Financial Crime World

Norwegian’s Financial Crime Policy: A Regulatory Landscape Shift

Introduction

As the regulatory landscape continues to shape the financial sector, Norwegian has updated its Financial Crime policy to ensure compliance with anti-corruption laws and protect the company from financial crimes.

Standard Contract Provisions for Compliance

  • All written agreements with third parties must include standard contract provisions that ensure compliance with anti-corruption laws.
  • These provisions require transparency in business dealings and prohibit corrupt practices such as bribery and embezzlement.

Monitoring and Reporting Financial Crime

  • Norwegian conducts an annual corruption risk assessment to identify potential vulnerabilities and ensures adherence to the Financial Crime policy.
  • The company’s Board of Directors owns the policy and conducts in-depth investigations into reported violations.
  • Any breaches of the policy, including financial crimes such as bribery, money laundering, and violations of international sanctions, may result in criminal penalties for individuals and the company alike.

Confidentiality and Data Protection

  • All employees are obligated to protect the confidentiality of company information and keep all matters confidential that could provide third parties unauthorized access to confidential information.
  • Norwegian has implemented a privacy standard that aims to establish an internal control system containing legally binding principles for the processing of all personal data within the company, in accordance with the EU General Data Protection Regulation 2016/679.

Investment and Securities Trading

  • Company policy prohibits employees and their family members from trading securities while in possession of material, non-public information relating to the company or any other company.
  • Employees are encouraged to invest in Norwegian securities, but must obtain clearance in advance of any contemplated securities transactions from the company’s representative in charge of insider trading matters or the Board.

Reporting Financial Crime

  • All individuals associated with Norwegian are obligated to report any breaches of the Financial Crime policy.
  • Violations should be reported via the company’s whistleblowing procedure, facilitating confidential internal reporting. Alternatively, reports can be made to superiors, HR, managers, union officials, or safety representatives.

Compliance and Enforcement

  • The company ensures confidential, impartial, and timely handling of all reports, following its established Complaints Procedure.
  • Any breaches of the policy may result in disciplinary actions, including potential dismissal or contract termination.

Conclusion

As the regulatory landscape continues to evolve, Norwegian remains committed to maintaining a robust Financial Crime policy that protects the company from financial crimes and ensures compliance with anti-corruption laws.