Compliance Program


  1. We will carry out our business fairly, honestly and openly.
    (Example: transparent payment terms, clear records)
  2. We will not make bribes, nor will we condone the offering of bribes on our behalf, so
    as to gain a business advantage.
    (Example: no bribes to be paid by agents)
  3. We will not accept bribes, nor will we agree to them being accepted on our behalf in
    order to influence business.
    (Example: careful management of commission payments)
  4. We will avoid doing business with others who do not accept our values and who may
    harm our reputation.
    (Example: careful selection of business partners)
  5. We will set out our processes for avoiding direct or indirect bribery, and keeping to
    and supporting our values.
    (Example: a process for dealing with gifts and entertainment)
  6. We will keep clear and updated records.
    (Example: records of decisions on giving donations or how a demand for a bribe or
    conflict of interest was handled)
  7. We will make sure that everyone in our business and our business partners know our
    (Example: good communication and training; no excuse for not knowing)
  8. We will regularly review and update our Programme and processes as needed.
    (Example: learn from experience and networking with others)
  9. We will keep to these Principles even when it becomes difficult.
    (Example: not paying facilitation payments)


Our business has committed to not giving or receiving bribes. As gifts and entertainment
could sometimes disguise bribes, or be misinterpreted as bribes, we have set out these
rules which clearly define what we consider to be genuine and acceptable and what is not.

We may accept gifts of small items of limited value. We may not accept valuable items.1
Although we may accept a gift now and then, we may not accept gifts which are given regularly or often.
Our business rule is that gifts we give must be of moderate value, legal under local law, and agreed by management.2
Valuable items received as gifts will be returned, or disposed of as agreed by management.3

We may give and accept reasonable, hosted entertainment which is in the legitimate interests of the business.
We will not give or accept lavish or frequent entertainment, or entertainment which is not hosted.4

  1. Y ou may wish to set a limit on the value, e.g. US $30, or to give examples of small gifts such as promotional
    items, flowers or chocolates. Examples of valuable items are gold jewellery, expensive watches or airline tickets.
  2. There are usually laws or regulations on what government officials may accept. It will help you to discuss and decide what gifts to offer customers, rather than to leave it to one individual. Remember your customers may also have a gifts policy.
  3. Sometimes it would be rude to refuse a gift, e.g. at a public event. It helps to have thought about this in advance and to have guidance prepared. In such cases the gift could be accepted, but returned later with a letter of explanation. Alternatively, its value might be donated to charity. The giver should be told what you have done and why, to avoid gifts of value being presented on other occasions.
  4. Where no-one from the business offering the event attends to host guests, e.g. at a sporting event, this is then a gift, not entertainment, and falls under the rules on gifts. There ought to be an element of business involved, e.g. promoting good relations or following a business meeting. Lavish entertainment goes beyond what is appropriate, e.g. weekend accommodation at expensive hotels, and including spouses. It is fine to do this, but each business should pay its own travel and accommodation expenses.





Trúgvi Joensen,

managing director.