Norwegian Energy Company ASA and its affiliates (Noreco) are committed to conducting business with high ethical standards and according to applicable laws, rules and regulations. Noreco’s corporate governance, internal control and operating procedures are designed to detect and prevent misconduct and fraudulent actions. However, if our controls by any chance do not detect or safeguard all possible circumstances, we encourage our own employees, partners, vendors and other stakeholders to always report any suspected fraudulent or unethical behaviour.
Our whistleblowing service is an important tool to foster high ethical standards and maintaining stakeholders and public confidence in us.
Our Whistleblowing Service
Whistleblowing provides an opportunity to report suspicions of misconduct; anything that is not in line with our values and policies. Our whistleblowing service is intended solely for reporting suspected misconduct or irregularities, such as fraudulent, inappropriate, dishonest, illegal or negligent activity or behaviour.
The whistleblowing service should not be used for general complaints or to report on issues related to personal disputes or matters.
Criticisable conditions may be brought to the Noreco’s attention by reporting through the Company’s integrity channel for whistleblowing. The integrity channel is provided and operated by Advokatfirmaet PricewaterhouseCoopers (PwC) and is to be found linked on the corporate website noreco.com as well as on the Noreco intranet.
The integrity channel is available in English, Danish and Norwegian language. Notification can be submitted in any language you prefer.
Your message will be securely handled
We encourage you to report openly by providing your own name and contact details, as all reports are handled with strict confidentiality. However, you may choose to report your concern anonymously. It is also possible for you to remain anonymous towards Noreco while providing your identity to PwC
The system is separate for Noreco’s IT environment and does not track IP addresses or other data that could identify a person sending a message. The communicational channel is encrypted and password-protected and messages will be directly routed, received, and be decrypted by authorised and dedicated personnel in the in the PwC Forensic & Compliance Services.
If it is not possible to submit the Notification through the integrity channel (e.g. due to technical issues or similar), any criticisable conditions may be brought to the Company’s attention by reporting to PwC by e-mail: firstname.lastname@example.org or by phone at +47 93 00 99 77.
Processing of personal data
This section sets out how Norwegian Energy Company ASA and its affiliates (together “Noreco”, “we”, “us”) use, process and store personal data when you use our whistleblowing service.
PwC is data controller for any notification reported through the integrity channel. For their handling of personal data, see the Compliance section when you have entered the integrity channel.
PwC will handle
- Registration of the notification and its receipt
- Confirmation receipt to the whistle blower
- Evaluation and categorisation of the notification, risk assessment and QA including obtaining additional information when required
- Initial response and advise to the whistle blower
PwC will provide a summary report and recommendation for NORECO to decide any further investigation and handling. Anonymous notification will be handled correspondingly in the summary report.
When the summary report is received, Noreco will be the data controller and process any personal data in order to administer and handle the report. Correspondingly if further investigation and handling is to be handled by Noreco. The legal basis for processing of such data is either that processing is necessary for compliance with a legal obligation, or that the processing is necessary for the purposes of legitimate interests pursued by us. The legitimate interest pursued is to conduct business with high ethical standards and according to applicable laws, rules and regulations.
Noreco can also decide to establish a mandate for further investigation and handling by PwC, which then will be handled in PwC’s own corporate case management system.
Personal data is processed for as long as necessary in order to administer and handle the case, or as long as required by law. The report information is handled by Norwegian Energy Company ASA’s EVP People & Capability according to Noreco’s whistleblowing procedure and may be shared with other internal or external resources/entities if necessary due to the nature and content of the report.