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. If you see or know of possible
violations of the Code, I encourage you to report them.

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 Code is not an exhaustive guide covering every
situation. Instead it outlines high-level principles in
two main areas: how DNV GL conduct its business;
and the personal conduct of people involved in the
business of DNV GL at all levels in the organization,
both in ordinary work situations and in cases where
there are challenges to their personal or professional
integrity.
INTRODUCTION You are expected always to use your best judgment,
care and consideration in your work for DNV GL. The
Code is designed to offer guidance and encourage you
to make the right choices as you perform your work.

DNV GL is a signatory to the United Nations Global

Our success depends on trust. Compact. We are committed to adhering to its prin-
This is why we have a Code of Conduct. ciples in the areas of human rights, labour standards,
environmental protection and anti-corruption in our
business strategy, day-to-day operations, organiza-
tional culture and sphere of influence.
DNV GL’s business model is based upon trust: Trust
in the quality of what we do, trust in the integrity with Further reference: www.unglobalcompact.org/what-
which we perform, and trust in the impact and value is-gc/mission/principles
we deliver. Our success depends on trust at all levels
and in all business environments.

Trust can only be achieved if we persistently maintain Our Vision

high standards of business and personal conduct.
Our Code of Conduct (hereinafter “Code”) is built on A trusted voice to tackle global transformations
DNV GL’s Values. The purpose of the Code is to ensure
that all of DNV GL’s services and activities are carried out Our Values
in compliance with all applicable laws and regulations.
In the event that the Code differs from applicable laws ■ WE CARE
and regulations, the highest standard consistent with We care for each other, our customers,
local laws must be applied. our planet, and we take care of ourselves.

■ WE DARE
Moreover, the Code provides a framework for what we
We dare to explore, to experiment, to be
consider ethical, responsible and sustainable conduct: different, and to be courageous, curious and
Conduct which will make a positive contribution towards creative.
our ambitions and Vision as a company. The require-
ments and expectations set out, together with our ■ WE SHARE
Values, constitute the basis of our corporate activities. We share our experience and knowledge.
We collaborate with each other and our
customers, and we continue to grow and
develop as a result.

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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 GL With operations and subsidiaries in almost 100
Group AS and its subsidiaries (hereafter “DNV GL”), countries, DNV GL is obligated to observe the various
as well as to temporary employees, hired contractors legal and cultural frameworks of those countries.
acting on behalf of DNV GL, and anyone who holds You are expected to know relevant local laws and
a position of trust in DNV GL, including the Board of maintain generally accepted customs insofar as they
Directors and its sub-committees. are compatible with the principles in the Code.

You are responsible for reading and understanding the Even allegedly minor breaches of law during business
content of this Code and related documents, must activities can result in major damage to our business
conduct your tasks and responsibilities for DNV GL in partners, customers and DNV GL, as well as seriously
accordance with the requirements and principles that jeopardize our good reputation. Violating laws and
are set out in the Code. You must not act or encourage other binding regulations may also have far-reaching
others to act contrary to this Code, even if such devia- consequences in terms of labour and penal law.
tions may under the circumstances appear to be in the
commercial interest of yourself, your business unit or In addition to compliance with law, you must adhere
DNV GL as a whole. If it is not clear whether a particular to internal rules and regulations, including the
activity is legally or ethically acceptable, you should DNV GL management system.
consult with your 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 senior manage-

ment and all line managers to make the Code known
to employees and to promote and monitor compliance
with the Code in part of the organization.

This is a governing document of DNV GL, subject to

copyright.

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4.3 Fair and open competition
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 independ- a relative, an acquaintance or others with access to a
ent judgment, and never surrender to pressure potential business partner or decision maker).
and/or incentives 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 classify, 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 to DNV GL works to ensure a safe and healthy work
anyone if such benefits are intended to affect the out- environment for all employees. Health and safety
come of business transactions. Similarly, you must not functions are established in all offices, and basic
accept such benefits from DNV GL’s business contacts HSE training is mandatory for all employees.
or persons or companies connected to them.
DNV GL values dialogue and has broad geographic
employee representation in its Board of Directors.
4.6 Sponsorships and contributions DNV GL management will work constructively with
DNV GL upholds a strict policy of neutrality in the employee organizations through the Global Employee
political process of any country where it operates. Forum (GEF), regional and local work councils, and
DNV GL does not contribute funds or resources in daily 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 organized activities.
under strict guidelines.

4.9 Environmental stewardship

4.7 Relations with intermediaries and business DNV GL 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 minimize its emissions and consumption of
tiated commercial value for DNV GL. The scope of energy and natural resources, and will actively contribute
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.
to the level of services provided.

In some jurisdictions, DNV GL must cooperate with 4.10 Personal data and confidentiality
legislative or administrative requirements and use We will protect confidential, secret, and personal data.
the services of local business partners or sponsors. This is one of the key principles on which we base our
The requirements set out in this clause apply to such relationships with our employees, customers, and
agreements as well. suppliers. You must obey personal data protection
requirements, as well as statutory and company rules.

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

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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 system security CONDUCT
DNV GL is committed to upholding an appropriate
standard of information handling security. Therefore,
you are not allowed to use information in a way that
may jeopardize the integrity of DNV GL.

Information considered illegal, offensive or inappro-

We are expected to conduct ourselves and
priate must not be accessed, processed, downloaded, our business with respect and sensitivity.
stored or disseminated on your work computer.
Installing software or downloading, storing, using or
disseminating data or information in breach of copyright
laws or provision is prohibited. Material of a sexual 5.1 We value independence
nature is considered inappropriate. You must not, directly or indirectly, accept gifts which
are intended to influence business decisions, except
for promotional items of minimal value normally bearing
4.13 Internal monitoring systems a company logo. You may accept other gifts in situations
Internal controls are an integral part of DNV GL’s where it would clearly give offense to refuse, in which
ongoing business activities and ensure that we case the gift must be handed over immediately to your
adhere to the applicable laws and internal regulations. line manager and will be regarded as DNV GL property.
Their purpose is to allow the continuous inspection
and improvement of all company procedures. We will Hospitality, such as social events, meals or entertain-
ensure that our monitoring system is suitable and ment can be accepted if there is a clear business
meets all applicable legal requirements. reason for DNV GL.

4.14 Risk management 5.2 We value impartiality and integrity

Taking risks can not only jeopardize the reputation You must not, at any time, participate either directly
and business success of DNV GL, but result in damage or indirectly in any kind of business or activity that com-
to customers, business partners and colleagues. petes with or is detrimental to the interests of DNV GL.
In order to identify and minimize potential risks at an The same is true if it has the effect or the appearance
early stage, and to avert potential damage, DNV GL of affecting the impartiality and integrity of DNV GL
has a risk management policy and process in place. 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 where 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 authorized 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 company 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 DNV GL.
If you comment on any aspect of DNV GL business
DNV GL is against the purchase of sexual services. or issues, you must clearly include a disclaimer that
When representing DNV GL, you must refrain from the views are your own and not those of DNV GL.
purchasing sexual services.
You are legally responsible for your social media
posts, unless the posting has been specifically
approved by authorized 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

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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
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. QUESTIONS
In most cases, concerns about possible breaches
of the Code should be reported directly to your line
If you have any questions on the content of this Code,
manager. Most cases can and should be handled
please contact your line manager, the Compliance
locally in the line organization, or be referred to
Officer, the HR Department or the internal DNV GL
the Compliance Officer.
Ombudsman.
You may also report your concerns directly to a

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DNV GL Ombudsman. DNV GL has an internal and an
external Ombudsman. All contacts with the Ombuds-
men will be treated anonymously at your request.

The Ombudsmen report violations of the Code

of Conduct directly to the Compliance Officer.
The Compliance Officer will thoroughly investigate
APPENDIX
and clarify the reported violations with the support
of the respective operational management and in
close collaboration with the Ombudsmen. DMSG-0-2-A1
(For a professional printing version please refer to
If a concern is expressed in good faith relating to Brand Central.)
a possible violation of the Code to sources inside
or designated by DNV GL, DNV GL will not permit
retaliation in any form.

8 ©DNV GL 05/2018