CODE OF

CONDUCT

Dear colleague,

Our customers and stakeholders expect us to operate

to a high ethical standard. Our business conduct as
well as our personal conduct must always reflect the
DNV GL Values, demonstrate ethical leadership and
uphold our reputation for integrity.

As a company we need to have safeguarding measures

in place, such as a robust governance structure and
management system. Our Code of Conduct clarifies
what is expected from each of us on an individual level.

You represent DNV GL and the trust that we have

built through 150 years. You need to know the Code
of Conduct and act in line with it. Discuss with your
manager if you feel pressure to act in a way that might
compromise our integrity. Also, I encourage you to
report possible violations of the Code.

The Code is ours, and we all have a responsibility

to live up to its standards – wherever you are and
wherever you go with us in DNV GL.

Sincerely,

Remi Eriksen
President & CEO
DNV GL Group

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The success of a company with global operations
depends on trust at all levels and in all business
environments. DNV GL’s business model is based
upon trust: Trust in the quality of what we do, trust
in the integrity with which we perform, and trust in
the impact and value we deliver.

The Code is not an exhaustive guide covering every

INTRODUCTION situation. Instead it outlines high-level principles in
two main areas: DNV GL’s conduct of its business;
and the personal conduct of people involved in the
business of DNV GL at all levels in the organisation, both in
ordinary work situations and in cases where there are
challenges to their personal or professional integrity.

You are expected always to exercise your best

Our success depends on trust. judgment, care and consideration in your work for
This is why we have a Code of Conduct. DNV GL. The Code is designed to offer guidance
and encourage you to make the right choices as you
perform your duties.

The success of a company with global operations DNV GL is a signatory to the United Nations Global
depends on trust at all levels and in all business Compact. We are committed to adhering to its prin-
environments. DNV GL’s business model is based ciples in the areas of human rights, labour standards,
upon trust: Trust in the quality of what we do, trust environmental protection and anti-corruption in our
in the integrity with which we perform, and trust in business strategy, day-to-day operations, organisa-
the impact and value we deliver. tional culture and sphere of influence.

Trust can only be achieved if we persistently maintain Further reference: www.unglobalcompact.org/

high standards of business and personal conduct. AboutTheGC/TheTenPrinciples/index
Our Code of Conduct (hereinafter “Code”) is built on
DNV GL’s Values. The purpose of the Code is to ensure
that all of DNV GL’s services and activities are carried out in Our Vision
compliance with all applicable laws and regulations. In
the event that the Code differs from applicable laws Global impact for a safe
and regulations, the highest standard consistent with and sustainable future
local laws must be applied.

Moreover, the Code provides a framework for what we Our Values

consider ethical, responsible and sustainable conduct:
Conduct which will make a positive contribution towards ■ We build trust and confidence
our ambitions and Vision as a company. The require- ■ We never compromise on quality or integrity
ments and expectations set out, together with our ■ We are committed to teamwork and innovation
Values, constitute the basis of our corporate activities. ■ We care for our customers and for each other
■ We embrace change and deliver results

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SCOPE AND
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COMPLIANCE
RESPONSIBILITY WITH LAWS, RULES
AND REGULTIONS

The Code applies to everyone involved We must observe the laws of the
in the business of DNV GL. countries where we operate.

This Code of Conduct applies to all employees of DNV With operations and subsidiaries in more than 100
GL Group AS and its subsidiaries (hereafter “DNV GL” countries, DNV GL is obligated to observe the various
or “the Group”), as well as to temporary employees, legal and cultural frameworks of those countries.
hired contractors acting on behalf of the Group, and You are expected to know relevant local laws and
anyone who holds a position of trust in the Group, maintain generally accepted customs insofar as they
including the Board of Directors and its sub-committees are compatible with the principles in the Code.
(in the following referred to as “You”).
Even allegedly minor breaches of law during business
You are responsible for reading and understanding the activities can result in major damage to business
content of this Code and related documents, and must partners, customers and DNV GL, as well as seriously
conduct your tasks and responsibilities for DNV GL in jeopardise our good reputation. Violating laws and
accordance with the requirements and principles that other binding regulations may also have far-reaching
are set out. You must not act or encourage others to act consequences in terms of labour and penal law.
contrary to this Code, even if such deviations under the
circumstances may appear to be in the commercial inter- In addition to compliance with law, you must adhere
est of yourself, your business unit or DNV GL as a whole. to internal rules and regulations, including the
If it is not clear whether a particular activity is legally DNV GL management system.
or ethically acceptable, you should consult with your
immediate line manager, the Compliance Officer,
the Legal Department, the HR Department or the
internal DNV GL Ombudsman.

As a global company, we face local individual, cultural or

administrative practices that may be contrary to the spirit
and provisions of the Code. Nevertheless, violations of
the Code will not be tolerated and may lead to internal
disciplinary actions, dismissal, or even criminal prosecution.

It is the responsibility of the DNV GL executive manage-

ment and all line managers to make the Code known
to employees and to promote and monitor compliance
with the Code in their organisation.

This is a governing document of DNV GL, subject to

copyright.

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 4.3 Fair and open competition

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DNV GL’s policy is to compete vigorously and fairly,
in full compliance with all applicable antitrust and
competition laws. Commercial policy and pricing will
be set independently and will never be agreed upon
with competitors or other non-related parties.

Agreements with competitors, or any other activities

CONDUCT which unduly obstruct free and open competition,
influence prices, or allocate business areas, geogra-
OF BUSINESS phies or clients, are not allowed.

You must not schedule or accept meetings with

competitors without an agenda and minutes of meet-
ings being made. During meetings with competitors,
it is not allowed to exchange internal data such as
Our ability to create value depends on prices, costs and customer information.
exercising high ethical standards in all our
dealings with colleagues, partners, suppliers Legally protected information, as well as information
and other stakeholders of DNV GL. that is relevant for competition, must not be disclosed
to third parties.

4.4 Corruption
4.1 Quality of our services DNV GL must conduct its business in a fair and trans-
DNV GL’s services to customers must meet the highest parent manner. There is a zero tolerance policy against
standards of quality and integrity. Our customers corruption and trading in influence. Corruption or
should have trust in what we deliver, and be met bribery is the abuse of a position of trust to acquire
and treated with respect, enthusiasm, openness personal or business benefits for DNV GL, yourself or
and a willingness to collaborate. You must undertake others without being legally entitled to these benefits.
all services professionally and in accordance with Trading in influence exists when an improper benefit is
agreed rules, standards, methods and policies. provided to someone in order indirectly to influence the
performance of the duties of a third party (for instance
You must maintain your impartiality and independent a relative, an acquaintance or others with access to a
judgment, and never surrender to pressure and/or potential business partner or decision maker).
inducements to misrepresent findings or to alter
certificates, the results of inspections, audits or tests. This prohibition applies both to the party giving or
The information in reports and certificates that are offering an improper benefit, and to the party who
issued must be truthful and accurate. All work, find- requests, receives or accepts such advantage. For
ings and results should be adequately documented. the matter to be considered illegal, it is sufficient that
a demand or an offer of improper benefit is made.

4.2 Avoiding conflict of interest Any behaviour which might cause the suspicion of
DNV GL must avoid conflicts of interest and any bribery or trading in influence is forbidden. This applies
combination of roles and services that could be in particular to the use of irregular ways of payment.
perceived as representing a threat to the impartiality
and independence that are the basis for our services.
This requires a professional, independent and 4.5 Gifts and hospitality
impartial treatment of job-related tasks. No presents or bonuses which have the effect of or
even the appearance of impacting or impairing the
In particular, we do not class, certify or verify ability to reach an independent decision should be
our own work. accepted from or given to clients or business partners.
Excepted are modest gifts for special occasions,
or advertising gifts, as well as invitations that involve
a business purpose. Giving or accepting monetary
gifts is prohibited under any circumstances.

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Regardless of value, benefits must not be offered DNV GL works to ensure a safe and healthy work
to anyone if such benefits are intended to affect the environment for all employees. Health and safety
outcome of business transactions. Correspondingly, functions are established in all offices, and basic
you must not accept such benefits from DNV GL’s HSE training is mandatory for all employees.
business contacts or persons or companies
connected to them. DNV GL values dialogue and has broad geographic
employee representation in the Board of Directors
of the holding company of the Group. DNV GL
4.6 Sponsorships and contributions management will work constructively with employee
DNV GL upholds a strict policy of neutrality in the organisations through the Global Employee Forum
political process of any country where it operates. (GEF), regional and local work councils, and in daily
DNV GL does not contribute funds or resources operations.
to any political party, elected official or candidate
for public office in any country. All employees have the right to express their views and
concerns in good faith, in accordance with this Code.
In some instances, DNV GL offers charitable dona- All employees have the right to join labour union(s)
tions, sponsorships or other forms of contributions and participate in organised activities.
under strict guidelines.

4.9 Environmental stewardship

4.7 Relations with intermediaries and business The Group works to reduce the environmental impact
partners of its own operations, procurements, investments and
The principles of this Code are also applicable property management. As the world faces unprece-
to intermediaries and partners. dented environmental challenges, we take our impact
on the environment seriously and see it as our respon-
If DNV GL uses intermediaries, including agents, sibility to help change this course.
sponsors and consultants to promote its services,
these must be selected based upon their substan- DNV GL will minimise its emissions and consumption of
tiated commercial value for the Group. The scope energy and natural resources, and will actively contribute
of services to be provided should always be clearly to environmental protection by promoting the devel-
stated, payment mechanisms should be transparent, opment and propagation of environmentally friendly
and the size of the payment should be proportional technologies. DNV GL will support employees in the
to the level of services provided. reduction of their personal environmental footprint.

In some jurisdictions, there are legislative or admin-

istrative requirements that DNV GL must cooperate 4.10 Confidentiality
with or use the services of local business partners When taking up work with DNV GL, all employees
or sponsors. The requirements set out in this clause and subcontractors must sign a declaration of secrecy.
apply to such agreements as well. You must comply with applicable copyright laws and
confidentiality obligations. Data and information
must always be handled in a manner that protects
4.8 Good working environment the interests of DNV GL and our customers.
DNV GL is committed to protecting and advancing
the health and well-being of its employees worldwide. Both during the term of your employment and
afterwards, company and business secrets must
DNV GL strives for diversity at all levels of the organisa- be protected from being divulged to unauthorised
tion and is firmly committed to providing equal oppor- persons. This includes not only the company’s
tunity in all aspects of employment. DNV GL will treat all internal interests but any information which concerns
employees fairly and with respect, and will not tolerate DNV GL customers and their business matters.
any form of discrimination or harassment on the basis
of gender, religion, race, national or ethnic origin,
cultural background, social group, disability, sexual
orientation, marital status, age or political opinion.

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4.11 Accurate and complete data, records,
reporting and accounting
DNV GL is committed to transparency and accuracy
in all of its dealings. This includes compliance with
generally accepted accounting principles at all times.
All accounting records must also be kept and pre-
sented in accordance with the laws of the applicable
jurisdiction.
PERSONAL
4.12 Information and IT systems CONDUCT
You are not allowed to use information in a way
that may jeopardise the integrity of DNV GL.

Information considered illegal, offensive or inappro-

priate must not be accessed, processed, downloaded,
stored or disseminated on your work computer.
We are expected to conduct ourselves and
Installing software or downloading, storing, using our business with respect and sensitivity.
or disseminating data or information in breach of
copyright laws or provision is prohibited. Material
of sexual nature is considered inappropriate.
5.1 We value independence
You must not, directly or indirectly, accept gifts which
4.13 Internal monitoring systems are intended for influencing business decisions, except
Internal controls are an integral part of DNV GL’s for promotional items of minimal value normally bearing
ongoing business activities and ensure that we a company logo. You may accept other gifts in situations
adhere to the applicable laws and internal regulations. where it would clearly give offense to refuse, in which
Their purpose is to allow the continuous inspection case the gift must be handed over immediately to your
and improvement of all company procedures. We will line manager and will be regarded as DNV GL property.
ensure that our monitoring system is suitable and
meets all applicable legal requirements. Hospitality, such as social events, meals or entertain-
ment can be accepted if there is a clear business
reason for DNV GL.
4.14 Risk management
Taking risks can not only jeopardise the reputation
and business success of DNV GL, but result in damage 5.2 We value impartiality and integrity
to clients, business partners and colleagues. In order to You must not, at any time, participate either directly
identify and minimise potential risks at an early stage, or indirectly in any kind of business or activity that com-
and to avert potential damage, DNV GL has a risk petes with or is detrimental to the interests of DNV GL.
management policy and process in place for the Group. The same is true if it has the effect or the appearance
of affecting the impartiality and integrity of DNV GL
or yourself. You may not use corporate property,
information or your position for personal gain.

If you wish to hold a position on the board, or perform

a similar function in the governing body, of a company
or institution of a commercial nature external to the
DNV GL Group, you must first obtain the approval
of your line manager. If the company or institution
could be perceived as a competitor to DNV GL,
such a role must be approved by the Group CEO.

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You must not have any financial or other interest, 5.4 We use company property and assets
directly or indirectly, in any business or activity that appropriately
the fact of your having such an interest could call into The use of DNV GL’s materials, financial assets or
question your or DNV GL’s integrity and impartiality. facilities for purposes not related to DNV GL’s business
is prohibited unless it is specifically approved by
You cannot be involved in a recruitment decision management in other DNV GL documentation, or
concerning your immediate family. Immediate family authorised by a manager who has the authority to do so.
members will not be employed in, or remain in,
closely related positions, where a possible conflict Private use of DNV GL personal computer systems
of interest may occur, or where one may become is allowed, as long as it does not expose DNV GL to
aware of confidential information affecting the other. litigation or negative consequences, interfere with
For the purpose of the Code, “immediate family” job duties, breach DNV GL policies and instructions,
is defined as your father, mother, spouse/fiancée/ or degrade the performance of the DNV GL systems
co-habitant, child, brother or sister, or the father, or networks.
mother, child, brother or sister of your spouse/
fiancée/co-habitant.
5.5 We communicate transparently and honestly
The DNV GL brand-profile in domestic and interna-
5.3 We treat each other with dignity and respect tional markets is greatly influenced by our ability to
In DNV GL, we treat each other with mutual respect and communicate consistently and professionally with
dignity. Respect is at the heart of building a success- external parties, including the media. In DNV GL,
ful cooperation between the Group and each of us. we maintain a principle of openness and are honest
Business and personal decisions will be taken in and responsive when dealing with interested parties.
accordance with the general policy of equal treatment
as defined by objective, comprehensible criteria. To build and protect the DNV GL brand and image,
the Group President & CEO and business area
You must not discriminate or be discriminated against, CEOs will represent DNV GL in instances when
i.e. placed at a disadvantage for no objective reason, a senior management presence would be beneficial.
on the basis of race, gender, age, nationality, ethnic Communication professionals in Group Communica-
background, skin colour, political opinion, sexual tions and in the global communication departments
orientation, religious beliefs, marital status, physical in the business areas are the designated spokes-
constitution or other personal characteristics. persons. In addition, when assigned by Group or
business areas communications, managers and
DNV GL will not tolerate personal insults or any other technical experts may take on a spokesperson role
form of harassment, including sexual harassment, in related to their responsibilities.
the workplace. Sexual harassment includes all forms
of unwelcome verbal, nonverbal or physical conduct When participating in social media either as an
of a sexual nature. Demeaning comments about an identified employee of DNV GL Group or concerning
employee’s appearance, questions or comments DNV GL business or topics, it is important that you
about his or her sex life, sexual coercion and un- state that you are expressing a personal opinion,
desired sexual acts are prohibited. or clearly state that you are affiliated with the
DNV GL Group. If you comment on any aspect of
DNV GL is against the purchase of sexual services. DNV GL business or issues, you must clearly include
When representing DNV GL, you must refrain from a disclaimer that the views are your own and not
purchasing sexual services. those of DNV GL.

You are legally responsible for your postings,

unless the posting has been specifically approved
by authorised management. You should remember
that you may be subject to liability if your posts are
found to be defamatory, harassing or in violation
of any other applicable law.

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REPORTING OF
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BREACHES
MISCONDUCT OF THE CODE

You are encouraged to report Violations of the Code may result in disciplinary
possible violations of the Code. procedures, including termination of employment
or contract, as well as potential legal proceedings.

You are required to cooperate in good faith with

Openness and discussion about ethical conduct is any internal investigations relating to this Code.
important to DNV GL. You are therefore encouraged
to report concerns related to possible violations of the
Code, as well as any other violations of law or company
policy. Serious violations, such as cases of corruption
and bribery, must be reported immediately. Reporting

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is a key part of ensuring that individual and systematic
challenges to our business model and ethical require-
ments are handled in the appropriate manner.

In most cases, concerns about possible breaches

of the Code should be reported directly to your line
manager. Most cases can and should be handled
locally in the line organisation, or be referred to
the Compliance Officer.
QUESTIONS
You may also report your concerns directly to a
DNV GL Ombudsman. DNV GL has an internal as
well as an external Ombudsman. All contacts with
the Ombudsmen will be treated anonymously at If you have any questions on the content of this Code,
your request. please contact your line manager, the Compliance
Officer, the HR Department or the internal DNV GL
The Ombudsmen report violations under the Ombudsman.
Code of Conduct directly to the Compliance Officer.
The Compliance Officer will thoroughly investigate
and clarify the reported violations with the support
of the respective operational management and in
close collaboration with the Ombudsmen.

If a concern is expressed relating to a possible Note: At all times, the version of the Code of Conduct found in
the DNV GL Management System (document DMSG-0-2 DNV GL
violation of the Code in good faith to sources inside
Code of Conduct) is the current version of this document.
or designated by DNV GL, DNV GL will not permit
retaliation in any form. ©DNV GL 08/2014