegian has implemented a privacy standard aimed at protecting personal data of customers, employees, and other third parties. The company ensures that all personal data is:

• Processed fairly and lawfully for legitimate purposes only
• Kept confidential, accurate, up-to-date, and stored in a secure way

Reporting Violations of Financial Crime Policy

Norwegian encourages all individuals associated with the company to report any breaches of its Financial Crime policy through its established whistleblowing procedure. Reports can be made:

• Confidentially
• Anonymously
• Ensuring that incidents are handled impartially and timely

The company takes any violations of its Financial Crime policy seriously, including bribery, money laundering, and violations of international sanctions. Such offenses may result in criminal penalties for individuals and the company alike, as well as immediate disciplinary actions, including potential dismissal or contract termination.